The records behind a labour hire declaration

That record is the whole basis of your declaration. Without it the split cannot be worked out by you, by your insurer, or by anyone reviewing it later.

What is actually required, and what is only recommended

These are two different things and they get confused constantly.

The records are required. Under the Act, employers must maintain records relating to the number of workers employed, the appropriate industry classification, and total remuneration paid or payable for each period of insurance. Those records must be retained for not less than seven years.

The log is a template. WorkCover WA publishes a Labour Hire Worker Placement Log at Appendix 1 of its Guidelines for Labour Hire Employers, and says maintaining such a record may assist with tracking placements and remuneration. It is the regulator's own recommended shape for evidencing the records. It is not itself mandatory.

So nobody can tell you that you must keep the log. What they can tell you is that you must keep the underlying records for seven years, and that this is the format the regulator drafted for doing it.

What goes in it

Appendix 1 has eight columns, and it runs for a policy period.

Look at what those columns are for. Dates and dollars against a host PRC is exactly the arithmetic a declaration needs, and the estimated and actual columns sitting side by side are the same pair your policy runs on, an estimate at inception and an actual at the end.

The template is a form of the answer, not just a filing habit.

The regulator acknowledges this is hard

Worth knowing, because it is unusually candid and because it is the sentence to reach for if anyone suggests this should have been easy.

The Guidelines accept that in the labour hire industry the supply of workers may be short term, unknown in advance for some workers, or not align with the period of insurance cover. That is the regulator conceding that the information needed to classify correctly does not exist when the policy is written.

They then say effective records are particularly important for labour hire companies supplying large numbers of workers to hosts in diverse industries. Which is to say: the harder your book is to classify, the more the record matters.

The three rules the record has to support

From the Guidelines' own key points on remuneration declarations.

Apportion to the host's PRC. When declaring the remuneration of labour hire workers, apportion it based on the relevant classification of the host employer.

A worker across two hosts splits by dates. Where a worker is placed with two or more hosts in different industries over a policy period, identify each host and each PRC, and apportion that worker's remuneration relative to the period of each placement and the period of insurance cover.

Plans change, and the next declaration catches it. If a worker does not take up a placement, or ends up with a different host and a different classification than was declared, the next declaration is updated to account for the change.

None of those can be done from a payroll report. Payroll knows what you paid. Only the placement record knows where it was earned. How labour hire classification works

You probably already hold most of it

This is the part that makes the job smaller than it looks.

Labour hire businesses invoice hosts from placement data, so the raw material usually exists somewhere: a scheduling or workforce system, the invoicing run, timesheets, or a spreadsheet somebody keeps. Firms running a workforce platform have it in structured form already. Firms running on spreadsheets and email usually have it too, scattered.

What is normally missing is not the data. It is the host classification against each placement, and a single place where the whole period assembles.

What we do

Build the log from what you already have. Your scheduling exports, host invoices and payroll, assembled into the Appendix 1 schema for the periods you need.

Determine each host's classification, from the host's own workers compensation classification where it can be obtained and otherwise from what that host actually does, with the basis written down. Each host determined once stays determined, which is why the second year costs less than the first.

Hand you the process for keeping it current, sized to how you actually work, so it is maintained as placements happen rather than reconstructed at renewal.

Produce the declaration from it, with the apportionment shown, so the figure you lodge has its working attached. The labour hire wage declaration

Why it is worth doing before anyone asks

A placement record is the first thing requested if your declarations are ever looked at, and it is the only thing that can settle the question in either direction.

That cuts both ways, which is the point. Without records, a classification position you believe is correct cannot be demonstrated, and you carry the argument rather than the evidence. With them, the answer is arithmetic, whichever way it comes out.

It is also the cheapest moment to do it. Records recede at one period a year against a seven year retention obligation, and reconstructing a year from memory and invoices costs more than keeping it did.

Fees

Fixed, agreed in writing before any work starts, and never a percentage of anything. The build is priced on the number of periods and placements. Keeping it current afterwards is a smaller recurring piece, and it is the part that stops this becoming a project again next year.