Record-Keeping for Accommodation Audits: What HR Should Be Able to Produce

Build Well · 3 September 2026

Most accommodation audits are not lost on the condition of the buildings. They are lost on paperwork: the approval certificate nobody can locate, the inspection report that was never filed, the allocation list that stopped matching reality three months ago. This guide sets out what an HR team should be able to produce on request, what sits with the camp operator, and how to keep the file current without turning it into a project.

Who asks to see accommodation records?

Four groups, and they ask for different things. Government inspectors are the obvious one: MOHRE and municipal authorities assess the facility itself, but they also expect the employer to be able to explain where its workers live and under what arrangement. Regulations in this area are updated from time to time, so treat any list of documents as a floor rather than a ceiling, and confirm the current position with your PRO.

The second group is your clients. Main contractors, international principals and supply-chain auditors increasingly ask about worker welfare before they award or renew work, and they ask in writing. The third is your own group: internal audit, HSE or a parent company running a compliance review. The fourth, less often but at the worst possible moment, is an insurer or a lawyer after an incident.

Which documents should HR be able to produce?

Start with the commercial paperwork. The signed accommodation contract, all annexes, and a written schedule of what the price includes are the base of the file. If the arrangement is all-inclusive, the contract should say so in terms that name the services covered, because "all-inclusive" means different things to different operators. Keep any variation letters with the contract rather than in an email thread.

Next, evidence that the facility is properly approved. That means the operator's approval status for worker accommodation, the relevant municipal permissions, and the operator's trade licence, each with its expiry date noted somewhere you will actually see it. A certificate that expired in March is worse than no certificate at all, because it shows the file was built once and then abandoned.

Then the people layer, which is the part HR most often neglects. You should be able to produce a current allocation list showing which employee is housed in which building and room, with move-in and move-out dates. Reconcile it against payroll monthly. Auditors test this by picking three names at random and asking where those people sleep; the answer should take a minute, not a morning.

Finally, the evidence that you have been paying attention: dated site-visit notes, photographs, the log of complaints raised and how each was closed, copies of inspection reports and any corrective actions taken. Employers sometimes avoid recording complaints on the theory that a clean file looks better. The opposite is true. A file showing eleven issues raised and eleven closed demonstrates a functioning system. A file showing nothing demonstrates that nobody was looking.

What sits with the operator rather than with you?

A good deal of the technical record belongs to whoever runs the facility, and you are entitled to ask for it. That includes fire safety and civil defence documentation, water tank cleaning and pest control records, kitchen hygiene and maintenance logs, the waste removal schedule, security staffing arrangements and the CCTV retention policy. None of this is unreasonable to request, and an operator who has genuinely done the work will hand it over without a negotiation.

The practical move is to stop asking for these documents individually and write a standing obligation into the contract instead: a quarterly compliance pack, delivered on a set date, containing the current versions. It costs the operator very little and it means that when an audit lands, three quarters of your file is already assembled. If you are choosing between providers, ask each one whether they can supply such a pack. The answer is a reliable proxy for how the camp is actually run, as is the way they handle .

How should the file be organised and kept current?

One folder, one named owner, one review date each quarter. That is the whole system, and it fails almost entirely because of the second item: files with no owner drift. Give it to a specific person in HR or administration, and put the quarterly review in their objectives rather than in their inbox.

Date and version everything, including photographs. Diary the expiry dates of every certificate and licence sixty days ahead, so renewals are chased before they lapse. Reconcile the allocation list monthly against joiners and leavers, because that is the record that decays fastest. And keep the site-visit habit: a short dated note after each walkthrough, even a paragraph, builds a chronology that no retrospective effort can reproduce.

What does a weak record-keeping trail actually cost?

Rarely a fine, at least at first. The usual costs are quieter. A client audit stalls and the renewal slips a quarter. A deposit dispute at contract exit turns on condition photographs that were never taken. An incident occurs and the company cannot evidence the checks it genuinely carried out, so it is treated as though it carried out none.

There is also a straightforward time cost. HR teams routinely spend days rebuilding a file under deadline pressure, when an hour a quarter would have kept it standing. The paperwork is not the point of good accommodation, but it is the only proof of it that survives contact with an auditor.

The Build Well position

Build Well operates MOHRE-approved staff accommodation in and , managed by Build Well Facilities Management LLC as a single accountable operator. Because approval, security, housekeeping and maintenance sit with one party rather than several, the documentation employers need for an audit comes from one source and one point of contact.

Frequently asked questions

How long should we keep accommodation records after a worker leaves?

Align retention with your general employment record policy rather than treating accommodation separately, and keep the contract and approval documents for the life of the arrangement plus a reasonable period after. Retention requirements are updated from time to time, so confirm the current position with your PRO or legal adviser.

Is the employer or the camp operator responsible if records are missing in an audit?

The operator holds the facility documentation, but the employer remains accountable for its workers' housing arrangements. In practice both are asked, and the employer is the one whose approval or client relationship is at risk, so the sensible approach is to hold copies of anything you would need to produce yourself.

What is the single record HR most often cannot produce?

A current, accurate allocation list. Contracts and certificates are usually filed at signing, but the record of who is living where changes every month and is rarely maintained. Reconciling it against payroll each month solves most of the problem.

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