More Inspections, Greater Scrutiny: Why Data Centres Need Workforce Compliance Assurance 

Across Europe, inspections of major construction projects are becoming more frequent and more searching. 

Authorities are looking beyond identity cards, access credentials and folders containing the expected documents. They want to understand the arrangements behind them. 

Who really employs the worker? Are they entitled to work in that country? Have the correct posting notifications been made? Do their tax and social security arrangements stand up to scrutiny? 

They are also looking further into the supply chain. Developers can no longer assume that responsibility stops with the individual subcontractor. 

Activity is not assurance 

Many developers believe workforce compliance has been dealt with because contractors have completed their own checks or workers have passed through an onboarding system. 

In my experience, that is the central mistake. 

Individual contractors apply different standards. They request different documents, interpret requirements differently and make different judgements. Some undertake detailed checks. Others rely on declarations or assume somebody else has already done the work. 

The result can be a project with plenty of compliance activity but no consistent or defensible compliance position. 

There is also too much reliance on access credentials. Being allowed through the gate is not the same as being lawfully and correctly employed. 

This becomes a serious issue on a major data centre project. There may be hundreds of companies, several tiers of subcontracting and thousands of workers from different countries. Some are directly employed. Others work through agencies, foreign companies or local subsidiaries. Each arrangement can bring different immigration, employment, tax, social security and posted-worker obligations. 

Leaving every contractor to interpret those obligations independently is not a credible control. 

When the inspector arrives 

I learnt one fairly obvious lesson in the Royal Marines: the middle of an operation is a poor time to discover that you have forgotten something important. Inspections work on much the same principle. Once an inspector is on site, small gaps in the evidence have an irritating habit of becoming large problems. 

The project must produce evidence. Who employs this worker? What has been checked? Is the evidence current? Who approved the worker, and on what basis? 

And, importantly, can the project retrieve that information quickly? 

If the answers are spread across contractors, emails and spreadsheets, the project loses control of the situation. Missing evidence cannot sensibly be reconstructed while an inspector is waiting. Assurances that the paperwork exists somewhere will not carry much weight. 

The European Labour Authority is helping national bodies work together on cross-border inspections. Between 2021 and December 2024, it supported 236 inspections involving almost 19,000 workers. Construction is one of the sectors receiving particular attention. The Authority has also said that it wants joint inspections to become more frequent and systematic. 

Do platforms matter for workforce compliance?

A good workforce platform gives the project one structured source of information. 

It applies common onboarding requirements, shows the status of workers and contractors, identifies missing or expiring evidence and preserves a clear audit trail. Most importantly, it gives the developer visibility across the supply chain. 

Without that visibility, the developer is largely dependent upon individual contractors saying that everything is in order. 

The platform is central, but it does not work alone. It provides the structure, evidence and visibility. Experienced assessors provide the judgement required when national rules differ or employment arrangements are unusual. 

That combination matters. Technology makes consistent oversight possible at scale. Expert assessment makes the evidence reliable. 

So what is Workforce Compliance Assurance?

This is where I draw a distinction between workforce compliance and Workforce Compliance Assurance. 

Workforce compliance is the obligation. Workforce Compliance Assurance is the evidence that the obligation is being met. 

It means setting one project-wide standard, independently verifying workers and employers, recording why each decision was made and maintaining a current, auditable record throughout the project. 

This is not a one-off check at mobilisation. Documents expire. Workers change employer. Contractors introduce new companies into their supply chains. The compliance position changes, so the evidence must be maintained. 

Nor is the objective simply to get people through the gate. 

It is to give the developer confidence that the workforce is lawfully engaged, that contractors are being held to a consistent standard and that the project is ready when – not if – it’s inspected. 

The test is straightforward. If an inspector selected any worker on site tomorrow, could the project identify the employer, explain what had been checked and produce the evidence without searching across several organisations and systems? 

If the answer is uncertain, the project may have compliance processes. It doesn’t yet have Workforce Compliance Assurance.