High-impact outcomes and targeting non-compliance in high-risk industries in 2024-25

6 November 2025
High-impact outcomes and targeting non-compliance in high-risk industries in 2024-25

The Labour Hire Authority (LHA) Annual Report 2024-25 showcases the outcomes of its compliance and enforcement program in high-risk industries such as meat processing, security, construction and horticulture.

The report highlights actions taken by LHA to remove exploitative operators, address a range of unlawful conduct, and intervene to protect workers, including:

  • decisive action taken against unlawful providers, with over 600 licences refused or cancelled, high-value assets seized, and LHA’s first criminal charges filed
  • 335 investigations finalised and 145 field activities conducted
  • a record penalty of $759,674 secured against construction companies and directors involved in unlicensed operations
  • growing awareness of obligations across industry and the community, with targeted engagement and communications reaching tens of thousands of labour hire stakeholders across the year.

Throughout the year, field activities undertaken by LHA officers identified several key compliance issues across all industries, including:

  • hosts engaging unlicensed providers
  • non-compliance with labour hire industry laws or other workplace laws (such as taxation and superannuation)
  • underpayment of workers.

In 2024-25, non-compliance was prosecuted through the Supreme Court of Victoria, where LHA took legal action leading to nearly $1.6 million in total penalties imposed on businesses and individuals across several judgements.

LHA took enforcement action through court proceedings across a wide range of industries, occupations and regions. In 2024-25, action was taken against both companies and individuals, and a range of civil penalty contraventions and criminal offences were prosecuted.

Significant outcomes in 2024-25 included:

LHA increased collaborative efforts with Commonwealth, State, Territory and Local government regulators and law enforcement agencies in 2024-25 to detect and deal with significant non-compliance resulting in harm to workers, the labour hire industry and the community.

LHA became an active member of State and Commonwealth-led multi-agency taskforces established in 2024-25 to respond to the infiltration of the construction industry by organised crime. LHA also spearheaded multi-agency field operations at farms in Victorian regions where there is a high risk of exploitation and non-compliance.

Focus on targeted industries

LHA has continued to strengthen its compliance and enforcement program, achieving significant outcomes across industries, occupations and regions.

The program focuses on high-risk industries and high-impact harms, leveraging data and intelligence to direct activities.

Targeted industries included meat and poultry processing, commercial cleaning, security and horticulture, with specific harms targeted across industry areas.

Meat and poultry processing compliance program

LHA enhanced its focus on the meat and poultry industries in 2024-25, undertaking targeted inspections at metropolitan and regional facilities and taking licensing action against non-compliant providers.

Labour hire workers in the meat and poultry processing industries were the target of a communication campaign to raise workers’ awareness of their rights and how to report unlawful treatment by labour hire businesses. The campaign was launched across digital, social media and press channels.

The meat and poultry processing industries have historically seen significant rates of worker mistreatment and exploitation, so are defined as prescribed industries under the Labour Hire Licensing Act 2018 (Vic).

These industries are at higher risk of worker exploitation due to their high proportion of migrant workers from a range of backgrounds, including PALM scheme workers.

During inspections undertaken in 2024-25, LHA inspectors observed:

  • host businesses using unlicensed labour hire providers
  • unsafe and unhygienic working conditions
  • workers being unreasonably charged for tools required for their work
  • deficient personal protective equipment
  • non-compliant worker accommodation
  • cash payments and failure to contribute superannuation
  • exploitation of PALM scheme workers, including concerns around ‘poaching’.

LHA’s investigations have identified the use of complex supply chains, with multiple layers of subcontracting. There is an inherent increased risk of non-compliance in complex supply chains, due to the arrangements not always being transparent to regulators. In addition, potential illegal phoenix activity and low contract prices has been identified, which would not enable providers to meet their obligations to workers.

In 2024-25, LHA refused the licence application of a large labour hire provider operating in the meat processing industry for non-compliance with the Act and cancelled the licences of several other labour hire providers in the meat industry. The licence of one provider was cancelled after LHA established that they were making unlawful deductions from their worker’s wages.

Up to June 2025, LHA has refused 37 applications and cancelled 39 licences for businesses operating in the meat and poultry processing industries.

Security compliance program

Businesses that supply security guards and crowd controllers to venues such as hotels, clubs, pubs, events, and retail and commercial premises are generally considered to be labour hire providers. The security industry can often involve the supply of labour through complex supply chains.

Up to June 2025, LHA has participated in three significant multi-agency operations focused on taxation non-compliance and illegal phoenix activity in complex supply chains in the security industry. These compliance risks are being identified more regularly in LHA’s own investigations.

LHA continues to work with other regulators such as Victoria Police’s Licensing Regulation Division (LRD) and the Australian Taxation Office (ATO) including by:

  • strategically providing intelligence and information to relevant regulators to support timely action
  • working together to identify and take action against the true controlling minds behind these behaviours.

LHA has cancelled 45 labour hire licences and refused 19 licence applications in the security industry to June 2025, after uncovering non-compliance with legal obligations through its intelligence-led compliance program.

After a lengthy investigation, LHA imposed supply chain responsibility and transparency conditions on a major provider in the security industry in 2024-25.

It was identified that a number of the provider’s contracts with subcontractors contained low contract prices, which would not cover compliance with minimum legal obligations to workers.

LHA imposed supply chain transparency and responsibility conditions on the provider. LHA now has oversight over the provider’s arrangements, enabling LHA to monitor compliance within the provider’s supply chain to ensure workers receive their entitlements.

Construction compliance program

LHA took a range of actions against labour hire companies in Victoria’s construction industry in 2024-25, including in response to practices that may be unlawful, coercive or reflect widespread non-compliance.

To June 2025, LHA has cancelled 126 licences and refused 44 licence applications from businesses in the construction industry, including businesses operated by organised crime or outlaw motorcycle gang (OMCG) figures. LHA has also imposed conditions on 26 licences.

The focus on the construction industry saw the highest total penalty for breaches of labour hire law in Australia issued by the Supreme Court of Victoria in September 2024.

A total of $759,674 in penalties were issued to five companies and three company directors for their involvement in unlicensed labour hire operations. The penalties reflected unlawful conduct across multiple layers of subcontracting.

In December 2024, the Victorian Government announced that LHA’s regulatory powers would be strengthened to further address unlawful conduct in the construction industry.

For more information on compliance in construction in 2024-25, read LHA year in review 2024-25.

Horticulture compliance program

LHA’s compliance and enforcement activities continued to focus on the horticulture industry in 2024-25.

LHA’s focus on horticulture has led to significant compliance and enforcement outcomes, improving fairness for businesses and workers.

This included several visits to horticulture hosts in 2024-25 across Victoria:

LHA has taken a range of actions against businesses operating in the horticulture industry for non-compliance with the LHL Act, including cancelling 227 licences and refusing 178 licence applications to June 2025.

From May to June 2025, LHA ran a statewide communications campaign targeting horticulture hosts across digital and traditional media channels.

A web page, featuring multilingual resources and information about checking labour hire licences and the benefits of using licensed providers, continues to be promoted in LHA advertising and communications.

Since being established in 2019, LHA has taken more compliance and enforcement action against labour hire businesses in horticulture than in any other industry area.

Read the full report

You can read the Labour Hire Authority Annual Report 2024-25 in full on the LHA website.