Placing workers under 18: what a recruitment agency needs to check first

Most temp desks place under-18s rarely enough that the process isn't a well-worn habit the way an adult placement is — a Saturday retail role, a summer warehouse placement, an apprenticeship-adjacent position. That rarity is exactly why it's worth having a clear, written process for it rather than relying on a consultant to remember the differences the one time a year it comes up.

What actually changes once a work-seeker is under 18

The underlying legal duties an agency carries — a right to work check, agreed terms, a Key Information Document — don't disappear or relax for a younger work-seeker. What changes is what sits around them: working hours are restricted differently, certain types of work are off-limits regardless of what the hirer wants, and DBS requirements are more likely to be triggered because a higher proportion of roles suitable for a 16 or 17-year-old put them in contact with other young people.

Working hours and rest breaks

• –Daily and weekly working hour limits for under-18s are generally stricter than for adult workers, and night work is restricted in most sectors with only narrow exceptions.
• –Rest break and daily rest entitlements are generally more generous for young workers than the standard adult position.
• –Certain hazardous tasks, and work involving specific machinery or licensed activities such as alcohol sales, are restricted or prohibited outright for under-18s regardless of what a hirer's usual role description asks for.
• –These restrictions sit under working time and health and safety legislation separate from the Conduct Regulations, and current gov.uk guidance is the right place to confirm specifics for a given role.

Right to work and DBS — same duty, different practical shape

The right to work check itself isn't different in kind for a younger work-seeker, but age verification becomes part of the same check rather than a separate step — confirming date of birth from the same document used to confirm right to work is a natural, low-effort addition. DBS requirements follow the role as they do for any worker (see our broader look at when temporary workers need a DBS check), but roles suitable for under-18s are disproportionately likely to sit in sectors — education, retail environments serving families, hospitality — where an enhanced check or a barred list check becomes relevant more often than it would for a typical adult commercial placement.

What the hirer needs to know too

A hirer used to running rotas built around adult shift patterns won't automatically know the hour and rest-break restrictions that apply once a worker on their site is under 18 — that's the agency's information to supply, not an assumption the hirer will already have in hand. Flagging the restrictions clearly before the placement starts, rather than discovering a rota breaches them after the fact, avoids a scramble to rearrange shifts once the worker has already started.

Consent, and who else needs to be in the conversation

There's no single blanket legal requirement for parental or guardian sign-off on every placement of a 16 or 17-year-old, but it's good practice, and in some cases a specific hirer or sector expectation, to have a parent or guardian aware of and comfortable with the placement, particularly for a first assignment. Building this into the standard conversation — not necessarily as a formal signatory on the work seeker's agreement, but as a genuine check that's actually happened — avoids an awkward situation later if a parent contacts the agency with concerns nobody flagged in advance.

Where this goes wrong in practice

The most common failure isn't a deliberate shortcut — it's a consultant who places under-18s rarely enough that the hour restrictions and role limitations simply aren't front of mind, and a generic risk assessment or generic KID template gets used because nothing in the process flags that this placement needs a different one. A date of birth captured at registration that automatically flags an under-18 placement for a different checklist removes the reliance on memory entirely, and is a small addition worth making even for a desk that only places a handful of under-18 workers a year.