Contractor management services

From 1 October 2026, the definition of providing labour hire services under the Labour Hire Licensing Act 2018 (Vic) will be amended. You should review these changes to determine whether you or the entities you source labour from are now required to hold a labour hire licence.

Substantial penalties may apply if you provide labour hire services without a licence or engage an unlicensed provider.

The Labour Hire Licensing Regulations 2018 will also be amended to support these legislative changes. As the amended regulations are not yet in force, some guidance on this website may not fully reflect the updated legislative framework. This guidance will be updated once the amendments to the regulations commence.

Contractor management services are a form of labour hire where a provider recruits or places one or more individuals who are engaged as independent contractors with another person, under an arrangement entered into between the provider and that person, that is wholly or principally for recruiting individuals to supply labour for another person or placing individuals with another person to perform labour for that person.

The provider then manages the performance of those individuals under the arrangement.

This covers arrangements where a business (the provider) recruits individuals who are engaged as independent contractors for a third party (the host) and manages their performance under the arrangement, even if the individuals are engaged or paid directly by the host.

Examples of businesses captured by this provision include businesses that recruit or place individuals who are engaged as independent contractors and then provide ongoing functions such as administration, payroll, supervision, or performance management for the host.

Under Victorian law, labour hire providers must hold a licence, and businesses must only engage licensed providers to supply workers.

Licensing helps to ensure labour hire companies meet their obligations to workers, and supports fairness, transparency, and integrity in the industry. 

Labour hire providers must comply with a range of legal obligations, including around worker pay and conditions, superannuation and taxation.

Senior decision-makers, and anyone else who influences or controls the business, must also be ‘fit and proper’ – in terms of their legal and compliance history, as well as their honesty, integrity and professionalism. 

The Labour Hire Authority (LHA) oversees Victoria’s labour hire licensing scheme, including its monitoring, compliance and enforcement. 

Under the Labour Hire Licensing Act 2018 (Vic), penalties for using or providing unlicensed labour hire services may exceed:

  • $660,000 for a corporation
  • $160,000 for an individual.

Penalties also apply for advertising labour hire services without a licence, or before a licence application is approved. Any subcontractors to a labour hire provider must also be licensed.

More information

For information on legal obligations, licence applications, renewals and further resources, visit the Provider page.

Providers can apply for and renew a licence via the Labour Hire Licensing Online portal.

Providers must pay a licence application fee at application and licence renewal. Licence fees are also payable annually. For more information, please visit the Licence fees and costs.

Scenarios: When is a labour hire licence required?

The examples below are for illustrative purposes only. You should consider your particular circumstances and seek legal advice if you are unsure.

Scenario 1

Excellent Contractors Pty Ltd (Excellent Contractors) enters into an arrangement with ABC Sports Club Inc for the recruitment and placement of relief chefs. ABC Sports Club Inc directly engages and pays the chefs as independent contractors. However, Excellent Contractors Pty Ltd recruits the chefs and manages the performance of those individuals under the arrangement, including payroll administration.

Considering the arrangement as a whole, it is wholly or principally for the recruitment of individuals to supply labour for ABC Sports Club Inc, together with the management of their performance. Excellent Contractors Pty Ltd is providing labour hire services under section 8(2) and must hold a labour hire licence.

Scenario 2

XYZ Pty Ltd (XYZ) engages Top Talent Recruiting Pty Ltd (Top Talent) to source and place IT professionals. Top Talent identifies, interviews, and recommends candidates, after which XYZ directly engages the individuals. Top Talent has no ongoing role in managing the individuals' performance.

In this case, the arrangement is limited to recruitment services. Although Top Talent recruits and places individuals, it does not manage their performance under the arrangement. As one of the elements of section 8(2) is not satisfied, Top Talent Recruiting Pty Ltd is not providing labour hire services under section 8(2) and is not required to hold a labour hire licence.