The treatment of migrant workers is once again under scrutiny, with recent investigations revealing systemic failures across Australia’s supply chains. These cases, many involving labour hire arrangements and the Pacific Australia Labour Mobility (PALM) scheme, are not simply outliers. They point to deeper weaknesses in how organisations understand and manage immigration compliance.

The most concerning factor? These risks are not hidden. They are embedded within known vulnerabilities in workforce structures, visa frameworks, and subcontracting arrangements. What’s missing is serious accountability, at the executive level.

Dependency, Silence, and Structural Power Imbalances

PALM visa holders, many employed in agriculture, meat processing, and regional service industries occupy an uncertain position in the labour market. Their work rights are tied to a single employer, which means speaking up against poor treatment can carry the very real threat of losing their job, and with it, their right to remain in the country.

Lawyer Joshua Strutt, from the Immigration Advice and Rights Centre, has described these workers as “among the most exploited in Australia.” His organisation has seen cases involving unsafe housing, withheld wages, and serious injuries all going unreported due to fear of visa cancellation.

Some industry groups claim satisfaction surveys show these workers are content. But those who work directly with affected communities, including union leaders and legal advocates, see something different: fear, coercion, and silence.

This is not about bad actors operating in the shadows. It is about systemic blind spots that allow exploitation to flourish in plain sight.

Woolworths and the Cost of Reactive Compliance

To its credit, Woolworths acted when a third-party labour hire firm was found housing workers in substandard conditions. That firm has since been removed from the PALM register. Yet it continues to seek re-entry into the market under different guises, demonstrating how difficult it is to manage workforce compliance when subcontracting chains lack transparency.

Woolworths audits more than 1,000 worksites a year, identifying thousands of compliance breaches, ranging from safety violations to underpayment. In recent Fair Work Ombudsman investigations, Woolworths and its partners agreed to pay $98,000 in lump sum remediation across meat and produce sites in New South Wales.

These actions, while commendable, are reactive. The question for business leaders is: why weren’t these issues identified sooner?

Immigration Compliance Is No Longer a Back-Office Function

Under the Migration Amendment (Strengthening Employer Compliance) Act 2024, the stakes for immigration compliance have changed. From 1 July 2024, organisations found to be in breach of sponsorship obligations can be placed on a prohibited employers register, barring them from hiring temporary visa holders for up to five years.

This is not a theoretical risk. It is an operational and reputational threat that directly impacts workforce continuity. Businesses that depend on migrant labour across aged care, agriculture, food services, and logistics must now treat immigration compliance as a matter of strategic governance.

Key risks include:

• Civil penalties of up to $79,200 per breach
• Criminal liability for executives under provisions of the Migration Act
• Sponsorship cancellation and access bans for employers
• Contract and supply chain exposure, especially when relying on outsourced labour
• Brand damage, particularly in consumer-facing sectors

It is no longer enough to delegate compliance to HR or legal. Boards and executive teams must be able to evidence active oversight. Organisations also carry obligations under the Modern Slavery Act 2018 (Cth), which requires entities with consolidated revenue above $100 million to identify and address risks of modern slavery in their operations and supply chains. While compliance often focuses on offshore risks, recent domestic cases show that labour exploitation particularly involving visa holders can occur within Australia’s own borders. Immigration compliance must therefore be viewed as a core component of a company’s modern slavery risk strategy, not a separate or secondary concern.

Supply Chains Are a Risk Multiplier

Procurement and vendor management teams are central to this conversation. Where labour is outsourced or delivered through layered subcontracting, the risk of non-compliance increases significantly.

In most organisations, there is little to no visibility into the visa status of contracted workers. VEVO checks are rarely embedded into supplier due diligence. Visa conditions, such as location or role restrictions, are not routinely monitored across third-party arrangements.

In the context of the PALM scheme, these oversights are especially dangerous. Without structured compliance systems, organisations risk becoming complicit in unlawful employment practices, even if the breaches occur further down the chain.

For risk and procurement leaders, this is an inflection point. Immigration compliance must now sit alongside WHS, anti-slavery, and tax compliance in the evaluation of suppliers and labour hire providers.

Manual Processes Are No Longer Defensible

Despite rising enforcement activity, many large employers continue to manage visa compliance through spreadsheets, manual VEVO checks, and email reminders. These systems are not fit for purpose.

Common issues include:

• Inaccurate or outdated visa records
• Missed visa expiries and notifiable event deadlines
• Poor internal awareness of sponsorship conditions
• Inadequate record-keeping to withstand audit scrutiny

In regulated sectors or those with high visa-holder concentrations, such lapses represent a material risk. Failing to act exposes the business to compliance breaches, reputational fallout, and potential service disruption.

The reality is simple: manual systems no longer meet regulatory expectations.

A Smarter Approach: Technology-Enabled Compliance

Complize is one example of a purpose-built compliance platform helping employers take control of immigration risk. Designed specifically for Australian businesses employing temporary visa holders, Complize offers:

• Real-time visa tracking and expiry alerts
  
• Sponsorship obligation monitoring, including notifiable events
• Micro-learning for managers on immigration rules (Visa Bytes)
• Audit-ready reporting and secure document storage
  

The platform integrates seamlessly with existing HR systems and reduces manual effort by more than 80%. Critically, it provides visibility across departments and supplier arrangements, ensuring that immigration compliance is not siloed or reactive.

Closing the Accountability Gap

Migrant worker exploitation is a predictable outcome of weak systems and fragmented oversight. It thrives in the grey areas, where suppliers aren’t scrutinised, where visa holders are left unmonitored, and where executives assume compliance is someone else’s job.

That era is over.

Today, regulators, investors, and the public expect organisations to understand who is working for them, under what conditions, and with what legal authority. This requires more than ethics statements or periodic audits. It demands real systems, active leadership, and enterprise-level accountability.

If your organisation sponsors, employs, or contracts workers on temporary visas, the time for action is now.

To learn how Complize can support your compliance transformation, book a demo today.