Providers in the security industry can face licensing action for incorrectly applying the Registered and Licensed Clubs Award 2020

7 May 2026
Providers in the security industry can face licensing action for incorrectly applying the Registered and Licensed Clubs Award 2020

The Labour Hire Authority (LHA) has found that some labour hire providers in the security industry are underpaying workers by using the incorrect award.

As well as being unfair to workers, paying workers on a lower award rate can disadvantage legitimate businesses, by making it harder for them to compete and win contracts against companies with artificially low-cost structures. 

While many awards are based on the industry a business operates in, some awards are based primarily on the occupation of a worker, regardless of the industry of the overall business. 

By law, all employers must apply the award that is most specific to the employer’s industry and the employee’s work. 

If a security officer is engaged via a labour hire arrangement, then the worker must be paid under the Security Services Industry Award 2020 (SSIA).

However, LHA has identified instances of security officers being paid under the Registered and Licensed Clubs Award 2020 (RLCA) when engaged via a labour hire arrangement to provide security services at a club venue.

This award only applies if the security officer is employed directly by the club venue; it does not apply to labour hire workers, who must be paid under the SSIA.

By applying incorrect award rates, workers are lawfully underpaid, often by significant amounts – up to $9 per hour. This also results in underpayment of superannuation.

The table below outlines the clear differences between the two pay rates.

 

Full-time grade 1 doorperson/security officer under RLCA

Full-time level 1 security officer under the SSIA

Difference

Monday to Friday day

$25.85 (7:00am to 7:00pm)

$27.13 (6:00am to 6:00pm)

$1.28

Monday to Friday night

$28.66 (7:00pm to midnight) or $30.07 (midnight to 7:00am)

$33.02 (6:00pm to 6:00am) or $35.27 for permanent night shift workers

Up to $6.61

Saturday

$38.78

$40.70

$1.92

Sunday

$45.24

$54.26

$9.02

Public holiday

$64.63

$67.83

$3.20

By applying the wrong award with lower hourly rates, businesses are also unlawfully lowering costs for wages, superannuation, portable long service leave, and workers’ compensation insurance. This means they can quote for security jobs based on incorrect lower costs, which puts businesses who quote correctly – based on the SSIA rates – at an unfair disadvantage.

Providers that are unwilling or unable to comply with their legal obligations face licence cancellation.

The Fair Work Ombudsman (FWO) provides support, advice and information for employers on employee entitlements and relevant Awards. Use the ‘Find my Award’ tool to find the relevant award for an industry and job title – to access the tool, visit the FWO website.

Businesses should seek legal advice if uncertain of the correct award rate that applies to their employees.

Recent changes for the security industry

Businesses that engage or supply security workers should also be aware of amendments to the Private Security Act 2004 (Vic) and the new Private Security Regulations 2025 (Vic) that came into effect in 2025 to ensure they continue to meet their legal obligations.

Some of these changes are designed to protect workers from exploitation and improve transparency and integrity within the industry – in line with LHA’s objectives.

To deter intentional misclassification of workers, the amendments include a new requirement that workers engaged as independent contractors hold a private security business licence, in addition to a private security individual operator licence.

Security businesses involved in non-compliance with this new obligation may be subject to compliance action by Victoria Police’s Licensing and Regulation Division (LRD) and have their licence cancelled by LHA.

For more information on the changes, see our April 2025 article.

More information

LHA’s Guidance for the security industry: cost of meeting your legal obligations has been updated for the 2025-26 financial year.

LHA uses its security industry guidance as a benchmark for assessing risks of non-compliance.

Low contract prices can signal a heightened risk of non-compliance with a provider’s legal obligations, including those related to workers’ pay, entitlements, and taxes.

Some security businesses use the guidance to support their own compliance, and to highlight to clients the cost of meeting legal obligations to workers. Industry feedback suggests it is a valuable tool in contract negotiations.