A labour crime inspection on site – what are they looking for?

«A-krim» is not one agency but a partnership in which Arbeidstilsynet, NAV, the police and Skatteetaten each use their own statutory powers. An inspection does not necessarily mean the authorities have concluded anything. Find out which agencies are taking part and what they are actually asking for.

What should you do when the inspectors arrive?

Start by establishing which agencies are taking part, who the contact person is, what the inspection covers and what documentation they are asking for. It helps to designate one person – the project manager or the general manager – to coordinate communication. The business should cooperate and produce the documentation that exists, within what each agency has power to require. Do not start tidying the history by changing old timesheets, backdating agreements or constructing missing documents after the inspection has begun. Where something is missing, it is better to say so and put it right in a way that can be verified.

A-krim is not one agency

It matters to understand who inspects what. Arbeidstilsynet can check contracts of employment, working hours, health and safety, generally applicable pay, HSE cards, hired labour and the working environment. Skatteetaten can check tax and duty reporting, a-meldinger, bookkeeping and information about Norwegian and foreign assignments. NAV works on possible abuse of welfare and benefit schemes. The police can follow up identity, unlawful work, human trafficking and other possible criminal offences. So the a-krim centre does not have one a-krim statute giving every inspector the same powers. Arbeidstilsynet describes the inter-agency cooperation.

HSE cards and the site register

Businesses on construction sites have to make sure anyone doing work carries a valid HSE card where the card requirement applies. It applies to sole traders too, and the card has to be worn visibly. The site register is the client's responsibility, not automatically the main contractor's. The client (byggherre) has to maintain an electronic register of everyone who will work on the site, including the site's name and address, the client's name, the businesses working there, organisation numbers where registration is required, each person's name and date of birth, their employer and their HSE card number. The register has to be checked and updated daily and kept for six months after the work ends. The client can agree that the main contractor does the practical work of keeping it, but the client remains responsible for the requirement being met.

Contracts, working hours and pay have to be documentable

Every employee has to have a written contract of employment. On an inspection it can also be relevant to document who is actually working on the site, recorded working hours, payslips, salary payments, who the employer is and any hired-labour arrangements. Pay in money must as a general rule be paid through a bank or payment intermediary into the employee's account. There is a narrow exception where that is impossible or very burdensome. Building work on construction sites is covered by generally applicable pay and working conditions. The rates change over time, so use Arbeidstilsynet's current rates rather than old figures in internal procedures. The Working Environment Act's overtime rules apply on top, with a supplement of at least 40% under the main rule.

Foreign assignments can carry their own reporting duty

Assignments given to foreign contractors in Norway can trigger a duty to report to the Register of Assignments and Employment Relationships. Skatteetaten still refers to the scheme by the familiar form numbers RF-1198 and RF-1199, but the reporting goes through the OAR solution where the conditions are met.

Hiring from staffing agencies has strict rules

As at 2026 there is a ban on hiring from staffing agencies for building work on construction sites in Oslo, Akershus, Buskerud, Østfold and Vestfold. The ban covers the building work itself. Engineers and administrative staff are examples of work that is not necessarily covered. So it is wrong to assume every hired person on a construction site is automatically caught.

Hired labour or subcontracting?

This is a common point of inspection, and what decides it is not what the contract is called. Weight is given to who directs the work, who is responsible for the result, whether what is supplied is mainly labour, whether the work meets a permanent labour need, and whether the work falls within the client's core activity. The actual arrangements decide. An independent subcontractor with its own management of the work and real responsibility for the result can be a contract for services, while a company that in practice just supplies workers under the client's direction can be assessed as hired labour.

The main contractor has a duty to check

In industries with generally applicable pay and working conditions, the contract chain has its own duties. The client has to inform the supplier of the generally applicable requirements, and the main contractor has to check that its subcontractors follow them. That duty does not mean the main contractor has to check every single salary payment. A practical, risk-based approach is to establish procedures and responsibilities, write the requirements into the contracts, assess the supplier's risk, and carry out spot checks and obtain documentation where needed. Suppliers and subcontractors can become jointly and severally liable for generally applicable pay, overtime pay and holiday pay the employer has not paid. The employee normally has to make a written claim within three months of the pay due date. Arbeidstilsynet explains the duty to check.

What if the business finds errors during the inspection?

Do not try to repair the history by constructing documents. Do not backdate contracts of employment, alter old timesheets to hide actual working hours, produce a false subcontract or change payroll documentation. A better approach is to document what is actually missing, find the historical documentation that does exist, correct future practice, put reporting errors right in a traceable way, and answer the authorities' questions accurately.

What consequences can follow?

Arbeidstilsynet can order matters to be put right, attach an enforcement fine to an order, stop activities in particular situations, and impose administrative fines. For unlawful hiring, it can order the business to end the arrangement and impose an administrative fine. Skatteetaten, NAV and the police can follow up their own findings under their own rules. So there is no single a-krim penalty. A construction business should have control of HSE cards, the electronic site register, contracts of employment, working-time records, pay and payslips, payment of pay through a bank, a-meldinger, subcontracting and hiring agreements, documentation of the duty to check, and OAR reporting where it is required. Not all of those documents have to be physically on site – the authorities can ask for several of them to be sent afterwards.

This is general guidance, not advice on your specific case. Deadlines, rates and amounts change – always check the current rules, or get in touch with us.

Is it urgent?

We can work out what actually has to be done, what documentation exists and how quickly it can be sorted. You can also reach us in the evenings and at weekends.

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