The Penalty Most Host Employers Do Not Know They Carry
Most Queensland manufacturers know that labour hire providers must be licensed. Far fewer know that the law puts the business using the workers at the same risk as the business supplying them. If you bring in electricians, fitters or operators through a provider that turns out to be unlicensed, the maximum penalty you face is identical to the provider’s.
This guide explains what Queensland’s labour hire licensing scheme requires of host employers, how to check a provider properly, the traps in the public register and how to build the check into the way your plant engages labour.
What the Law Says
The scheme is set out in the Labour Hire Licensing Act 2017 (Qld). Three sections matter to a host.
Section 10 makes it an offence to provide labour hire services without a licence.
Section 11 makes it an offence to enter into an arrangement with a provider who does not hold a licence. This is the host’s offence.
Section 12 makes it an offence to enter into an arrangement designed to avoid the Act.
All three carry the same maximum penalty: for an individual, 1,034 penalty units or three years imprisonment, and for a corporation, 3,000 penalty units.
What That Means in Dollars
The value of a Queensland penalty unit rose to $172.70 on 1 July 2026. At that value, 1,034 penalty units is $178,571.80 and 3,000 penalty units is $518,100.
Those are maximums, and a court would consider the circumstances. The point is the symmetry. A plant manager who signs up an unlicensed provider is exposed in the same way as the person running that provider. An assumption that they were licensed is a weak position to argue from. A dated record showing that you checked the register is a strong one.
Who Counts as a Labour Hire Provider
Broadly, a business provides labour hire services if, in the course of carrying on business, it supplies a worker to another person to do work. The worker remains engaged by the provider and does the work for the host.
In a manufacturing plant this covers the obvious cases: production operators supplied for peak season, tradespeople placed to cover a roster gap, and shutdown crews supplied to work under your direction. It is less obvious where a contractor is engaged to deliver an outcome with its own people, supervision and methods. Not every contracting arrangement is labour hire, and the line can be fine. If workers from another business are effectively working as part of your team, under your supervision, treat it as labour hire until you have confirmed otherwise.
How to Check a Licence
Queensland publishes a register of labour hire licences that anyone can search online, free of charge. A proper check takes about five minutes.
Search the legal entity, not the trading name. Licences are held by legal entities. The name on the side of the van may not be the name on the licence. Ask the provider for the legal name and ABN of the entity you are contracting with, and search for that.
Confirm the status is active. Licences can be suspended, cancelled or expired.
Check the expiry date. Note it, because a licence that is active today may lapse during your engagement.
Read any conditions. A licence may be granted with conditions attached, and they are shown on the register.
Match the details to your paperwork. The entity on the register should be the entity on the contract and on the invoices.
Keep a record. Save a dated copy of the register entry. If your decision is ever questioned, it is evidence of what you checked and when.
The Pending Application Trap
The register site also publishes a list of pending applications. It is easy to mistake an entry on that list for a licence. It is not one. A provider that has applied and is waiting for a decision does not hold a licence, and a provider with only a pending application cannot lawfully be used.
New providers and providers that have restructured into a new entity are where this most often goes wrong. The people and the phone number are the same, but the legal entity is new and its licence has not yet been granted.
Checks Are Not a One Off
A check at onboarding protects you on day one. Engagements with labour hire providers often run for years. Build in three further points.
Check again at each contract renewal. Diarise each provider’s expiry date and check the register a few days after it. Check whenever something changes, such as a new entity name on an invoice, a change of ownership or a different ABN.
It is also reasonable to put obligations in your contract: that the provider holds and will maintain a licence, that it will tell you immediately of any suspension, cancellation or condition, and that it will not subcontract the supply to another provider without your agreement and without that provider also being licensed.
Licensing Is Not the Only Shared Obligation
A licence tells you the provider has met the scheme’s requirements. It does not transfer your safety duties. Under work health and safety law, the host and the provider both owe duties to a labour hire worker, and they are expected to consult, cooperate and coordinate with each other.
In practice that means the host inducts the worker to the site, provides safe plant and systems of work, supervises appropriately and tells the provider about the hazards of the role. The provider confirms the worker has the licences and competencies the role needs and stays in touch about how the placement is going. Neither can assume the other has it covered.
For electrical roles there is a further check. An electrician must hold a current Queensland electrical work licence, and that too can be confirmed on a public register in a couple of minutes.
Avoidance Arrangements
Section 12 is aimed at structures set up to sidestep the scheme, such as dressing up a labour supply as something else. A host that knowingly takes part is exposed to the same maximum penalty. If a provider proposes an unusual structure and the explanation involves not needing a licence, take advice before agreeing.
A Five Minute Procedure for Your Plant
Make the check part of engaging any labour, not something that depends on a person remembering.
Before a purchase order is raised for supplied labour, the legal name and ABN are obtained. The register is searched for that entity. Status, expiry and conditions are recorded and a dated copy saved. The expiry date goes into a calendar. The contract carries the licence clauses. The check is repeated at renewal and after expiry.
Give the task to a named role, such as procurement or the maintenance planner. The cost is minutes a year. The exposure it removes is measured in hundreds of thousands of dollars.
Check Us
BevTech holds a Queensland labour hire licence, and we would sooner you verified that than took our word for it. The licensee is Bev-Tech Engineering Pty Ltd and the licence number is LHL-01447-W5F6V. It was issued on 29 June 2018, is active with no conditions, and runs to 29 June 2027. Search the register for that entity and you will find the same details.
We are a family owned engineering business in Richlands, Brisbane, with more than 25 years in beverage and FMCG manufacturing. We supply industrial electricians, PLC and automation engineers, fitters and turners, machinists, fabricators and production operators for shift cover, peak periods and shutdowns, backed by our own engineering team and machine shop. If you would like to talk about labour hire or shift cover for your plant, use the contact form at bevtech.com.au/contact.
This article is a general guide current as at October 2026 and is not legal advice. Penalty unit values change each July. For advice on a specific arrangement, speak to a lawyer or the Queensland labour hire licensing regulator.
