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Ethical nurse recruitment: fees, the WHO Code and how to spot scams (2026)

Why nurses should never pay to get a job abroad, what the WHO Code and the UK Code of Practice mean for you, and how to spot fake job offers and illegal agents.

Nurses are needed in many countries, and that attracts people who want to make money from nurses. Some are honest agencies that the employer pays. Others charge nurses illegal fees, sell fake job offers or disappear with the money.

This guide explains three things. First, who should pay for recruitment. Second, the ethical recruitment rules that employers and agencies follow, such as the WHO Code and the UK Code of Practice. Third, how to spot a fake offer and protect yourself. It is general information for nurses and midwives anywhere. Rules were checked on the official pages in October 2026.

Rule one: you should not pay to get a job

The International Labour Organization (ILO) sets out fair recruitment principles. One of them is that “workers shall not be charged directly or indirectly, in whole or in part, any fees or related costs for their recruitment” (ILO). These principles are guidance, not law, but many countries have laws that follow the same idea.

In the UK, it is the law:

  • It is illegal under section 6(1) of the Employment Agencies Act 1973 for a recruitment organisation or agency based in Great Britain to charge a work-seeker a fee for finding them work (UK Code of Practice).
  • The UK employer pays the sponsor licence fee, the certificate of sponsorship (CoS) fee and the immigration skills charge. You should never be asked to pay these (GOV.UK).

Some official costs may still be yours, depending on the country and the employer. Examples are your own visa application fee, exam fees and registration fees. You pay these to the official body (the government, the test provider or the nursing regulator), not to an agent. If someone asks you to pay them for a job, an interview or a sponsorship document, stop.

The WHO Global Code of Practice

The WHO Global Code of Practice on the International Recruitment of Health Personnel was adopted by the World Health Assembly in 2010 (WHO). It is voluntary. Its main ideas, from WHO’s own overview (WHO overview):

  • Recruitment should be transparent and fair, and should not weaken the health systems of developing countries.
  • Migrant health workers should get fair recruitment and equal treatment.
  • The Code does not limit the freedom of health workers to move to countries that want to admit and employ them, in line with the law.
  • Active recruitment from countries with a critical shortage of health workers should be discouraged.

On 29 May 2026, the World Health Assembly amended the Code. It now covers health workers recruited as care workers, applies during emergencies, and encourages destination countries to invest in source countries’ health workforce (WHO news).

The WHO safeguards list

WHO also publishes the Health Workforce Support and Safeguards List. The 2023 list has 55 countries. They have fewer doctors, nurses and midwives than the global median (49 per 10,000 people) and low coverage of essential health services (WHO). Employers and agencies that follow the Code do not actively recruit health workers from these countries. WHO says an updated list will be published later in 2026.

What this means for you as a nurse: the list does not stop you from moving. It limits what employers and agencies may do. National codes based on it, such as the UK code below, ban things like advertising to you or paying for referrals. You can still find a job yourself and apply directly to the employer.

The UK Code of Practice

England has its own Code of Practice for the international recruitment of health and social care personnel, last updated on 27 March 2025. Wales follows it. Scotland and Northern Ireland have separate codes. It applies to NHS and private employers, agencies and other recruiters (UK Code of Practice).

Red, amber and green countries

List What it means
Red No active recruitment. The red list is drawn from the WHO safeguards list.
Amber Recruitment only under the terms of a government-to-government agreement.
Green Active recruitment is allowed.

You can see which countries are on each list in the code itself.

Active recruitment and direct applications

“Active recruitment” is when employers or agencies target people to market UK jobs to them. It includes advertising to candidates through any medium and referral bonus schemes.

A direct application is different. It is when you apply for a specific advertised job yourself, straight to the employer, without a third party. The code allows employers to consider direct applications from people in any country, including red and amber countries. NHS Employers confirms this in its Code of Practice FAQ.

The Ethical Recruiters List

NHS Employers keeps the Ethical Recruiters List. It lists the recruitment organisations and agencies that follow the code. UK health and social care employers are told to use only agencies on this list. You can search it by organisation name. Before you work with an agency for a UK job, check that it is on the list.

Repayment clauses

Some UK employers ask you to repay certain costs if you leave early. The code says these clauses must be transparent, proportionate, time-limited and flexible. The employer may include costs such as relocation, visa fees and regulatory exam fees. It may not ask you to repay the agency fee, the immigration skills charge, the sponsor licence fee, the certificate of sponsorship or the cost of the interview process. The code gives an example where the amount falls over three years: 100% in the first year, 50% in the second, 25% in the third, and nothing after 36 months.

How to spot a fake job offer

GOV.UK lists these warning signs of a recruitment scam (GOV.UK):

  • Someone contacts you out of the blue about a job.
  • The job needs no experience.
  • The salary is unusually high.
  • The job description is vague or badly written.
  • There are no contact details or no real address.
  • You are asked to pay a fee up front.

The UK government also warns that scammers use email addresses and phone numbers that look official but are not, give false names, and promise “guaranteed” visas or jobs that do not exist (GOV.UK). If you pay for a fake certificate of sponsorship, you can lose your money and your visa application will be refused.

Other signs to watch for:

  • No registration is mentioned. To work as a registered nurse you must register with the nursing regulator in that country, such as the NMC in the UK. An offer that skips this is a warning sign.
  • Pressure to decide fast or to keep the offer secret.
  • You must send your original passport or certificates to an agent.

How to protect yourself

  1. Find the job on the employer’s own website. On this board, every job links to the employer’s own careers page, so you apply straight to the employer.
  2. Check the employer. For the UK, check that the employer is on the register of licensed sponsors. Call the employer using a phone number from its official website, not one in the message you got.
  3. Check the agency. For UK jobs, check the Ethical Recruiters List. In other countries, check the government’s list of licensed recruiters.
  4. Pay official fees only to the official body. Pay exam, registration and visa fees on the official website of the regulator, test provider or government.
  5. Get everything in writing. Ask for a written contract that shows the salary, hours, and any repayment clause, before you travel.
  6. Keep records. Save every message, receipt and document.

If something goes wrong

  • Stop paying. Scammers often ask for “one more fee”.
  • Report a UK agency that charged you a fee. For agencies in Great Britain, use the Employment Agency Standards online form or email eas@businessandtrade.gov.uk. For Northern Ireland, contact the Employment Agency Inspectorate (GOV.UK).
  • Report fraud. The UK government’s fraud page lists Action Fraud (actionfraud.police.uk) for the UK. Outside the UK, report it to your local authorities (GOV.UK).
  • Tell the real employer if the scammer used its name, through the contact details on its official website.

Frequently asked questions

No. Under section 6(1) of the Employment Agencies Act 1973, it is illegal for a recruitment agency based in Great Britain to charge a work-seeker a fee for finding them work. The employer also pays the sponsor licence fee, the certificate of sponsorship fee and the immigration skills charge.

What is the WHO safeguards list?

It is a WHO list of countries with too few health workers. The 2023 list has 55 countries with fewer doctors, nurses and midwives than the global median and low health service coverage. Employers and agencies that follow the WHO Code do not actively recruit from them. An update is due later in 2026.

Can I apply for a UK nursing job if I live in a red list country?

Yes, by direct application. The UK Code of Practice allows employers to consider direct applications, where you apply for a specific advertised job yourself, straight to the employer, without a third party. What the code stops is active recruitment, such as agencies advertising to you or being paid for referring you.

How do I check if a recruitment agency is ethical?

For UK jobs, look for the agency on the Ethical Recruiters List kept by NHS Employers. You can search it by name. UK health and social care employers are told to use only agencies on this list. Also check that the employer is on the UK register of licensed sponsors.

What are the warning signs of a fake nursing job offer?

GOV.UK lists unexpected contact about a job, no experience needed, an unusually high salary, a vague job description, no contact details or address, and a request to pay a fee up front. An offer that does not mention registration with the nursing regulator is also a warning sign.

Sources

  1. https://www.ilo.org/publications/general-principles-and-operational-guidelines-fair-recruitment-and
  2. https://www.who.int/publications/i/item/wha6316
  3. https://cdn.who.int/media/docs/default-source/health-workforce/migration-code/who-global-code-of-practice-an-overview.pdf?sfvrsn=89d1f628_1
  4. https://www.who.int/publications/i/item/9789240069787
  5. https://www.who.int/news/item/29-05-2026-who-global-code-of-practice-on-the-international-recruitment-of-health-personnel-amended
  6. https://www.gov.uk/government/publications/code-of-practice-for-the-international-recruitment-of-health-and-social-care-personnel/code-of-practice-for-the-international-recruitment-of-health-and-social-care-personnel-in-england
  7. https://www.nhsemployers.org/articles/ethical-recruiters-list
  8. https://www.nhsemployers.org/articles/code-practice-frequently-asked-questions
  9. https://www.gov.uk/government/publications/applying-for-health-and-social-care-jobs-in-the-uk-from-abroad/part-1-applying-for-health-and-social-care-jobs-in-the-uk-from-abroad
  10. https://www.gov.uk/government/publications/frauds-tricks-and-scams/fraud-tricks-and-scams
  11. https://www.gov.uk/government/publications/register-of-licensed-sponsors-workers
  12. https://www.nmc.org.uk/registration/joining-the-register/register-nurse-midwife/trained-outside-uk/

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