Guides and reviews for people who run small UK firmsNewsletterHow we reviewAbout us
Advertisement

Home › Recruitment agencies › AWR, right to work and the Conduct Regulations

AWR, right to work and the Conduct Regulations

How much does a gangmaster's licence cost in 2026? The Fair Work Agency fees for agencies supplying food and farm workers

A gangmaster's licence costs £3,490 to apply for and £620 a year to renew at turnover under £1 million. The four fee bands, the VAT rule and a worked year.

A white industrial building with a canopy over its loading bay

A gangmaster's licence costs £3,490 to apply for and £620 a year to renew if your turnover in the licensed sectors is under £1 million. Those are the Fair Work Agency's fees for its lowest band, read on GOV.UK on 1 October 2026; the highest band pays £8,500 and £4,000. Any agency that supplies workers to farms, food factories or packhouses needs the licence, and a perm desk is not exempt.

The fees on 1 October 2026

Turnover in the regulated sectors Band Application and inspection Renewal, each year
£10 million or more A £8,500 £4,000
£5 million to less than £10 million B £6,820 £3,100
£1 million to less than £5 million C £5,190 £1,860
Less than £1 million D £3,490 £620

The first fee covers the application and the inspection. For a new applicant the band follows the turnover you expect in the regulated sectors over the year. At renewal it follows what you turned over there in the previous 12 months. On that wording the office and driving desks of a general agency do not count towards the band. The guidance says neither fee is refunded.

Turnover includes the VAT you charge

On 28 September 2026 the guidance was changed, in the words of its update note, "to make it clear that gross annual turnover includes VAT charged to clients". For an agency that adds 20% VAT to every invoice, that puts the £1 million line at £833,333 of billing before VAT.

An agency billing food clients £840,000 a year before VAT has a licensing turnover of £1,008,000 and sits in band C. Its renewal is £1,860, which is £1,240 more than band D. A first application is £5,190, which is £1,700 more. Our guide to VAT on recruitment fees explains why VAT falls on the whole of a temp's charge.

Who needs one

The regulated sectors are agriculture, horticulture, shellfish gathering, and food processing and packaging. The guidance's list for processing and packaging runs from bread, ready meals and sandwiches to pet food, alcohol and soft drinks. It covers production line work and packing by hand or by machine.

Three parts of the definition reach an agency that does not think of itself as a gangmaster:

  • Permanent placements count. The detailed guidance says an employment agency supplying a worker for permanent work with a labour user needs a licence, as an employment business supplying a temp does.
  • Forwarding CVs counts. Sourcing candidates and sending their details to another labour provider, or to the business that will use them, is listed as labour provision.
  • Payroll and umbrella companies count. One that employs the worker directly needs its own licence, and so does the agency that supplies through it.

Some supply is excluded. No licence is needed to supply a worker to process or pack produce in a catering establishment, a shop, a wholesale market or a wholesale establishment, each as the guidance defines it. A restaurant kitchen is a catering establishment. A factory making sandwiches is on the list of licensed work. If you are unsure, the Fair Work Agency's licensing team answers on 0345 161 6000. Our start-up checklist lists the other registrations an agency may need.

One year, worked

An agency supplies twelve packers to a bakery for 37.5 hours a week all year, at the £19.50 charge rate used in our temp margin calculator.

Line Working Result
Hours a year 12 × 37.5 × 52 23,400
Billing before VAT 23,400 × £19.50 £456,300
Turnover for the licence £456,300 × 1.2 £547,560
Band Less than £1 million D
Fee in year one Application and inspection £3,490
Fee in year two Renewal £620

Spread over the hours, the first year's fee is 14.9p an hour and each renewal is 2.6p. The calculator's margin at that rate is £2.13 an hour, or £49,842 over the year. The licence takes 7.0% of the first year's margin and 1.2% of each year after. Over two years the fees come to £4,110.

The dates that cost money

  1. Ten weeks to check an application. The guidance says applications are usually checked within 10 weeks of the fee being paid, and that some take longer. For a contract starting on Monday 4 January 2027, ten weeks back is Monday 26 October 2026.
  2. One year of licence. The expiry date is printed on the certificate. Renewal opens six weeks before it, needs no inspection and takes around five working days.
  3. No grace after expiry. A business whose licence lapses comes off the public register and must stop trading in the regulated sectors until a new licence is granted. At band D that means paying £3,490 where the renewal would have been £620, which is £2,870 more, and waiting for the checks again.

The price of going without

Acting as a gangmaster without a licence carries up to 10 years in prison and a fine. The client is exposed too. Using an unlicensed gangmaster carries up to six months in prison and a fine, so a food client has its own reason to ask for your licence before the first shift.

What the fee does not cover

The inspection tests the licensing standards, and meeting them is where the rest of the cost sits. To apply you need a sample worker contract, a sample timesheet and, if you already supply workers outside the regulated sectors, a payslip you have issued.

Among the standards marked critical are these:

  • PAYE and National Insurance worked out and paid correctly.
  • VAT registration once the business is over the threshold.
  • No fee charged to a worker for finding them work, which is the ban our guide to charging candidates covers.

The standards also say worker and client records must be kept for at least one year, which our guide to how long an agency keeps records sets beside the longer payroll periods.

We did not find a published figure for the cost of preparing for an inspection, so this page gives none. It is general information, not legal advice.

Short answers from this page

How much does a gangmaster's licence cost for a recruitment agency in 2026?

A gangmaster's licence from the Fair Work Agency costs £3,490 to apply for, inspection included, and £620 a year to renew where turnover in the regulated sectors is under £1 million. The highest band, £10 million or more, pays £8,500 and £4,000. Turnover includes the VAT charged to clients, and neither fee is refunded.

Source: GOV.UK, Fair Work Agency, How to apply for or renew a gangmaster's licence, updated 28 September 2026, read 1 October 2026

Does a recruitment agency need a gangmaster's licence to place permanent staff in a food factory?

Yes. Fair Work Agency guidance says an employment agency supplying a worker for permanent work in agriculture, horticulture, shellfish gathering or food processing and packaging needs a licence, as a temp supplier does. Forwarding CVs for that work counts too. Acting as a gangmaster without a licence carries up to 10 years in prison and a fine.

Source: GOV.UK, Fair Work Agency, Detailed guidance on who needs a gangmaster's licence, updated 15 June 2026, read 1 October 2026

Every short answer for recruitment agencies

Where this comes from: GOV.UK, Fair Work Agency, "How to apply for or renew a gangmaster's licence" (updated 28 September 2026) and its update history; "What a gangmaster's licence is and who needs one" (updated 17 June 2026); "Detailed guidance on who needs a gangmaster's licence" (updated 15 June 2026); "The Fair Work Agency licensing standards for gangmasters" (published 7 April 2026); each read in a browser render on 2026-10-01. Arithmetic is ours. Not legal advice.

AL

AEO Lookup editorial team

We write practical guides for people who run small UK firms, and we check every fact against its source on the date shown. Read how we review, or tell us if something has changed.

More for recruitment agencies