Key points
- The ILO position is that workers should not be charged recruitment fees and related costs.
- A cost record lists each cost type, amount, payer, date and receipt per placement.
- Record facts as they happen, review them on a schedule, and keep corrections as new entries.
- The record shows what happened. It does not itself show that any rule has been met.
Questions about who paid what in a placement come from several directions: employer clients, source-country partners, auditors and workers. They are hard to answer well when the costs are spread across invoices, bank transfers and chat messages.
The International Labour Organization restated its position on 11 May 2026: jobseekers, and especially vulnerable migrant workers, should not be charged recruitment fees and related costs. Whatever the rules in your corridor, a clear record of each cost is the foundation for answering any question on the subject.
This article describes a cost record that an agency can keep. It records what happened. It does not decide whether any cost was permitted. For that, use the rules from the authority in the relevant country and your legal adviser.
What counts as a cost entry
Record every cost connected to the placement, whoever paid it. Typical categories are:
- recruitment or service fees
- medical examinations
- visa, permit and processing charges
- travel and transport
- insurance and similar cover
- training or orientation
- accommodation before deployment
- document preparation and attestation
Use a fixed list so the same type of cost is always called the same thing. A free-text label makes totals unreliable.
What each entry holds
For each cost, keep:
- Placement and worker: which placement it belongs to.
- Type: from your fixed list.
- Amount and currency: exactly as invoiced or paid.
- Payer: who actually paid. The employer client, the agency, a partner or the worker.
- Date: when it was paid.
- Evidence: the invoice, receipt or transfer record.
- Entered by: who made the entry, and when.
The payer field is the one that matters most and is most often left vague. Name the party, not "company".
Record at the moment of payment
Costs entered at month-end are costs rebuilt from memory. Enter the cost when the invoice is approved or the payment is made, with the document attached. A short daily habit beats a long monthly clean-up.
Keep corrections as new entries
If a cost was entered wrongly, do not overwrite it. Add a correcting entry that refers to the original, with a reason and a date. The history of corrections shows that the record is honest.
Review by exception
Once a week, or at each stage change, look at three lists:
- placements with a cost that has no evidence attached
- costs where the payer field is blank or ambiguous
- placements with no cost entries at all
Fix each list to empty. An empty list is a sign that the record is complete enough to rely on. If you already run a weekly expiry review, these three lists can join it.
Be careful with what the record claims
A cost register shows what was recorded. It does not show that all costs have been captured, or that any rule on who may bear a cost has been met. Avoid summary wording that suggests more than the record shows, in reports and in messages to clients. Describe the facts and the date range they cover.
Questions the record should let you answer
A cost record is useful when it can answer plain questions quickly. For any placement, can you say what was paid, by whom, on what date, and where the receipt is? For an employer client, can you list the costs recorded against their workers for a period? For a worker, can you show the entries that relate to them?
If any of these takes more than a few minutes, look at where the difficulty lies. Usually it is a missing payer name, a receipt kept outside the record, or a cost type that has no fixed label. Fix the structure, then the entries.
Weekly review checklist
- Every cost entry has a payer, an amount, a date and a document.
- No placement has a cost that is missing evidence.
- Corrections are separate entries with a reason.
- Totals for each employer client can be produced from the entries.
Where Worker Vault fits
Worker Vault includes a recruitment cost register on each placement, with who paid and what, recorded factually. At deployment, recruitment costs carry into the worker's record along with documents and compliance records, so the history stays with the worker.
The register is a record of facts entered by your team. It is not a cost analytics tool and it does not decide whether any fee is lawful. To see how it sits with placements and worker records, Book a Demo, or read about compliance follow-up and what travels with the worker at deployment.
See your workers, documents and deadlines in one place
Book a demo and we will walk through how your agency would run recruitment and worker records in Worker Vault.




