GLAA, the Fair Work Agency and UKVI Sponsor Licences

Many UK employers are becoming increasingly familiar with Skilled Worker sponsorship, sponsor duties and UKVI compliance. But there is another layer of compliance that can easily be overlooked, particularly in agriculture, horticulture, food production, food packing and shellfish-related work, and this is gangmaster licensing.

This is often still referred to as GLAA licensing, although from April 2026 the relevant licensing function sits with the Fair Work Agency (FWA). The underlying point remains the same: if your business is in, or supplies labour into, a regulated sector, you need to understand whether a gangmaster’s licence is required.

That matters even more if you hold a UKVI sponsor licence. A breach of gangmaster licensing legislation is not just a regulatory issue. It can be a criminal offence, and it may also place your sponsor licence at risk because sponsors must comply with wider UK law. 

Who is responsible for gangmaster licensing?

The Gangmasters and Labour Abuse Authority, commonly known as the GLAA, was the body associated with licensing labour providers in certain high-risk labour sectors.

From 7 April 2026, the relevant functions now sit within the Fair Work Agency (FWA), an executive agency sponsored by the Department for Business and Trade. The FWA is responsible for enforcing workers’ rights, including the applications and management of gangmaster licences and investigating whether a labour provider is licensed.

Which sectors are governed by gangmaster licensing?

The licensing scheme is focused on work in:

• agriculture;
• horticulture;
• shellfish gathering;
• processing and packaging of products derived from agriculture, fish or shellfish.

The Fair Work Agency protects workers from exploitation by operating a licensing scheme in agriculture, horticulture, shellfish gathering and associated processing and packaging sectors. If an individual or an organisation supplies labour or uses workers to provide services in these sectors, they may need a gangmaster’s licence.

Examples of businesses that may be affected include farms, growers, food manufacturers, fresh produce businesses, meat processing businesses, fish and shellfish processors, poultry businesses, flower packing businesses, and businesses involved in associated processing or packaging.

What about construction, care, hand car washes and other sectors?

The GLAA historically held a wider labour exploitation role and has been associated with monitoring and investigating exploitation risks in sectors such as construction, care, hand car washes, recycling, garment manufacturing, warehousing, hospitality, nail bars and taxi driving. However, those sectors are not generally within the gangmaster licensing scheme.

It is likely that the FWA will expand its investigations into these wider sectors, notably they have been urged to act on reports identifying construction as a sector plagued by “systemic” labour exploitation, particularly regarding subcontractors and agency worker chains.

Under its new guise, the FWA has also stated it will prioritise industries with high numbers of low-paid, precarious, and zero-hours workers, which includes the care sector. The agency has the power to carry out both planned and unannounced inspections of labour users, including in-person or virtual visits to sites.

Furthermore, under the Employment Rights Act 2025, the FWA also has broadened powers to inspect workplaces, demand documentation, and interview workers to ensure compliance, particularly regarding payroll, holiday pay, and statutory sick pay.

Who needs to be licensed?

A licence may be required where a person or business is acting as a gangmaster in a regulated sector. The official guidance explains that acting as a gangmaster includes supplying labour to agriculture, horticulture, shellfish gathering, and food processing and packaging; using labour to provide a service in the regulated sector and using labour to gather shellfish.

The concept of “supply” is deliberately wide. It can include supplying temporary workers, introducing workers for direct employment, sourcing candidates, forwarding CVs or application forms, and screening candidates for work in licensed sectors. The Home Office makes clear that it does not matter whether the arrangement is formal or informal, or whether the end client makes the final decision to employ the worker.

This is where some employers fall foul of the rules. They may think “it’s only the introduction of candidates” or “they’re only helping with recruitment”. In a regulated sector, that may still be enough to bring the activity within the licensing regime.

Do you need a licence if you directly employ staff?

Usually, you do not need a gangmaster’s licence simply because you directly employ staff to work exclusively for your own business. For example, a farm advertising for workers, recruiting them directly and employing them to work only on that farm would not normally be “supplying” workers to another labour user.

However, the position can change if the farm were to:

• supply those workers to another business;
• introduce workers to another business;
• use their workers to provide a service to another person in a regulated sector.

The official guidance states that a business needs a licence if it supplies a worker to a labour user for work covered by licensing, or if it uses a worker to provide a service to another person to do work covered by licensing.

So, the key question is not only “do we employ the worker?” It is also “what are we doing with that worker, and for whom?”

What are the two main breaches employers need to understand?

There are two common risk areas.

• Supplying labour without holding the required licence. It is illegal to act as a gangmaster without a licence. The maximum penalty for operating without a licence is 10 years in prison and a fine.
• Using an unlicensed gangmaster. It is also illegal to use an unlicensed gangmaster. The maximum penalty for this offence is 6 months in prison and a fine.

There is also a specific offence relating to false documents. A person commits an offence if, in an attempt to make another person believe they are licensed, they possess or control a false, improperly obtained or third-party document connected with licensing.

In practical terms, the compliance message is simple: do not supply workers into a regulated sector without checking whether a licence is required, and do not use a labour provider unless you have checked that they are properly licensed.

You can check whether a labour provider is licensed using the official public register of licensed labour providers.

Why does this matter for UKVI sponsor licence compliance?

Sponsor licence holders must comply with their sponsor duties. One of those duties is to comply with wider UK law, not just immigration law.

The Home Office sponsor guidance states that sponsors have a duty to comply with wider UK law, including employment law, legally required licences, registrations or approvals needed to run the business lawfully, licensing by statutory bodies where required, and not engaging in criminal activity.

This means a breach of gangmaster licensing legislation or involvement in labour exploitation can create two problems at once:

• A potential criminal or regulatory issue under the gangmaster licensing regime; and
• A sponsor compliance issue because the organisation may no longer be complying with wider UK law.

For regulated businesses that sponsor Skilled Workers, Seasonal Workers or other sponsored workers, this is particularly important. UKVI is likely to look closely at whether the sponsor is operating lawfully, whether workers are being recruited and managed appropriately, and whether the sponsor’s wider compliance arrangements are robust.

If I sponsor Skilled Workers, do they still need to be placed by a licensed provider?

Sponsorship does not remove the need to comply with gangmaster licensing rules.

If a third party is supplying, introducing, sourcing, screening or otherwise arranging workers for roles in a regulated sector, that third party may need a gangmaster’s licence, regardless of whether the workers are sponsored.

Equally, if your business is both a sponsor and a labour provider, you may need to consider both regimes together: sponsor duties on one side, and gangmaster licensing obligations on the other.

Do UKVI and the Fair Work Agency talk to each other?

Employers should not assume that immigration compliance and labour market enforcement operate in separate silos.

The Fair Work Agency licensing standards refer to the Gangmasters Licensing Act offences being enforced by the FWA on behalf of the Home Office. The licensing standards also state that the FWA may consider whether relevant individuals have contravened requirements or standards of other regulatory authorities, including UKVI.

That does not mean every issue will automatically be referred to UKVI, or that every UKVI compliance issue will automatically trigger FWA action. But it does mean businesses should treat labour licensing and sponsor licence compliance as connected risk areas.

How can employers prevent a breach?

A practical compliance plan should include:

• mapping which parts of the business involve agriculture, horticulture, shellfish gathering, or associated food/fish/shellfish processing and packaging;
• identifying whether workers are directly employed, supplied by an agency, introduced by a recruiter, provided by an intermediary or used to deliver services to another business;
• checking the public register before using any labour provider in a regulated sector;
• keeping evidence of licence checks, including screenshots or dated records;
• reviewing contracts with agencies, recruiters, umbrella companies and subcontractors;
• training HR, operations, procurement and site managers to spot when GLAA/FWA licensing may be relevant;
• adding gangmaster licensing checks to sponsor licence compliance audits;
• taking advice before moving sponsored workers between sites, clients, group companies or third-party arrangements.

Official government guidance does illustrate that exclusions exist, but employers should check carefully whether an exclusion applies before relying on it.

Key takeaway for sponsor licence holders

If your business operates in agriculture, horticulture, shellfish gathering, or associated processing and packaging, gangmaster licensing should be part of your sponsor licence compliance framework.

A breach is not a minor technical issue. It can involve criminal offences, fines, imprisonment, licence revocation risk and UKVI sponsor compliance consequences.

For employers using sponsored workers, the safest approach is to ask three questions:

1. Are any roles or sites within a regulated sector?
2. Are any workers supplied, introduced, screened, sourced or managed by a third party?
3. Have we checked and documented whether a gangmaster’s licence is required?

If the answer to any of those questions is unclear, it is worth getting advice before the issue becomes a UKVI or FWA compliance problem.

Useful links:

• Public register of licensed labour providers