Targeting high-risk industries and high-impact harms – outcomes in 2025-26
5 November 2026
The Labour Hire Authority (LHA) Annual Report 2025-26 showcases the outcomes of LHA’s compliance and enforcement program targeting high-risk industries and high-impact harms.
The program leverages data and intelligence to address specific harms across industries, as well as targeting industries including horticulture, construction and security across Victoria.
Horticulture
The horticulture industry has a higher risk of worker exploitation due to the seasonal and transitory nature of the work, and the number of migrant workers, including those in the PALM scheme.
The industry also poses a regulatory challenge, as bad actors move across the state with the harvest season, with solid evidence that they orchestrate harms across regional or jurisdictional boundaries.
Since the scheme began in 2019, LHA has taken more compliance and enforcement action against labour hire businesses in horticulture than in any other industry area, cancelling 280 licences, refusing 218 licence applications and imposing more than $3 million in penalties for non-compliance.
In 2025-26, LHA continued to expand its focus on hosts’ compliance with labour hire laws, bringing five growers in the horticulture industry before the courts for allegedly engaging unlicensed providers, including four Swan Hill farms and a Yarra Valley orchard. The hosts each face maximum penalties exceeding $660,000 per contravention.
Other compliance and enforcement action in horticulture in 2025-26 included:
- In June 2026, a record $830,000 in penalties were issued to an unlicensed provider who advertised for horticulture work in Mildura.
- In March 2026, LHA filed nine criminal charges against a director of a labour hire company for providing false information to LHA.
- Also in March, four people were arrested after an LHA investigation into alleged money laundering operation in Mildura.
- In late 2025, LHA imposed conditions preventing a labour hire provider operating in horticulture from charging workers for overcrowded, unsanitary and unsafe accommodation at two Warragul properties.
- In November 2025, LHA filed eight criminal charges against the owner of a labour hire company, alleging that he knowingly provided false information to LHA.
- In July 2025, penalties of $91,000 were issued to a Queensland business and director who advertised while unlicensed for grape workers in Mildura.
LHA carried out 54 site inspections and 23 inspections of worker accommodation, targeting areas of Victoria that have higher levels of non-compliance, such as the Yarra Valley, Mornington Peninsula and Mildura.
Collaboration between agencies, and the involvement of federal agencies, are key to removing exploitative providers from the industry and protecting workers, and in 2025-26 LHA conducted joint operations with the Fair Work Ombudsman (FWO) in Mildura, the Mornington Peninsula and Pakenham.
LHA continues to work collaboratively with law enforcement agencies and other regulators to ensure that non-compliance can be investigated and enforced across workplace laws and obligations under each regulator’s jurisdiction.
Construction
Labour hire has been a feature of the construction industry for decades, and businesses that provide labour hire workers to construction sites must comply with their obligations under the Labour Hire Licensing Act 2018 (Vic).
In 2025-26, LHA took a range of regulatory actions against labour hire companies in Victoria’s construction industry, often in response to practices that may be unlawful or coercive, or reflect widespread non-compliance.
LHA actions during the year included:
- cancelling the labour hire licence of B K Labour Hire, having formed the view that the company and/or its director provided false or misleading information.
- cancelling the labour hire licence of 24/7 Personnel, following an investigation finding that the company had failed to declare Jay (Jie) Zhu as a relevant person, and knowingly provided false and misleading information to LHA – a criminal offence under the LHL Act.
- cancelling the licence of XF Victoria Pty Ltd, finding that the company had failed to declare Daniel Salter as a relevant person
- refusing an application by Women in Construction to renew its labour hire licence, as it was not satisfied that director Luke Ellery and other relevant persons were fit and proper. LHA also identified that multiple relevant persons had not been disclosed to it.
In addition, two companies in Victoria’s construction industry elected to cancel their labour hire licences after LHA commenced investigations into them. Both were associated with other businesses that had been subject to recent LHA licensing action.
A dedicated internal taskforce leads LHA’s work to investigate and address unlawful behaviour in the construction sector. LHA is a member of a number of cross-jurisdictional regulatory and law enforcement groups addressing alleged criminal or unlawful conduct in the construction industry.
LHA is also a member of the Victorian Government’s alliance of regulators, law enforcement and other entities working to address allegations related to Victorian Government construction sites.
LHA’s construction taskforce works closely with a range of primary regulators and law enforcement agencies to detect, disrupt and deter non-compliance through:
- sharing data and intelligence
- collaboration when assessing licence applications
- compliance monitoring and investigations
- joint field activities.
Security
Security work often involves complex supply chains, where a principal contractor sources workers from a subcontractor to supply to the principal contractor’s client. This can be a lawful business model, but it carries an inherent increased risk of non-compliance.
Providers are free to enter into arrangements with hosts, intermediaries and subcontractors as they see fit. However, contract prices must be sufficient to cover the cost of meeting legal obligations for wages, superannuation, leave entitlements, portable long service leave and workers’ compensation insurance.
Where contract prices fall below the minimum cost of meeting these obligations, there is a risk that the provider or another party in the supply chain is not complying with the law.
Supply chain transparency and responsibility is crucial not only to protect workers from exploitation, but also to disincentivise, detect and respond effectively to taxation non-compliance and illegal phoenix activity perpetrated through complex supply chains.
In 2025–26, a significant multi-agency operation led to the cancellation of MA Services Group Pty Ltd’s licence.
LHA revealed that some major Australian corporations had entered into underpriced contracts with MA Services Group, a security company that underpaid workers, did not comply with taxation and other laws, and entered external administration with significant debts owed to workers and creditors, including the government.
LHA cancelled the labour hire licence of MA Services Group in January 2026. The company can no longer operate or advertise in Victoria.
LHA had earlier imposed extensive conditions on MA Services Group’s labour hire licence, including requiring additional reporting that supported further action against the company.
LHA analysis of the company’s contracts revealed a troubling, two-tier pricing approach: while clients such as government agencies were billed ‘by the book’, some other large corporate clients paid rates too low for MA Services Group to cover its costs if it paid wages, benefits and taxation at lawful rates.
The issue highlights the need for action on multiple fronts, and the need to hold large, price-setting companies to account for conditions in their supply chains.
Insolvency and external administration
Insolvencies of labour hire providers are of particular interest to LHA. Workers often lose wages and entitlements, and non-compliant providers can undercut lawful competitors, such as by not meeting tax obligations.
In June 2026, LHA cancelled the labour hire licence of Hudson Global Resources Pty Ltd (Hudson), effectively banning the company from providing labour hire in the state.
LHA formed the view that Hudson contravened the LHL Act, noting:
- the significant history of unlawful conduct by Hudson, including breaches of workplace, taxation, corporations and labour hire laws
- substantial unpaid debts to workers, the government and creditors, including over $8 million in unpaid superannuation and wages, and an ATO debt of over $20 million
- issues with compliance capacity, given that Hudson was under external administration, subject to active criminal proceedings from ASIC, had traded at a loss for several years, and had not demonstrated meaningful accountability or governance reform
- several transactions identified by the company administrator as likely representing breaches of directors’ duties, including forgiveness of $11 million in debts owed by related companies
- failure to declare its CEO and other executives as decision-makers within the company, in contravention of the LHL Act.
The stronger labour hire licensing laws that took effect in Victoria on 1 June 2026 were applied in the cancellation of Hudson’s licence.
Wages and conditions
In their licence application, a labour hire businesses must correctly identify the legal instrument underpinning payments to their workers, such as the relevant award or enterprise agreement.
Licence applicants must declare how they plan to comply with legal obligations, including workplace laws and laws relating to taxation and superannuation. An applicant who cannot nominate the correct industrial instrument may put workers at risk of exploitation and LHA has a lower risk tolerance for this in high-risk contexts, such as horticulture.
In 2025-26, an LHA investigation into a licensed provider supplying workers to a manufacturing factory led to the provider paying 17 workers over $135,000 in total to rectify underpayments.
LHA received intelligence that labour hire workers supplied at the manufacturing factory were allegedly being underpaid.
A worker reported to LHA compliance officers that they were working as a forklift driver and had qualifications to be paid as a Level 3 Warehouse Operator but were being paid as an unskilled labourer. They estimated they were being underpaid by around $10 per hour.
The worker believed that up to 15 other workers were also being underpaid. They informed LHA that they had tried to resolve the issue with the provider but had been unsuccessful.
During an LHA investigation, the provider acknowledged that 17 workers had been paid at the wrong rate under the relevant award, due to a breakdown in communication between the factory and the provider.
As the provider cooperated with LHA, explained the reason for the error and rectified the underpayments, LHA allowed the provider to keep its licence.
LHA continues to monitor their compliance with relevant laws, and further non-compliance may lead to the provider’s licence being cancelled.
Standard conditions
In 2025–26, LHA commenced imposing standard conditions on all new licences in horticulture, security, commercial cleaning and meat and poultry processing industries, due to higher risks of worker exploitation and unlawful conduct in those industries. LHA will also apply the standard conditions progressively to existing licences.
The standard conditions target significant harms that affect workers, the community, and businesses doing the right thing.
The conditions increase transparency by:
- ensuring that all workers receive information on their rights
- requiring that providers report to LHA on the use of subcontractors, payroll services and any change in industry.
The conditions also promote integrity by:
- restricting cash payments to workers and subcontractors, as businesses operating in the cash economy carry a higher risk of worker exploitation and non-compliance with legal obligations
- prohibiting the supply of workers engaged as independent contractors to hosts, given LHA’s view that workers who are engaged to perform horticulture activities are usually employees, not genuine independent contractors, and misclassification of employees and sham contracting cause harm
- limiting subcontracting to one layer, to manage the increased risks of non-compliance with workplace, taxation, superannuation, and occupational health and safety laws in complex supply chains
- setting clear requirements for personal protective equipment to be provided to workers free of charge
- outlining clear requirements around the provision of worker accommodation, as overcrowded, unsafe and unsanitary accommodation is common in the horticulture industry.
Read the full report
Read the full Labour Hire Authority Annual Report 2025-26.