What WHS Documents Does a Labour Hire Business Need?

Quick answer: A labour hire business in Australia generally needs a WHS policy, worker competency and licence register, host employer WHS assessment records, general and site-specific worker induction records, shared duty and consultation records, incident register, return-to-work program, evidence of required insurances, and labour hire licensing documentation for the relevant states. Because both the labour hire provider and the host employer owe a duty of care to placed workers, documentary evidence of consultation and coordination between the two PCBUs is particularly important.

Last reviewed: 12 June 2026

Labour hire businesses operate in a uniquely complex WHS environment. Unlike most employers, a labour hire provider supplies workers to perform work under the direction of another business — the host employer. This arrangement creates a shared duty situation where two separate persons conducting a business or undertaking (PCBUs) each owe obligations to the same workers. Getting WHS documentation right is not just about ticking boxes; it is about demonstrating that you have actively managed the risks that come with placing workers in workplaces you do not directly control.

This guide sets out the core WHS documents that labour hire businesses commonly need, explains the shared duty framework, and highlights specific records that support compliance with both WHS legislation and labour hire licensing requirements.

Note: WHS legislation in Australia is based on the model Work Health and Safety Act 2011 developed by Safe Work Australia, but each state and territory has its own laws and regulators. Labour hire licensing schemes also vary by jurisdiction. Always check the requirements that apply to your business in each state or territory where you operate.

At a glance

Core WHS documents required

The following table summarises the documents most commonly required or expected for a labour hire business operating in Australia.

The shared duty framework and why documentation matters

The most distinctive feature of WHS in labour hire is the shared duty arrangement between the labour hire provider and the host employer. Under the model WHS Act, both are PCBUs and both owe a duty to ensure, so far as is reasonably practicable, the health and safety of placed workers. This duty cannot be passed entirely to the other party by contract.

In practice, this means:

• The labour hire provider must satisfy itself that the host workplace is reasonably safe, provide workers with relevant WHS information, and remain engaged with the worker's safety throughout the placement.
• The host employer must manage the day-to-day risks associated with the work, provide site-specific inductions, apply hazard controls, and treat placed workers with the same duty of care as direct employees.

Documentation is the evidence trail that shows both parties are meeting their obligations. For the labour hire provider specifically, records of host employer assessments, consultation arrangements, and ongoing communication with hosts and workers are critical to demonstrating due diligence. For more detail on how duty holders interact, see our guide on WHS duty holders explained.

Host employer WHS assessment records

Before placing a worker at a host employer's site, a labour hire provider should conduct and document an assessment of the host's workplace and WHS management arrangements. The assessment typically examines:

• The physical work environment and identified hazards at the placement site
• The host employer's WHS policies, procedures, and management systems
• Emergency procedures and first aid arrangements
• The nature of the work the placed worker will perform and associated risks
• Whether the host has adequate supervision and induction processes in place
• The host's workers compensation and insurance arrangements

Assessment records should be retained and updated whenever a new placement is made at the same site or when there is a significant change to the work environment or work activities. A well-documented host assessment process is one of the clearest ways a labour hire provider can demonstrate it has exercised its duty of care before a placement commences.

Worker induction records

Induction documentation in a labour hire context generally has two distinct components.

General induction by the labour hire provider

Before a worker commences any placement, the labour hire provider should deliver a general induction that covers:

• The provider's WHS policy and expectations
• The worker's right to cease unsafe work and how to raise WHS concerns
• How to report incidents and injuries to the provider
• The worker's obligation to cooperate with the host employer's WHS arrangements
• The provider's return-to-work and injury management processes
• How to contact the provider's safety or HR team during a placement

A signed general induction record should be held on file for each worker before their first placement commences.

Site-specific induction by the host employer

When a placed worker arrives at a host employer's site, the host is responsible for delivering a site-specific induction covering the particular hazards, emergency procedures, and rules at that workplace. The labour hire provider should obtain and retain a copy of — or a reference to — each worker's site induction record. This helps the provider maintain a complete picture of the worker's induction history across multiple placements.

Worker competency and licence register

Labour hire businesses are commonly asked by host employers to supply workers with specific skills, qualifications, or licences. Maintaining a current competency and licence register for all placed workers is essential for:

• Verifying that workers hold the licences required for the work they will perform (e.g. high risk work licences, driver licences, working with vulnerable people checks)
• Providing evidence to host employers that workers are suitably qualified
• Tracking expiry dates and ensuring licences are renewed before workers are placed in roles requiring them
• Supporting the host employer's contractor and worker management obligations

The register should include each worker's name, qualifications and licences held, the date each was obtained, the expiry date, and the licence or certification number where applicable.

Shared duty and consultation records

Because both the labour hire provider and the host employer share WHS duties for placed workers, documented consultation and coordination between the two parties is a key compliance requirement. For guidance on WHS consultation obligations generally, see our guide on WHS consultation requirements.

Shared duty and consultation records for a labour hire business typically include:

• Placement or host employer agreements that clearly set out the WHS responsibilities of each party — including who is responsible for specific induction steps, hazard controls, incident reporting, and return-to-work management
• Pre-placement consultation records documenting discussions about the specific work, hazards, and risk controls before a worker is placed
• Ongoing communication records covering WHS matters raised during a placement — such as hazard reports, near misses, or changes to the work environment
• Review or reassessment records following an incident, a change in work scope, or a formal review of the host's WHS performance

These records collectively demonstrate that the labour hire provider did not simply place a worker and walk away, but maintained an active and consultative approach to that worker's safety throughout the engagement.

Incident register and injury management records

Placed workers are employees of the labour hire provider, which means the provider is generally responsible for workers compensation, incident reporting, and injury management — even though the incident may have occurred at the host employer's premises.

Key records to maintain include:

• Incident register: All incidents, near misses, dangerous occurrences, and work-related injuries or illnesses involving placed workers should be recorded, regardless of where the incident occurred. Serious incidents must be notified to the relevant WHS regulator.
• Incident investigation records: A documented investigation for each significant incident — identifying the root cause, contributing factors, and corrective actions — demonstrates that the provider is actively learning from incidents and managing risks.
• Workers compensation records: Claims, medical certificates, rehabilitation plans, and return-to-work documentation for injured placed workers.
• Return-to-work program: Employers in most Australian states are required to have a return-to-work program. For a labour hire provider, managing the return to work of an injured placed worker may require coordination with both the workers compensation insurer and the host employer.

Insurance documentation

Labour hire businesses are routinely required to provide evidence of current insurance coverage to host employers and clients. At minimum, a labour hire provider should hold and be able to produce:

• Workers compensation insurance — required by law for all employers with workers in each state or territory where workers are engaged
• Public liability insurance — covering third-party injury or property damage arising from the business's activities
• Professional indemnity insurance — often required by host employers and covering claims arising from the provider's advice, services, or failure to supply suitably qualified workers

Insurance certificates should be kept current and readily accessible, with a process in place to track renewal dates.

Labour hire licensing documentation

Labour hire licensing schemes operate in Queensland, South Australia, Victoria, and the Australian Capital Territory. If your business supplies workers in any of these jurisdictions, you must hold a valid labour hire licence issued by the relevant regulator.

Licensing documentation a labour hire business should maintain includes:

• A copy of the current labour hire licence for each licensed jurisdiction
• Evidence of ongoing compliance with licence conditions — which may include financial record-keeping, annual reporting, and maintenance of fit-and-proper-person requirements
• Records confirming that all host employers in licensed jurisdictions have been advised of the provider's licence details
• Renewal reminders and any correspondence with regulators regarding licence status

Failure to hold a required licence is a serious offence in each licensing jurisdiction, with significant financial penalties for both the provider and any host employer that knowingly engages an unlicensed provider. Always confirm the current licensing requirements with the relevant regulator before commencing operations in a new state or territory.

Example scenario

Consider a labour hire business operating across New South Wales and Queensland, supplying warehouse and logistics workers to a range of host employers. The business employs 60 placed workers at any given time and maintains a small back-office team.

Before placing a new cohort of workers with a Queensland-based distribution centre, the business would typically hold:

• A current Queensland labour hire licence, with the licence number provided to the host employer before commencement
• A completed host employer WHS assessment for the distribution centre, covering warehouse hazards, manual handling risks, forklift traffic management, and the host's emergency procedures
• A placement agreement with the host employer setting out each party's WHS responsibilities, induction obligations, and incident reporting expectations
• General induction records signed by each worker before their first shift, confirming they have been briefed on the provider's WHS policies, incident reporting procedures, and consultation arrangements
• Site-specific induction records provided by the host and retained by the provider for each placed worker
• A competency and licence register confirming which workers hold a valid forklift licence, and tracking expiry dates
• An incident register updated in real time, with a documented incident investigation process for any injury or near miss
• A return-to-work program that includes procedures for coordinating with the host employer and the workers compensation insurer when a placed worker is injured
• Current workers compensation, public liability, and professional indemnity insurance certificates, provided to the host employer as part of the pre-placement documentation package

Frequently asked questions

Does a labour hire business share WHS responsibility with the host employer?

Yes. Under the model WHS Act, both the labour hire provider and the host employer are persons conducting a business or undertaking (PCBUs) and each owes a duty of care to the placed worker. The duties overlap and neither party can contract out of their obligations. This shared duty arrangement means both parties must consult, cooperate, and coordinate with each other to manage risks to placed workers. Documentary evidence of that consultation and coordination — such as host employer assessment records and shared duty agreements — is an important part of demonstrating compliance.

What is a host employer WHS assessment and when is it required?

A host employer WHS assessment (sometimes called a host assessment or site assessment) is a structured review of the host employer's workplace, work processes, and WHS management arrangements before a worker is placed. It helps the labour hire provider satisfy itself that the host workplace is reasonably safe and that the host has adequate WHS systems in place. While no single law prescribes an exact format, conducting and documenting host assessments is a widely recognised practice for labour hire providers and is considered part of meeting the duty of care owed to placed workers.

Do labour hire workers need a separate induction from the labour hire provider and the host employer?

Generally, yes. A labour hire provider typically delivers a general induction covering the provider's WHS policies, reporting obligations, workers' rights, how to raise safety concerns, and how to contact the provider. The host employer then provides a site-specific or workplace induction covering the specific hazards, emergency procedures, and rules at the placement site. Both induction steps should be documented. Some providers combine elements of both, but the worker should receive — and sign off on — information relevant to both the provider's obligations and the host's workplace before commencing work.

Which Australian states require labour hire businesses to hold a licence?

As at mid-2026, Queensland, South Australia, Victoria, and the Australian Capital Territory operate labour hire licensing schemes. Under these schemes, a labour hire provider must hold a licence to lawfully supply workers, and host employers in those jurisdictions must only engage licensed providers. The schemes are administered by state and territory regulators, and licensing requirements — including fit-and-proper-person tests, financial checks, and ongoing obligations — vary between jurisdictions. Always check the current requirements with the relevant regulator in each state or territory where you operate.

Get your WHS documents in order

Blue Safe Online provides ready-to-use WHS document systems for Australian businesses, including labour hire providers. Whether you are setting up a WHS system from scratch, preparing documentation ahead of a labour hire licence application, or updating your host assessment and induction records, the Blue Safe Online platform gives you access to professionally prepared WHS policies, registers, procedures, and more — designed for the Australian regulatory environment.

Browse WHS documents on Blue Safe Online

This guide provides general information only and does not replace legal advice or consultation with the relevant WHS regulator or labour hire licensing authority. WHS document requirements may vary by state or territory, the nature of your placements, and the industries in which you operate.