Labour supply apps, farms and food processing: the gangmaster licence

Apps and platforms that fill shifts automatically are spreading into farm work, packhouses and food factories. In those sectors the Gangmasters (Licensing) Act 2004 adds a layer that general recruitment rules do not: anyone who supplies workers for the work it covers must hold a licence, and a business that uses an unlicensed supplier can commit an offence. This page explains who is caught and what to check.

The short answer: a person must not act as a gangmaster except under the authority of a licence (s6(1)). Supplying a worker to do agricultural work, shellfish gathering, or processing or packaging of farm produce, fish or shellfish for another person is acting as a gangmaster (s3, s4), and it makes no difference whether the supply runs through intermediaries. Acting without a licence, and entering into arrangements with an unlicensed gangmaster, are criminal offences (s12, s13).

Which work is covered

The Act applies to (s3(1)):

• agricultural work, where agriculture includes dairy farming, producing consumable produce for sale or other use, grazing land, orchards, woodland, market gardens and nursery grounds;
• gathering shellfish; and
• processing or packaging produce derived from agricultural work, or shellfish, fish or products derived from them.

Regulations can exclude or add descriptions of work (s3(5)), so check them for a particular activity. The work covered is work in the United Kingdom, on the adjacent shore or seabed, or in UK coastal waters, and the Act applies whether the gangmaster acts in the UK or elsewhere (s5).

Who counts as a gangmaster

A person acts as a gangmaster if they supply a worker to do covered work for another person (s4(2)). For that purpose it does not matter (s4(3)):

• whether the worker has a contract with the supplier or is supplied to it by someone else;
• whether the supply is direct or through one or more intermediaries;
• whether the supplier supplies the worker itself or procures the supply;
• whose control the work is done under.

A person also acts as a gangmaster if they use a worker to do covered work in connection with services they provide to another person, or, for their own business, use a worker to harvest or gather produce they have bought or agreed to harvest, to gather shellfish, or to process or pack such produce (s4(4) and (5)). Making arrangements under which the worker does the work counts as using them, whether or not the worker is self-employed or has a contract (s4(6)).

A "worker" is an individual who does covered work, and someone without the right to be or work in the UK is still a worker for the Act (s26).

For a platform, the question is what it actually does. One that finds, sends or arranges workers for a farm or packhouse may be supplying or procuring the supply of workers, even if the work is offered through an app and accepted by the worker. Regulations can set out circumstances in which a licence is not required (s6(2)), so check those before concluding either way.

The licence

Licences are granted by the Secretary of State, for the period and subject to the conditions the Secretary of State considers appropriate, and describe the activities they authorise (s7). Section 7 takes this form following amendments by the Employment Rights Act 2025 from 7 April 2026. A licence covers the holder and the people employed or engaged by the holder who are named or specified in it (s7(3)). Breaching a licence condition is not, by itself, acting without a licence (s12(1)).

Offences

• Acting without a licence, or holding a false, improperly obtained or someone else's licence document to make people believe an unlicensed gangmaster is licensed, carries up to ten years' imprisonment on indictment (s12).
• Using an unlicensed gangmaster: a person commits an offence if they enter into arrangements under which a gangmaster supplies them with workers or services and the gangmaster is acting without a licence (s13(1)). It is a defence to prove they took all reasonable steps to satisfy themselves that the gangmaster had a valid licence and did not know, and had no reasonable grounds to suspect, that it did not (s13(2)).

Practical steps

• Farms, packhouses and food processors: before taking workers through any app, agency or contractor, check that whoever is supplying them holds a licence that covers the activity, and keep a record of the checks. Repeat the check through the chain if workers come via intermediaries.
• Platforms and labour providers: map your model against section 4, including procuring a supply and using workers to provide services to a client, and take advice before operating in these sectors without a licence.
• The recruitment rules still apply alongside the licence; see recruitment agency rules.
• Workers: you count as a worker under the Act whatever your immigration status. If you are sent to farm, shellfish or food packing work, you can ask who is supplying you and whether they are licensed.

For pay and equal treatment once placed through an agency, see agency workers. This page is general information on the law as at 2 November 2026, not legal advice.