Do I need a gangmaster's licence for this supply? Four questions for a recruitment agency

A client in food or farming wants a worker, or a client you already supply is moving a temp onto a packing line. Whether your agency needs a gangmaster's licence for that supply depends on the work, the worker's own job, the part you play and the licence you hold. This questionnaire asks up to four questions and gives one outcome with the rule behind it. It follows the Fair Work Agency's guidance on GOV.UK as we read it on 2 October 2026: the detailed guidance on who needs a licence, updated 15 June 2026, and the page on applying and renewing, updated 28 September 2026. Nothing you choose leaves the page.

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Gangmaster's licence: is one needed for this supply

Answer each question. Some questions appear only when an earlier answer makes them relevant. Nothing you choose leaves this page.

1. Which kind of work will the worker do for the client?ChooseFarm or horticulture work: livestock, growing, harvestingProcessing or packing food, drink, flowers or pet foodGathering shellfishNone of these
2. Is the worker's own job, or the place it is done, on the guidance's list of work not covered?ChooseNo: line, packing, harvest, livestock or shore workYes: the job itself is on the list of work not coveredYes: food work in a kitchen, shop or wholesale siteNot sure
3. What part does your agency play in getting the worker to the client?ChooseWe supply the worker as a temp on our own payrollWe introduce the worker for a permanent or fixed-term jobWe source or screen candidates and pass their details onWe supply the worker through an umbrella or payroll company
4. Does your business hold a gangmaster's licence that is in date today?ChooseYes, and the expiry date is in the futureWe held one and it has expiredNo, or an application is still being checked

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The outcome is the rule as our guides and the sources named set it out, applied to the answers you gave. It is not advice on your own case.

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The questions, and why each is asked

1. Which kind of work will the worker do for the client? The Fair Work Agency licenses the supply of workers to four regulated sectors: agriculture, horticulture, shellfish gathering, and food processing and packaging. Work outside them needs no gangmaster's licence.

2. Is the worker's own job, or the place it is done, on the guidance's list of work not covered? The detailed guidance lists jobs that are not licensed, such as lorry drivers, forklift-only drivers, site engineers, fencing and gardening. It also excludes processing or packing in a catering establishment, shop, wholesale market, wholesale establishment or distribution warehouse. This question appears only when an earlier answer makes it relevant.

3. What part does your agency play in getting the worker to the client? Supply has a wide meaning in the guidance. A temporary supply, a permanent introduction, forwarding CVs and screening candidates all count, and an umbrella or payroll company that employs the worker needs a licence of its own. This question appears only when an earlier answer makes it relevant.

4. Does your business hold a gangmaster's licence that is in date today? A licence lasts one year and the expiry date is printed on the certificate. A business whose licence has expired is removed from the public register and must stop trading in the regulated sectors. This question appears only when an earlier answer makes it relevant.

Every outcome, and the rule behind it

No gangmaster's licence: the work is outside the regulated sectors

Reached when: "Which kind of work will the worker do for the client?" answered "None of these".

A gangmaster's licence is needed only for supplying workers to agriculture, horticulture, shellfish gathering, and food processing and packaging, the sectors the Fair Work Agency licenses under the Gangmasters (Licensing) Act 2004. Office, driving and construction work are outside them. GOV.UK's guide for agencies names one other group: nursing and domiciliary care agencies, which may need to register with the care regulator for their nation. The Conduct Regulations 2003 still apply to every supply, and the Fair Work Agency enforces those as well.

• Note on the vacancy record why the work is outside the regulated sectors.
• Run the questions again if the client moves the worker onto a food line or a farm.

Source: GOV.UK, Fair Work Agency, What a gangmaster's licence is and who needs one (updated 17 June 2026), and Employment agencies and businesses: licences, read 2 October 2026. The working is in How to start a recruitment agency in the UK.

No licence for a job the guidance lists as not covered

Reached when: "Is the worker's own job, or the place it is done, on the guidance's list of work not covered?" answered "Yes: the job itself is on the list of work not covered".

The Fair Work Agency's detailed guidance, updated 15 June 2026, lists work linked to the regulated sectors that is not licensed. In food and drink it names site engineers, forklift truck drivers with no other role in processing and packaging, lorry drivers and workers solely loading lorries. In agriculture it names fencing, gardeners, groundspersons, hedging, ditching and drainage, and game keeping. For shellfish, diving with breathing apparatus and dredging from a fishing vessel at sea are excluded. The test is the worker's whole job: a forklift driver who also packs is covered.

• Write the worker's duties on the assignment details and ask the client to confirm them.
• Stop and check again if the client adds line, packing or harvest work to the job.

Source: GOV.UK, Fair Work Agency, Detailed guidance on who needs a gangmaster's licence, paragraphs 2.13, 2.29 and 4.20 (updated 15 June 2026), read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

No licence if the premises meet the guidance's definition

Reached when: "Is the worker's own job, or the place it is done, on the guidance's list of work not covered?" answered "Yes: food work in a kitchen, shop or wholesale site".

No licence is required to supply a worker to process or pack produce in a catering establishment, a shop or other retail establishment, a wholesale market, a wholesale establishment or a distribution warehouse, each as the guidance defines it. A catering establishment prepares food ready to eat for service to the consumer, such as a restaurant, canteen or school kitchen. A wholesale establishment is run solely to sell produce for resale or to caterers, and the definition leaves out premises run mainly for processing and packaging. Work on a production line in a food factory is licensed.

• Check the client's premises against the definitions in section 4 of the detailed guidance.
• Keep a note of which definition applies and who at the client confirmed the facts.
• If the fit is doubtful, ask the licensing team on 0345 161 6000 before the first shift.

Source: GOV.UK, Fair Work Agency, Detailed guidance on who needs a gangmaster's licence, paragraphs 4.15 and 4.29 to 4.36 (updated 15 June 2026), read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

Ask the Fair Work Agency before the first shift

Reached when: "Is the worker's own job, or the place it is done, on the guidance's list of work not covered?" answered "Not sure".

The detailed guidance says its list of covered work is not definitive and that other types of work may come under the licensing scheme, so a job that is hard to place should be put to the Fair Work Agency. Its licensing team answers on 0345 161 6000 and at licensing@fairworkagency.gov.uk, Monday to Friday, 9am to 5pm. The cost of guessing wrong is high: acting as a gangmaster without a licence carries a maximum penalty of 10 years in prison and a fine.

• Send the licensing team the job description and the client's site details, and keep the reply.
• Wait for the answer in writing before the worker, or the worker's CV, goes to the client.

Source: GOV.UK, Fair Work Agency, Detailed guidance on who needs a gangmaster's licence, paragraphs 2.1 and 7.2 (updated 15 June 2026), read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

Stop supplying: an expired licence cannot be renewed

Reached when: "Does your business hold a gangmaster's licence that is in date today?" answered "We held one and it has expired".

A gangmaster's licence lasts one year. The Fair Work Agency's guidance, updated 28 September 2026, says a business whose licence expires before it is renewed is removed from the public register and must stop trading in the regulated sectors until a new licence is granted. That means a new application at £3,490 where turnover in those sectors is under £1 million, against a renewal fee of £620, and application checks that usually take up to 10 weeks from payment of the fee.

• Stop supplying workers to the regulated sectors until the new licence is granted.
• Apply online and pay the fee now, because the 10 weeks run from payment.
• Diary the next expiry date and the day renewal opens, six weeks before it.

Source: GOV.UK, Fair Work Agency, How to apply for or renew a gangmaster's licence (updated 28 September 2026), read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

Licence needed before you supply, introduce or forward a CV

Reached when: "Does your business hold a gangmaster's licence that is in date today?" answered "No, or an application is still being checked".

This work is licensed, and your part in it counts as supply. The guidance says a temporary supply, an introduction for a permanent or fixed-term job, forwarding CVs and screening candidates all need a licence, and so does supplying through an umbrella or payroll company. Acting as a gangmaster without one carries a maximum penalty of 10 years in prison and a fine. An application costs £3,490 where turnover in the regulated sectors is under £1 million, and checks usually take up to 10 weeks from payment.

• Send no worker, CV or shortlist to this client until the licence is granted.
• Apply online with a sample worker contract and a sample timesheet.
• Count 10 weeks back from the contract start to find the last day to apply and pay.

Source: GOV.UK, Fair Work Agency, Detailed guidance on who needs a gangmaster's licence, paragraphs 3.5, 5.5 and 7.2, and How to apply for or renew a gangmaster's licence (updated 28 September 2026), read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

You are licensed: check the umbrella or payroll company is too

Reached when: "What part does your agency play in getting the worker to the client?" answered "We supply the worker through an umbrella or payroll company".

The guidance says an umbrella or payroll company that employs or engages the worker directly needs its own gangmaster's licence, because it supplies the worker back to you for onward supply, and that you need one as well. A company that only administers payroll and has no contract with the worker does not. Using an unlicensed gangmaster is an offence under section 13 of the Gangmasters (Licensing) Act 2004, with a maximum penalty of 6 months in prison and a fine.

• Look the company up on the Fair Work Agency's public register before the first supply.
• Keep a dated copy of the register entry on the client file.
• Check the entry again each time your own licence comes up for renewal.

Source: GOV.UK, Fair Work Agency, Detailed guidance on who needs a gangmaster's licence, paragraphs 5.15, 5.16, 5.33 and 7.5 (updated 15 June 2026), read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

Your licence covers this supply: keep it in date and the names on it right

Reached when: any other set of answers.

With a licence in date you can make this supply. A licence lasts one year; renewal opens six weeks before the expiry date printed on the certificate, needs no inspection and takes around five working days. The renewal fee is £620 where turnover in the regulated sectors over the previous 12 months, including VAT charged to clients, was below £1 million. For licence holders with turnover under £5 million in those sectors, the individuals who negotiate with labour users and supply workers must be named on the licence.

• Diary the expiry date and the day renewal opens, six weeks before it.
• Check the consultant handling this client is named on the licence.
• Give the client your licence details so it can check the public register.

Source: GOV.UK, Fair Work Agency, How to apply for or renew a gangmaster's licence (updated 28 September 2026), and Detailed guidance on who needs a gangmaster's licence, paragraph 3.15, read 2 October 2026. The working is in How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers.

How to use the result

Use it when the vacancy comes in, before a CV or a worker goes anywhere. The guidance says it is not an authoritative statement of the law and that its lists are not definitive, so treat a no-licence outcome as a reason to write down why, and keep the note with the vacancy record. Clients have their own reason to ask for your licence: using an unlicensed gangmaster is an offence for them. Run the questions again when the worker's duties or the client's site change.

The outcome applies the rule to the answers given; it cannot see the facts behind them. Where an answer is a judgement, or the facts are unusual, the outcome may not fit. This page is general information, not legal advice.

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