Labour hire software in Australia: licensing, Same Job Same Pay and host timesheets

Where does labour hire licensing stand, state by state?

Four jurisdictions license labour hire providers at the time of writing (November 2026), and the rules moved in three of them this year. Licensing attaches to where the work is done, so a provider based in one state that supplies workers into another needs to meet that state’s scheme too. Date stamp anything you build on this table; it will change again.

Jurisdiction	Status (November 2026)	What it means for your systems
Victoria	Licensing under the Labour Hire Licensing Act 2018. Stronger fit and proper person and financial viability tests in 2026; supply chain definition clarified from 1 October 2026; prescribed construction roles from 18 January 2027	Track decision makers, viability evidence, subcontractors and high risk industry licence conditions
Queensland	Licensing under the Labour Hire Licensing Act 2017	Six monthly reports within 28 days of each period ending
South Australia	All industries covered since 29 January 2026; newly covered providers had until 29 July 2026	Every SA placement now needs a licensed provider
ACT	Licensing under the Labour Hire Licensing Act 2020	Separate licence and obligations
NSW	No scheme. On 2 October 2026 the government committed to release a bill within 100 days if re elected	Design for it now: hosts would have to use registered providers

Victoria’s construction change is narrow but sharp. From 18 January 2027, traffic management, site security, concreting and crane operating on Victorian Government funded construction projects worth more than $50 million are covered, and the LHA puts maximum penalties above $660,000 per breach for a company and $160,000 for an individual. If you supply any of those roles, your booking system needs to know which sites are in scope.

How do you pay Same Job Same Pay correctly?

When a regulated labour hire arrangement order covers a host, you must pay each covered worker at least the protected rate of pay for their work at that host, which is generally the full rate under the host’s enterprise agreement. That is a per host, per classification calculation, and it sits on top of your award logic rather than replacing it.

The Fair Work Commission’s guidance sets the rules your rate engine has to encode:

• Only workers, host employees, unions or the host can apply. You, as the labour hire employer, can’t.
• No order can be made where the host is a small business employer, or where the work is wholly or mainly a service rather than the supply of labour.
• The protected rate doesn’t apply where a training arrangement applies, or during an exemption period. Engagements of 3 months or less are generally exempt, although the Commission can set a longer, shorter or recurring period, or none.
• You can ask the host in writing for what you need to calculate the rate, and the host must provide it.

A workable design has four parts. First, a host register that records whether an order covers the host, its effective date and its exemption period. Second, a rates table per host and classification, loaded from the host’s written answer and versioned when the agreement changes. Third, a tenure counter per worker per host, so the system switches to the protected rate on the right day. Fourth, a reconciliation report showing, for each pay run, which workers were on protected rates and why. This is classic workflow automation work, and it is where errors become underpayment claims.

Why do host site timesheets cause most disputes?

Because the person who approves the hours works for someone else. Paper timesheets signed at the gate, photos sent by text and spreadsheets from the host’s supervisor are the usual reality. Each one invites a dispute about breaks, overtime or who was actually on site.

A host site timesheet app fixes the evidence rather than the people:

1. The worker clocks on and off on a phone, with location captured only at those moments and the worker told it is captured.
2. Breaks and allowances are recorded against the shift, not reconstructed later.
3. The host supervisor approves on their own login, so approval is attributable.
4. Disputed shifts go to an exceptions queue with both sides’ notes, not an email chain.
5. Approved hours flow to payroll through an integration with tools such as Astute Payroll, which lets you configure award and enterprise agreement rules, or to Employment Hero, ELMO or your own payroll.

Rostering tools such as Deputy handle the scheduling side well. The gap is usually the host approval step and the flow from approval to the right rate.

What evidence will a regulator ask for?

Expect to show how compliance happens day to day, not that you have policies. Victoria’s LHA says it may request a business compliance plan specific to your industry, workforce and business model, and that generic, templated or marketing style plans may not be accepted. Its 2026 changes let it weigh compliance with a wider range of laws, including bankruptcy, consumer protection, fair trading and corporate regulation.

An evidence pack your system should be able to produce on request:

• Every licence held, its conditions, renewal date and the nominated officers behind it.
• Financial viability evidence for the current licence period.
• Each host, the work supplied, and whether a protected rate order applies.
• Subcontractors and payroll services used, which Victoria’s standard conditions in high risk industries require you to report.
• Pay records showing award or protected rates applied and super paid.
• WHS inductions per host site and notifiable incidents.
• Accommodation provided to workers and its cost, where relevant.
• For Queensland, the numbers each six monthly report asks for: workers registered, workers supplied and workers’ compensation claims.

Victoria’s standard licence conditions in horticulture, meat and poultry processing, commercial cleaning and security also restrict cash payments and the use of independent contractors and subcontractors, so your payment and engagement data should make breaches visible before the regulator finds them.

What should a host portal do?

Let hosts order workers, see that each one is licensed, inducted and qualified, and approve hours, all without email. For hosts, the portal is proof they are using a licensed provider. For you, it is fewer phone calls and a record of every order.

Core features: job orders with start dates, site and role; a credential view per worker showing tickets, licences, visa work rights and site inductions with expiry dates; WHS induction completion; timesheet approval; and invoices that tie back to approved hours. If you supply construction, our construction software page covers the site side.

What changes with PALM scheme and visa workers?

More obligations, and more records that have to agree with each other. The PALM scheme lets approved employers hire workers from 9 Pacific islands and Timor-Leste when there are not enough local workers. Approval is assessed against the Approved Employer Deed and Guidelines, and labour hire providers must supply 5 years of accountant prepared financial statements and their labour hire licences where applicable. Read the deed before designing any software; its accommodation, pay, deduction and welfare rules drive the data model. For any visa holder, record work rights checks and visa expiry the same way the recruitment agency page describes.

What does labour hire software cost?

Indicative Australian market ranges, AUD ex GST, for modules around your existing payroll.

Module	Indicative range
Host portal with site timesheet app and approvals	$50k to $150k
Same Job Same Pay rate engine over payroll	$40k to $120k
Licence and evidence register with reporting packs	$25k to $70k
Payroll and accounting integrations, per system	$15k to $40k

Ranges assume Australian agency rates and include design, build, testing and launch. Our workflow automation cost guide explains the drivers. They are ranges, not quotes.

How AWLabs approaches labour hire software

AWLabs hasn’t yet delivered a project for a labour hire provider, and we aren’t workplace lawyers. We build the systems; your employment lawyer and payroll adviser sign off the rate rules and licensing interpretation before they are coded. After a Development Consult, our paid Discovery Audit maps your hosts, payroll and evidence trail, with the fee credited in full against the build. You then get a fixed price Schedule of Work with three options: The Minimum, The Recommended and The Complete. Senior engineers lead every build, you get updates every Tuesday and Friday, Sydney time, and the code and IP are assigned to you as they are paid for. See our build vs buy guide if you are still weighing an off the shelf platform.