Sham Contracting

Representing an employment relationship as independent contracting in Australia, which is prohibited under the Fair Work Act and carries civil penalties.

Compliance

Sham contracting is the Australian term for disguising employment as a contracting arrangement. The Fair Work Act specifically prohibits it, which puts it on a different footing from jurisdictions where misclassification is addressed only through tax and entitlement recovery.

What is prohibited

  • Telling a worker they are an independent contractor when they are in fact an employee
  • Dismissing or threatening to dismiss an employee in order to re-engage them as a contractor
  • Making a knowingly false statement to persuade an employee to become a contractor

How the line is drawn

Australian courts assess the totality of the relationship, and recent High Court decisions placed greater weight on the terms of a comprehensive written contract than earlier authority did. Legislative change has since reintroduced a focus on the real substance and practical reality of the relationship. The position has moved more than once, which is a reason to treat confident assertions about classification with care.

Why it matters when hiring internationally

Engaging Australian workers as contractors because it is administratively simpler carries a specific statutory risk here, over and above the back-pay and superannuation exposure. Penalties apply to the engaging entity, and the defence that the employer was unaware is limited. Where a role has the characteristics of employment, employing the person, whether directly or through an Employer of Record, is the position that holds.

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