New research from the European Labour Authority (ELA) provides valuable insight into the workforce compliance challenges facing major construction and infrastructure projects across Europe.
The report, examining the posting of Third-Country Nationals (TCNs) within EU labour supply chains, identifies a consistent theme: workforce compliance risks are increasingly associated with complex subcontracting structures, labour providers and limited visibility beyond Tier 1 contractors.
Among the key findings:
- Compliance risks often emerge deeper within labour supply chains rather than at principal contractor level.
- Authorities report increasing difficulty identifying the true employer and responsible party within complex contracting arrangements.
- Labour providers, recruitment intermediaries and cross-border employment structures add further layers of complexity.
- Documentation alone rarely provides sufficient assurance.
- Effective oversight requires visibility, transparency and ongoing monitoring across the workforce supply chain.
For the data centre construction sector, these findings are particularly relevant.
How compliance issues affect workforce management
As projects continue to scale across Europe, workforce compliance can no longer be viewed solely as a worker onboarding or document verification exercise. It is increasingly a project governance and risk management challenge.
At CEG, our approach to workforce compliance reflects this reality.
Alongside worker verification, we focus on workforce visibility, supply chain transparency and independent assurance, helping clients understand not only who is working on site, but also how workers entered the project, who employs them and where potential risks may exist within the wider contracting structure.
The ELA report reinforces a principle that is becoming increasingly important across major construction programmes:
The greatest workforce risks are often found furthest from the client.

Article by Dieter Loraine
Partner at CEG, which specialises in Workforce Compliance for complex, multi-jurisdictional data centre builds. He has worked across some of Europe’s most tightly regulated labour markets and continues to partner with global developers to establish deep supply chain visibility and robust risk governance across major European infrastructure programmes.