By Kelly Palmer, Founder of Palmer Shore, Ireland and North America

The international data centre industry continues to demonstrate extraordinary engineering capability, technological advancement, and commitment to delivering increasingly complex infrastructure. Yet as construction programmes expand across borders, the governance of the international workforces supporting these developments has not always evolved with the same consistency. Behind every major project is an extensive network of contractors, specialist subcontractors, labour providers and professional advisors, each managing obligations that can directly influence workforce availability, regulatory compliance, programme delivery, and commercial performance.

At Palmer Shore, we have consistently raised one fundamental issue through our work and contributions to international industry discussions: workforce compliance cannot be achieved by individual organisations operating in isolation. The industry must move beyond treating compliance as a collection of registrations, certificates and onboarding approvals. Effective governance requires a clear understanding of legal obligations, a willingness to challenge non-compliant practices and collaboration between the organisations responsible for delivering the work.

The consequences of failing to do so can be significant. Retrospective employment liabilities, unpaid overtime, statutory interest, regulatory penalties and workforce restrictions can undermine project margins and create disruption across the supply chain. A project may meet every engineering milestone and still fall short of its anticipated commercial return.

For Palmer Shore, workforce governance is therefore not simply a regulatory obligation. It is an essential component of protecting the commercial integrity of international construction projects.

Commercial accountability begins before mobilisation

The financial implications of international workforce deployment begin long before employees arrive on site.

When contractors enter new jurisdictions, they make commercial commitments based on anticipated labour costs, project durations, and delivery programmes. However, the full implications of corporate tax, payroll, social security, immigration, employment legislation, collective labour agreements, mandatory insurance and working-time requirements are not always understood before contractual pricing is agreed.

Where these obligations are identified after mobilisation, the opportunity to recover additional costs may be limited. A contract that initially appeared commercially attractive can become exposed to liabilities that could have been anticipated through appropriate feasibility assessments and workforce cost projections.

Palmer Shore integrates workforce governance into the early stages of international project planning, helping businesses assess their obligations, understand the true cost of deployment and make informed commercial decisions.

This approach is not simply about avoiding penalties. It is about establishing realistic project margins, protecting contractual commitments, and ensuring that international expansion is supported by appropriate governance from the outset.

The commercial success of a project should not depend on obligations that were never included in its original cost assumptions.

Compliance must be demonstrated, not assumed

Across international construction projects, significant investment has been made in workforce onboarding platforms, site access systems, and contractor approval processes. These are important controls, but they cannot independently demonstrate compliance with every obligation governing an international workforce.

A worker may hold a valid site access pass, have completed all required inductions and appear on an approved workforce register while aspects of their employment or deployment arrangements remain non-compliant. An A1 certificate does not establish immigration permission. A completed induction does not confirm compliance with employment legislation. An approved timesheet does not demonstrate that the correct collective agreement, overtime entitlements, or mandatory rest periods have been applied. These distinctions become particularly important where employees undertake rotational assignments, move between projects or remain deployed internationally for extended periods.

Working arrangements evolve, deployment durations increase and obligations may change throughout the project lifecycle. A compliant position established at mobilisation must therefore be maintained and reassessed as circumstances develop.

At Palmer Shore, we have consistently challenged the acceptance of non-compliant working arrangements and the assumption that administrative approval provides complete regulatory assurance.

We believe that where discrepancies are identified, contractors should be given clear guidance and the opportunity to correct their practices. However, meaningful improvement also requires accountability and a willingness to address arrangements that do not meet the applicable standards.

Challenging non-compliance is not about creating barriers to delivery. It is about establishing the conditions for lawful, sustainable, and commercially responsible project execution.

A timesheet is not just a timesheet

Working-time governance remains one of the most frequently misunderstood areas of international workforce compliance.

Timesheets are routinely submitted, approved, and processed through payroll, yet the accuracy of recorded hours does not necessarily establish compliance with national working-time legislation or the applicable collective labour agreement. Rotational working patterns, extended working days, overtime premiums, mandatory rest periods, employee classifications, and reference periods can create complex obligations that differ between jurisdictions and sectors.

Where these requirements are misunderstood, discrepancies may continue across successive payroll periods without being identified.

For projects employing hundreds of workers across multiple contractors, the cumulative financial consequences can be substantial. Backdated overtime, unpaid wage entitlements, statutory interest, regulatory penalties, and employment disputes can all affect the commercial outcome.

Depending on the jurisdiction and circumstances, legal liability may extend beyond the immediate employer, while the wider supply chain can experience contractual and operational disruption.

Palmer Shore approaches working-time records as an important source of compliance evidence, not simply an administrative requirement. By assessing working arrangements against applicable legal and collective agreement provisions, identifying discrepancies, and supporting corrective action, we seek to reduce the likelihood of avoidable liabilities accumulating throughout project delivery.

The purpose is not simply to identify an incorrect timesheet. It is to understand the underlying working arrangement, establish whether it is lawful and support the changes necessary to maintain compliance.

Collaboration is the foundation of lasting change

International data centre projects are delivered through collaboration. Developers, general contractors, specialist subcontractors, and professional advisors work together to achieve complex technical and commercial objectives.

Workforce governance must be approached with the same collective commitment.

“Joining VID FIREKILL and Ethos at Platform Global 2026 reinforced my belief that collaboration, shared accountability and workforce governance are essential to resilient data centre delivery.”

Kelly Palmer

Each organisation has distinct legal and contractual responsibilities, but the consequences of non-compliance can extend beyond individual employers. Inconsistent working practices, fragmented records, and limited communication between contractors can allow risks to develop without sufficient visibility or timely intervention.

Throughout our participation in industry discussions, including Platform Markets, Palmer Shore has consistently advocated for a more collaborative approach to international workforce compliance. No single contractor, adviser, developer, or technology platform can deliver meaningful and lasting improvement independently.

General contractors require appropriate visibility of the workforce risks within their supply chains. Subcontractors need clear expectations, reliable guidance, and practical support in meeting their obligations. Developers and investors need confidence that appropriate governance arrangements support project delivery and commercial performance.

Professional advisors must also be prepared to challenge assumptions, communicate risks clearly and work constructively with the organisations involved. Collaboration does not remove individual responsibility, nor does it mean accepting non-compliance. It creates an environment in which obligations are better understood, discrepancies can be addressed and contractors have the opportunity to improve their practices.

At Palmer Shore, we recognise that sustainable compliance requires behavioural change. Identifying a breach is only the beginning; understanding why it occurred, correcting the underlying process and preventing recurrence are equally important.

This requires education, communication, transparency, and accountability across the supply chain. The objective should not be to establish who is responsible only after something has gone wrong. It should be to create the conditions in which avoidable failures are identified and addressed before they threaten the project.

Developing technology to strengthen workforce governance

Working alongside our development team, we are building software designed to strengthen the assessment, monitoring, and management of international workforce obligations. This development reflects the practical challenges encountered across construction projects, where working-time records, payroll information, deployment documentation, regulatory registrations, and compliance evidence are often maintained through separate systems and processes.

Our aim is to bring greater structure and consistency to workforce governance, enabling clearer identification of discrepancies, more effective monitoring of obligations and stronger evidence to support compliance reviews. Working-time requirements, collective labour agreements, workforce deployment records, and regulatory obligations are important components of this work. We are not seeking simply to digitalise existing administrative processes.

Our objective is to develop technology that supports better information, earlier intervention, and more informed decisions. However, technology cannot replace professional judgement, regulatory expertise, or the responsibility of organisations to act on identified risks. Its effectiveness depends on accurate information, clear ownership of obligations and collaboration between the parties involved.

For Palmer Shore, technology is an important enabler of stronger governance, supporting our wider ambition to improve consistency, transparency, and accountability across international construction supply chains.

Protecting the commercial outcome

The financial consequences of workforce non-compliance are often considered only when a regulatory investigation, employment claim or contractual dispute arises. By that stage, liabilities may already have accumulated and the opportunity to prevent them may have passed.

We believe the industry must recognise the relationship between workforce governance and commercial performance much earlier. Accurate cost projections support informed tender decisions. Appropriate employment and deployment arrangements reduce the risk of disruption. Reliable working-time records support correct remuneration and compliance with applicable requirements. Ongoing oversight enables emerging discrepancies to be identified and addressed before they become material financial exposures.

Together, these measures can strengthen supply-chain relationships, protect project margins, and provide greater confidence to the organisations investing in and delivering international infrastructure.

The objective is not to suggest that every risk can be eliminated. International construction will always involve complex regulatory, operational, and commercial considerations.

It is to ensure that foreseeable obligations are understood, responsibilities are clearly established and avoidable exposure is reduced through effective governance.

The true measure of commercial success is not simply whether a project is completed, but whether the anticipated return is protected from liabilities that could reasonably have been prevented.

Our commitment to the industry

Palmer Shore has developed its approach around the belief that international workforce compliance should be practical, transparent, commercially informed and supported by collaboration.

We are prepared to challenge non-compliance, question established practices and advocate for higher standards. Equally, we recognise that lasting improvement depends on constructive engagement, shared knowledge, and the willingness of organisations to change how they operate.

Through our work with international contractors, our participation in industry discussions and our continued investment in technology, we are committed to helping move workforce governance from reactive administration towards proactive, evidence-led oversight.

As the data centre industry continues to expand, the strength of its workforce governance will become increasingly important to its ability to deliver projects responsibly, sustainably, and profitably.

Our ambition is to contribute to an industry in which compliance is understood as a continuing responsibility, contractors are supported in meeting their obligations and collaboration enables risks to be addressed before they become liabilities.

We believe the opportunity to improve standards is significant, but no organisation can achieve that change alone.

The future of international workforce governance depends on our collective willingness to challenge non-compliance, strengthen accountability and work together to protect the people, projects, and commercial value behind global infrastructure development.

Compliance protects people. Governance protects projects. Collaboration strengthens the supply chain. Together, they protect profit.

International workforce governance

Palmer Shore supports international contractors and project stakeholders through feasibility and tender assessments, workforce cost projections, cross-border employment compliance, collective agreement monitoring and ongoing workforce governance. Our commitment extends beyond advisory services to advocating for higher industry standards, supporting behavioural change, and developing technology that strengthens international workforce oversight.

Discover our expertise, our approach, and our commitment to advancing international workforce governance.

© 2026 Palmer Shore Limited. All rights reserved.

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Construction projects in Norway, particularly within data centre environments, operate under strict compliance frameworks enforced by the Norwegian Labour Inspection Authority (Arbeidstilsynet), the Tax Administration (Skatteetaten) and the immigration authorities (UDI). Failure to comply can result in immediate site removal, financial penalties, blacklisting from projects, delays in immigration approvals and — in hyperscaler environments — project shutdown.

This handbook sets out what foreign contractors and subcontractors need to know to mobilise and deliver compliantly on construction projects in Norway.

Legal framework

Norwegian construction work is governed by the Working Environment Act (Arbeidsmiljøloven), the General Application Act (Allmenngjøringsloven), the Tax Administration Act and the Immigration Act. Together these regulate working time, minimum wages, health and safety, posted workers, and tax and reporting obligations.

Determining the nature of the work

Construction activities include electrical and mechanical installation, commissioning, roofing and cladding, and structural works. Where work is classified as construction, mandatory minimum-wage regulations apply, reporting obligations increase significantly and labour inspections become more frequent.

Contractor types and registration

Contractors fall into three categories — Norwegian registered companies, EU/EEA contractors posting workers, and third-country contractors — each triggering different tax exposure, immigration requirements and reporting thresholds. Foreign contractors must assess the registrations they need: a Norwegian organisation number, VAT registration (if the threshold is exceeded) and employer registration, plus registration with the Register of Business Enterprises and notification of cross-border activity.

Posted-worker compliance

Before mobilisation, employers must hold an A1 certificate for EU workers, submit the required notification to the Norwegian authorities, and ensure employment contracts are aligned to Norwegian conditions. Failure exposes the project to double social security and immediate compliance breaches.

Collective agreements and classification

Construction-sector wages are governed by generally binding collective agreements (Tariffavtaler) that define minimum hourly pay, overtime rates, travel allowances and accommodation standards. Incorrect application creates wage-dumping risk. Workers must be classified by trade, skill level and experience; misclassification leads to underpayment, audit failure and back-pay liability.

Minimum wage and working time

Norway enforces statutory minimum rates in construction, and authorities review payslips, contracts and time records. Unlike some jurisdictions, allowances cannot be used to offset base salary. Typical working-time limits are a 40-hour standard week and a 9-hour standard day; extended shifts and rotation work require formal working-time arrangements and compliance with rest periods. Overtime must be compensated, justified and recorded, with authorities comparing timesheets against payroll. Saturday work is permitted and Sunday work is restricted, both requiring justification and additional pay.

Social security and A-melding reporting

All employers must submit the A-melding monthly report, covering salary, tax and social security. Failure results in fines and tax investigations. Accurate time records — start and end times, breaks and overtime — must be available on-site during inspections.

Tax exposure

• Permanent establishment (PE) — triggered by long-term project presence, a fixed site or local management, creating Norwegian corporate-tax and accounting obligations.
• Corporate and withholding tax — foreign contractors may face corporate tax, payroll tax and withholding obligations.
• Employee taxation and the 183-day rule — employees may remain taxed at home where they spend fewer than 183 days in Norway, there is no PE and costs are not borne locally; in practice this is often overridden by economic-employer rules.
• Economic employer risk — triggered where work is directed locally, workers are integrated into the project and costs are allocated locally, resulting in Norwegian payroll tax and employer obligations.

Workforce checks and qualifications

Employers must verify EU nationality or valid work permits. Specialist roles — electrical work, mechanical commissioning and other specialist trades — require recognised qualifications available for inspection. Data centre projects also require background checks and security clearance.

Inspections, documentation and liability

The following must be available on-site: A1 certificates, employment contracts, payslips, time records and ID documentation. Main contractors may be liable for subcontractors’ wage breaches, tax failures and social-security issues. The documentation checklist covers company items (registration documents, insurance, tax registration) and employee items (passport, contract, A1 or permit, payslips).

Immigration and skilled-worker permits

For non-EEA workers, a Skilled Worker Permit is required and the employer must sponsor it. Requirements include a job offer, relevant qualifications and a salary threshold. An early start may be possible where an application has been submitted, the employer requests it and the police approve.

Recommended compliance framework

Palmer Shore recommends a four-layer framework: site-entry compliance (documentation for site access), labour compliance (collective agreements, wages, working hours), tax compliance (PE analysis, withholding tax, employee taxation) and contractor oversight (ongoing subcontractor monitoring). The most common failures are missing A1 certificates, incorrect wages, misclassification and a lack of reporting.

In summary

Norway operates a highly controlled compliance environment, particularly in data centre construction and cross-border workforce mobility. Success requires structured onboarding, correct classification and full tax and labour alignment; failure results in financial exposure, operational delays and reputational damage.

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Construction projects in Austria operate within one of the strictest labour-compliance frameworks in Europe. Authorities inspect construction sites regularly to verify compliance with labour law, minimum-wage regulations, working-time laws, social security, posted-worker rules, tax law and construction collective agreements. Failure to comply can result in significant financial penalties, site-access bans, contractor-liability claims and project shutdowns.

Major hyperscale technology companies enforce strict contractor-compliance frameworks across their project supply chains. This handbook sets out what foreign contractors and subcontractors need to know to work compliantly on construction projects in Austria.

Legal framework

Austrian construction work is governed by the Labour Constitution Act, the Working Time Act and the Wage and Social Dumping Prevention Act, which together regulate working hours, minimum wage, worker protection and employment conditions. EU posted-worker rules apply when employees are temporarily sent to Austria — they must receive the Austrian minimum wage, local working conditions and applicable collective-agreement protections. Foreign companies may also trigger corporate-tax, payroll-tax or withholding-tax obligations depending on the project structure.

Determining the nature of the work

Before mobilising, contractors must establish whether the work is a construction activity — roofing, cladding, electrical and mechanical installation, scaffolding, civil works or structural installation. Construction work triggers construction labour agreements, BUAK obligations and stricter inspections. Regulated trades such as roofing, electrical work, heating installation and scaffolding require licensing, and foreign contractors may need to submit a Dienstleistungsanzeige (cross-border service notification) before starting.

Contractor types and registration

Contractors fall into three categories, each with different requirements: Austrian companies operating locally; EU/EEA contractors providing services across borders; and third-country contractors established outside the EU. Depending on the activity, foreign contractors may need a trade notification for regulated trades, Austrian tax registration (where a permanent establishment exists, employees are taxed locally or VAT registration is required) and social-security registration where workers are subject to Austrian social security.

Posted-worker compliance

Before employees travel to Austria, employers must obtain A1 certificates confirming each worker remains in their home-country social-security system — without one, a worker may become liable for Austrian social security — and submit a ZKO notification before work begins, covering employer and worker details, the location of work and the project duration. Failure to submit can result in substantial fines.

Collective agreements and worker classification

All construction workers must be paid according to the applicable Collective Labour Agreement (Kollektivvertrag) — for example the Bauarbeiter (general construction), Dachdecker (roofing) or electrical-installation agreements. Correct classification by trade, skill level, experience and responsibility determines minimum wage, overtime rates, allowances and holiday entitlements. Misclassification is one of the most common compliance failures on site, and authorities compare a worker’s actual role against their pay level.

Minimum wage and working time

Employers must pay at least the minimum wage set in the relevant collective agreement; underpayment is treated as wage dumping and carries significant penalties. A typical standard week is 39 hours, with a daily maximum of 12 hours, a weekly maximum of 60 hours and an average of 48 hours. Overtime must follow collective-agreement provisions, may attract premiums, and is checked by comparing timesheets against payroll records. Weekend work is restricted — Saturday is generally permitted under construction agreements, while Sunday work may require special authorisation and additional pay. Accurate time records (start, finish, breaks and overtime) must be available during inspections.

Construction Holiday Fund (BUAK)

BUAK, the Austrian Construction Workers’ Holiday and Severance Fund, applies to most construction activities. Employers must register workers, submit monthly reports and pay holiday contributions. BUAK typically adds 20–25% to base labour costs, so contractors must plan for the additional payroll expense and cash-flow impact.

Tax exposure

• Permanent establishment (PE) — may arise where project duration exceeds certain thresholds, a fixed site is maintained or employees operate continuously in Austria, creating corporate-tax, accounting and filing obligations.
• Construction withholding tax — Austria may require tax to be withheld on construction services; exemptions may apply depending on registration status.
• Employee taxation and the 183-day rule — employees may remain taxed at home if they spend fewer than 183 days in Austria, the employer has no PE and salary is not borne by an Austrian entity; in practice, projects often trigger economic-employer rules.
• Economic employer risk — even where workers are employed abroad, Austria may treat the project entity as the economic employer where it directs the work, workers integrate locally or costs are borne locally, triggering Austrian payroll tax and employee-tax registration.

Workforce checks and qualifications

Employers must verify each worker’s right to work (EU passport, residence permit, or work permit for third-country nationals). Roles such as crane operators, scaffolders and electrical engineers require certification, with proof available during inspections. Many hyperscaler projects also require criminal-record and security checks for site access and data centre security zones.

Inspections, documentation and liability

During inspections, contractors must produce A1 certificates, ZKO confirmation, employment contracts, payroll and time records, wage payments, worker classifications and qualification records. Main contractors may become liable where subcontractors fail to comply, including for unpaid wages, social-security contributions and BUAK obligations. Before mobilising, contractors should hold the full set: company registration extract, trade registration, liability insurance and company number, plus each worker’s passport, contract, A1, ZKO notification, qualifications and payroll documentation.

Recommended compliance framework

Palmer Shore recommends a four-layer framework: site-entry compliance (documentation for site access), labour compliance (collective agreements, wages, working hours), tax compliance (PE analysis, withholding tax, employee taxation) and contractor oversight (ongoing subcontractor monitoring). The most common inspection failures are incorrect classification, underpayment of wages, missing A1 certificates, failure to register with BUAK and incorrect working hours.

In summary

Austria maintains strict enforcement of labour and tax compliance in the construction sector. Foreign contractors must fully understand and comply with posted-worker rules, collective agreements, working-time laws, tax obligations and social-security regulations — failure to do so can lead to severe financial and operational consequences.

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