Why Healthcare Employers Must Rethink Visa Compliance Now

Across Australia's healthcare sector, the alarm bells around immigration compliance are getting louder. But are those at the top listening?

Most CEOs and Board Members know that the sector is increasingly reliant on international workers. In some aged care facilities, visa holders make up over 50% of the workforce. What’s less widely appreciated is the risk profile that now comes with that reliance—and how poorly equipped most organisations are to manage it.

Until recently, visa compliance was quietly filed under HR administration. Spreadsheets, emails, and good intentions were enough to satisfy internal risk frameworks. Today, that mindset is dangerously out of date.

Enforcement Is Escalating—And It's Targeting the Frontlines

Between July and December 2024, the Department of Home Affairs conducted over 1,700 site visits. In Melbourne alone, more than 40 businesses employing migrant workers—mostly in food and retail—were hit with joint surprise inspections by Border Force and the Fair Work Ombudsman. Healthcare is next.

The new Migration Amendment (Strengthening Employer Compliance) Act, which came into effect 1 July 2024, gives regulators sweeping powers. Organisations found in breach of sponsorship obligations may be barred from hiring temporary visa holders for 5 or even 10 years. In practice, that could mean shutting down entire wards, cancelling home care visits, or breaching aged care service delivery contracts.

Worse, personal liability provisions under the Migration Act (Sections 245AJ & 245AK) extend to executive officers. That means directors may be held civilly or criminally liable for failures to prevent unlawful work—regardless of whether they were directly involved.

Boards Have Underestimated the Strategic Risk

Visa compliance is not just a matter of good HR hygiene. It's a strategic governance issue that reaches across legal, workforce, and operational domains.

Consider the real consequences of a single compliance failure:

• $300,000+ in civil penalties for employing a worker without the right visa.
• Loss of accreditation if care standards can't be met due to staff shortages.
• Reputational damage if an organisation appears on the Department’s "prohibited employer" register.
• Emergency staffing costs of $750+ per carer shift or $1,000+ for registered nurses if visa holders must be stood down.
  
  Now multiply that by dozens—or hundreds—of workers. Suddenly, compliance failures look less like isolated administrative slip-ups and more like a systemic risk capable of derailing an organisation’s service delivery and financial position.

Manual Systems Are Not Fit for Purpose

Despite the stakes, many healthcare providers still rely on decentralised spreadsheets, outdated VEVO check logs, and email-driven processes. These manual systems:

• Provide no real-time visibility into visa status
• Can’t scale with workforce growth
• Offer no audit trail
• Leave hiring managers and supervisors in the dark
  
  Even with a diligent HR team, the sheer volume of notifiable events, visa expiries, and changing conditions makes human error inevitable. That risk is now untenable.

Governance Requires Systems—Not Just Policies

Regulators have made clear that intent is not enough. Organisations must actively manage visa compliance across onboarding, role changes, and exits. This requires:

• Automated alerting for visa expiries and work condition breaches
• Centralised dashboards for executive oversight
• Record-keeping systems capable of supporting legal defensibility
• Training for managers and staff on sponsorship obligations

It’s not about punishing HR. It’s about equipping them—and everyone else—with the tools to stay compliant.

Complize: A Compliance System for the Real World

Complize is a purpose-built immigration compliance platform, designed for sectors like healthcare and aged care where international workforce reliance is high.

We digitise the entire compliance lifecycle—from VEVO checks and notifiable event management to condition tracking and automated alerts. We provide:

• Workforce Module: Real-time compliance dashboards, reporting, and alerting.
• Visa Bytes: Micro-learning to train hiring managers and reduce HR bottlenecks.
• Knowledge Hub: Legal guides, checklists, and templates updated as the law changes.
  In a typical organisation employing 250 sponsored workers, Complize replaces over 1,000 hours of manual work and mitigates $600,000+ in contingent risk annually. In high-risk years, our platform delivers ROI exceeding 30x by avoiding sponsor bars, emergency hiring, and reputational fallout Aged Care Business Case….

The Board’s Responsibility

The risk is now squarely at the Board level. Just as directors are expected to oversee financial, clinical, and cybersecurity risks, so too must they now interrogate immigration compliance posture.

• Are our systems fit for purpose?
  
• Do we have real-time visibility into visa status and work rights?
  
• Can we demonstrate compliance to the Department—today—if asked?
  
  If the answer to any of those is “no,” action is required.

The Time to Act Is Now

In healthcare, regulatory enforcement is no longer theoretical. It’s active, escalating, and unforgiving of outdated systems. Organisations must stop treating visa compliance as an HR side issue and start addressing it as the board-level governance risk it has become.

Complize offers a clear path forward—for those ready to act.

→ Book a confidential assessment  with our team to review your current compliance posture.