Labour hire supply chains: why hosts in Victoria and SA need to check more than the first name on the invoice

Most businesses that use labour hire have, at some point, asked the right first question: is my provider licensed? We wrote about that earlier this year. What the last few months have added is a second question: who else is in the chain?

It matters because plenty of labour arrives on site through more than one company. A provider you trust subcontracts a crew to another outfit. A "workforce solutions" business sits in the middle, placing workers it doesn't employ. Two changes in Victoria and South Australia are aimed squarely at that layering, and hosts are named in both.

What changed in Victoria

The Labour Hire Authority (LHA) says two sets of changes matter here.

1 June 2026: tougher licensing for providers. The LHA says the changes apply to all licence holders and applicants. Decision-makers and anyone who exerts control over a labour hire business must pass a stronger "fit and proper person" test, which now looks at factors including character, professionalism and integrity. Businesses must declare whether someone else, such as a shareholder, holding company or influential relative, substantially influences a nominated officer. They must also declare that they are financially viable. The LHA can look at a wider range of compliance history, including bankruptcy, consumer protection and corporate law, and can ask for a compliance plan specific to the business rather than a generic template.

The LHA also describes new standard licence conditions for high-risk industries: horticulture, meat and poultry processing, commercial cleaning and security. They cover things like information for workers on their rights, reporting on subcontractors, limits on cash payments, and rules on accommodation and PPE. The LHA's page lists no new host duties from the 1 June changes.

1 October 2026: supply chains. This is the one hosts should read twice. The LHA says the definition of labour hire now focuses on whether labour supply is involved, and that in most cases this doesn't change when a licence is needed. But it makes clear that a licence is needed to supply labour anywhere in a supply chain, including "bare intermediary" companies that on-supply workers employed by others. The LHA says the aim is to improve accountability of hosts and of providers who subcontract.

The stakes are real. The LHA states that maximum penalties for breaching licence conditions are more than $160,000, and that maximum penalties per breach of the Labour Hire Licensing Act 2018 exceed $660,000 for a company and $160,000 for an individual. As at 30 June 2026 it reported 5,655 licensed providers, more than 500 applications refused and more than 1,000 licences cancelled.

A separate change is coming for construction on 18 January 2027, for certain activities on Victorian Government-funded projects over $50 million. If that's your world, read the LHA page directly.

What changed in South Australia

South Australia's scheme now reaches every industry. According to Consumer and Business Services (CBS), from 29 January 2026 all labour hire firms and workers are covered by the same laws, and providers in newly covered industries were given a six-month grace period until 29 July 2026 to become licensed. SA.GOV.AU says hosts must make sure their provider is licensed from 29 July 2026. It also says providers in newly covered industries whose applications were paid and accepted on or before 29 July 2026 can be used until their application is finalised.

For hosts, the state's guidance says:

• You must not enter an avoidance arrangement. It is against the law if you know, or reasonably should have known, that you entered into one.
• If it is reasonable that you'd be aware of non-complying labour, you must report it.
• Inspectors can enter workplaces, sometimes without notice.
• You can check the licensed provider register, and ask a provider awaiting a licence for its application acknowledgement email.
• If an agent or intermediary is involved, you can expect them to give you the licence number and details of the provider that sourced the workers.

The page doesn't give dollar penalties for hosts, only that using an unlicensed provider after 29 July 2026 risks "significant penalties". CBS and SafeWork SA say the same about the deadline.

What this means in practice

Neither state is asking hosts to become investigators. But "we only deal with one company" stops being a complete answer if that company is passing the work on. Here is what we'd do if we were buying labour hire in Victoria or SA:

1. Ask who actually employs the people on site. The name on the invoice and the name on the payslip are not always the same.
2. Ask whether any part of the crew comes through a subcontractor or intermediary, and get that company's name and licence number. South Australia's guidance says you can expect this from an intermediary.
3. Check every name on the public register, not just the first one. It takes minutes. Keep a screenshot or note with the date.
4. Keep a list of everyone working on your site. That is SA's own suggested practice, and it makes the rest much easier.
5. Sanity-check the price. SA's guidance suggests checking that contract prices cover award and agreement costs. If a rate looks too good to be true, ask why.
6. Write it into the agreement. Licence numbers, a duty to tell you before subcontracting, and a right to ask for evidence of pay and super.

Where we stand

We hold labour hire licences in Victoria and South Australia, and our licence numbers are on our agreements. You can check them on the public registers before we send anyone. If part of a job ever involved another provider, we'd tell you who, and expect you to check them as well.

That isn't a pitch for paperwork for its own sake. The honest case for licensing is that it separates providers who pay people properly and insure them from those who don't, and the supply chain rules close the gap where that separation used to blur.

If you're not sure whether your current arrangement has a hidden layer in it, ask us and we'll talk it through, or start with our guide to briefing a labour hire agency.

This is general information, not legal advice. Get advice on your specific situation, and check the Labour Hire Authority or SA Consumer and Business Services for the current rules.