Your insurer wants an accountant to sign your labour hire wages

Most accountants have never seen this form. That is the delay.

What the form actually is

QBE calls it QM10139, Labour Hire Accountant's Declaration. It is a single page. It carries the insured's name, the policy number, the state of risk and the period of insurance, then two figures: total estimated wages for the period, and total actual wages for the period.

Underneath those, one sentence for an accountant to sign. It says the wages reported in the attached Labour Hire Wages Declaration are an accurate representation of wages paid to labour hire workers employed by the insured during the period of insurance.

It travels with a second form, QM10138, the Labour Hire Wage Declaration, which carries the wages and the premium rating classification, or PRC, the code that sets your rate.

What your insurer calls it

Every insurer names this differently, and some do not have a separate form at all. Nobody publishes a list, so here is one. All of these are as published at September 2026.

Start here, because two different documents get confused. Every WA employer, labour hire or not, lodges a general declaration of remuneration each year. Since 1 July 2024 those are approved forms under the Workers Compensation and Injury Management Act 2023: IN1, Declaration of Estimated Remuneration, and IN2, Declaration of Actual Remuneration. Allianz, GIO, Zurich, CGU and Guild all publish the identical document, because an insurer cannot alter an approved form. Neither IN1 nor IN2 has anywhere for an accountant to sign.

Labour hire is where the extra paperwork appears.

Labour hire specific forms

So who actually needs an accountant. Outside labour hire, one or two insurers let an accountant, auditor or tax agent certify a wage declaration instead of the employer signing it, but it is an option and almost nobody takes it, because the employer can simply sign. On labour hire with QBE it is not an option, and that is why labour hire operators are the ones who get stuck.

It is an underwriting requirement rather than a scheme rule. WorkCover WA's own Guidelines for Labour Hire Employers do not mention accountant certification anywhere. That is why it differs from insurer to insurer, and why your accountant has probably never seen one.

Whichever form landed in your inbox, the questions below are the same.

Who is allowed to sign it

The form asks for a registered accountant, and for a qualification and an organisation.

Worth knowing: "registered accountant" is not a protected term in Australia. There is no register of them. Neither the insurer nor WorkCover WA defines the phrase.

That has a consequence most people miss. Because the title carries no weight of its own, the entire weight sits on the sentence that gets signed. What matters is that whoever signs it has actually checked something, and can say what.

If your company has not started trading, that sentence is not true yet

Read it again. Wages paid. During the period of insurance. Past tense, about money that has already gone out the door.

A company applying for its first policy has paid nothing and the period has not started. There is no honest way to sign that sentence about an estimate, and an accountant who signs it anyway has certified something that did not happen.

The form itself contemplates this. It has a field for estimated wages as well as actual wages. The declaration sentence just was not written for the inception case.

The answer is a scoped declaration. Rather than signing the printed sentence, we sign a statement of what was actually done and what it rests on: that the company has paid no wages and no period has elapsed, that the figure is an estimate for the forthcoming period, what information it was built from, which remuneration rules were applied, how the classification was determined, and that no payroll records were verified because none exist.

That is a stronger document than the printed sentence, not a weaker one, because everything in it is true and checkable. Your insurer may accept it, query it, or ask for something else. If they ask for words we cannot sign, we will tell you why, and we will not sign them.

If you have been trading, the sentence works but the harder question does not go away

For a business past its first year the wages exist, the records exist, and the declaration sentence means what it says. Signing it then is a real piece of verification work rather than a wording problem.

It is also where the money is, because by now a full year of placements has happened. The declaration has to reconcile to the payroll, the payroll has to carry everything the Remuneration Guidelines count as remuneration, and every dollar has to sit against the right host's classification for the part of the year that worker was there.

Three things go wrong most often. The total is short, usually because allowances, the grossed up value of benefits or salary sacrificed superannuation were left out. Contractors were paid who meet the definition of a worker. Or the total is right and the split is wrong, which changes nothing about your wages bill and a great deal about your premium.

This happens every year

The declaration is annual. So is the classification question, and it moves, because your hosts change. A firm that was placing into one industry at inception and three by the end of the year has a different answer at renewal than it had at inception, and nothing in the ordinary annual process will tell it so.

Getting it right once and then keeping the records that prove it is cheaper every year after the first.

The part that costs real money: the classification is not yours

This is where most labour hire declarations go wrong, and almost nobody knows the rule exists.

Under the WorkCover WA Industry Classification Order, unless your placements are predominantly clerical, the wages of the workers you place are declared at each host employer's classification. Not at your workers' job titles, and not at the labour hire rate.

An accountant placed with a mine is declared at the mine's rate. A general hand placed with a transport company is declared at the transport rate. The logic is that lending workers out should not make the risk cheaper than doing the work directly.

The spread is wide. On the 2026/27 recommended rates, clerical labour supply is 1.77% of declared remuneration. Shearing services is 6.56%. Carpentry is 5.62%. Road freight is 5.40%. In the other direction, iron ore mining is 1.08%, mineral exploration 0.65%, and accounting services 0.25%.

So the error runs both ways. Some hosts sit well above the labour hire rate and some well below it, and a firm declaring everything at one code is wrong in one direction or the other. You want to know which.

And the host is not always what it looks like. The classification follows the host's own predominant business activity, not the industry its projects serve. A fabrication and construction contractor doing work for resources clients is not a mining company, and the difference between those two answers can be more than two percentage points of your whole payroll.

Getting that determination right is the job. The form is the easy part.

What we check before signing

• The remuneration base. Allowances, overtime, the grossed up taxable value of fringe benefits and salary sacrificed superannuation are in. Superannuation paid by force of law is out. Estimates built from base hourly rates alone come out short, and fly in fly out rosters are allowance heavy. What counts as remuneration
• The classification of each host, from the host's own workers compensation classification where it can be obtained, otherwise from the host's published activity, with the basis stated in writing.
• Which host entity is actually the contracting party, because the declaration names the host.
• Whether directors work in the business, how each is paid, and whether cover has been elected. In Western Australia cover for a working director exists only where the director is named on the policy and the remuneration is declared at the time. It cannot be created afterwards.
• Whether anyone is engaged as a contractor, and if so on what basis.
• That the estimate is a genuine best estimate rather than a floor. The difference between the estimate and the actual figure is adjusted at the end of the period and the adjustment lands on you. An estimate set low does not save money, it defers it.

You also get the placement register set up to the schema WorkCover WA publishes at Appendix 1 of its Guidelines for Labour Hire Employers, and a short procedure for keeping it current. The Act requires labour hire employers to keep records of workers engaged, industry classification and remuneration for not less than seven years. That register is the first thing asked for if your declarations are ever reviewed, and most labour hire businesses do not keep one.

What we need from you

The hourly rate for each role. The roster, days on and days off and hours per day. Every allowance, and whether each is paid per day or per swing. Whether superannuation sits on top of the rates or inside them. The intended start date and the policy period. The host's own classification. Which host entity you are contracting with. Where your people will physically be.

If you do not have the host's classification, ask them. They will know it, it costs a phone call, and it is the strongest single piece of evidence available.

Time and cost

Two business days from a complete set of that information, subject to the host's classification being available.

Fees are fixed, agreed in writing before any work starts, and never a percentage of anything. Tell us the situation and you will have a number before you commit to anything.

Who does this

Ashley Boardman, Accountant, B.Com, principal of United Financial Group Pty Ltd in West Perth. Thirty years across accounting, payroll, investigations and software, beginning in 1996 with payroll for 120 construction personnel at Collie Power Station, and including twelve years as a licensed investigator conducting factual investigations for insurers and law firms.

No part of the work is subcontracted.