Sepang raid: Do you know whose workers are on your site?

On 15 September 2026, Immigration detained 173 foreign nationals at a construction site in Sepang. The department said the suspected breaches involved workers using Temporary Employment Visit Passes (PLKS) issued to other companies and social visit passes being used for work. The matter remains under investigation. For employers and site operators, it raises a practical question: can you account for every foreign worker on your site and the approval that permits that work?

Picture an enforcement visit tomorrow. Security has an access list, Operations has a headcount, and the subcontractor says it handles the permits. HR asks who actually employs each worker, but the three lists do not match. That is when a document gap can stop work and turn into a serious employer relations problem.

The legal position in plain terms

A valid passport and an unexpired PLKS are only part of the answer. The Immigration Department says a PLKS holder cannot change employer or sector without permission. Under section 60K of the Employment Act 1955, an employer must obtain prior approval to recruit a foreign employee, including for an approved change of employer. JTKSM confirms that the approval is given to the employer. A subcontractor can lawfully bring its own workers to a site under the proper arrangement; being on another company's premises alone does not prove an offence. The documents must support the actual employer, work and deployment.

This is where HR should be careful. A supplier contract, site badge or WhatsApp copy of a pass is not enough to resolve an inconsistent record. Establish who employs and pays the worker, who directs the work, and which approval covers the arrangement. Do this with the contractor before there is a dispute or an inspection.

What we recommend HR to do this week

1. Reconcile the people and permits. Match the live site roster against each worker’s legal employer, pass type and validity, approved sector, and any relevant transfer or deployment approval. Include subcontractors and agency workers.
   

2. Verify at source. Ask the responsible employer for current approvals and confirm doubtful records through the proper official channel. Keep a dated record of what was checked, by whom and when.
   

3. Pause unclear assignments. If the permit and deployment do not match, stop assigning that work until Immigration or legal advisers clarify the position. Deal fairly with affected workers and preserve wage and welfare records.
   

4. Put suppliers on notice. Require a named contact, notice before any worker or employer changes, and regular document rechecks. Operations and HR should share one current roster.
   

The site roster is only reliable when it matches the employer and permit records. Make that reconciliation routine. On enforcement day, there is no time to discover that the names match but the employers do not. 

If you need assistance, E2 can help you check the labour suppliers and subcontractors behind that roster. Our vendor review matches worker lists to employer and permit records, flags missing approvals, and helps HR set a process for onboarding and worker changes. If you are unsure about a vendor’s deployment, contact us before the next worker enters your site.