Staffing agency license in Missouri: repealed in 1999, PEO and health care rules now

Missouri does not license employment agencies or staffing firms. Its private employment agency law in RSMo chapter 289 was repealed in 1999, and the chapter number now sits empty between the unemployment and wage chapters. What Missouri does regulate is narrower: professional employer organizations register with the Secretary of State under a 2018 law, and since 2022 agencies that supply temporary health care personnel to hospitals and long-term care facilities, including staffing apps, register with the Department of Health and Senior Services and may not charge conversion fees.

This page covers the repeal, both registrations, a Missouri unemployment rule written for temp firms, and the employer accounts you need. For states with active licensing, see employment agency license requirements.

The 1999 repeal

The revisor shows the former chapter 289 sections, including § 289.005, 289.010, 289.020, 289.060, 289.070 and 289.100, as "Repealed L. 1999 H.B. 343 § A." Chapter 289 no longer appears in Title XVIII. I could not retrieve the 1999 bill text itself, and I did not check city ordinances in St. Louis or Kansas City.

The practical result as of October 2026:

Supplemental health care services agencies

Senate Bill 710 of 2022, effective August 28, 2022, created a registration for supplemental health care services agencies in RSMo 198.640 to 198.648. The definition covers businesses that provide or procure temporary employment for health care personnel in hospitals and licensed long-term care facilities. It expressly includes a temporary nursing staffing agency and the operator of a website or smartphone app that accepts requests for health care personnel, so on-demand shift platforms are inside it. Individuals contracting only on their own behalf are excluded.

Registration

• Annual registration with the Department of Health and Senior Services, separately for each business location (§ 198.642). The department makes annual unannounced surveys.
• Fees: $830 initial and $700 renewal, nonrefundable, under 19 CSR 30-105.020 (rule effective September 30, 2023). The statute caps the fee at $1,000.
• Financial responsibility: an escrow account or irrevocable letter of credit documenting at least four weeks of back wages per employee, and the owner and operator must be registered with the Secretary of State (19 CSR 30-105.030).
• Voided by a sale or transfer of ownership or management. A controlling person whose registration was revoked or not renewed is barred for five years.

Conditions of registration

Under RSMo 198.644, the agency must:

• document credentials and background checks for its personnel;
• carry malpractice insurance, and workers' compensation or, for independent contractors, occupational accident insurance;
• file quarterly reports of average amounts charged and paid by category for facilities that take Medicare or Medicaid;
• keep records for ten years and indemnify facilities, with a $100,000 cap on federal civil money penalties;
• "Not restrict in any manner the employment opportunities of its health care personnel"; and
• refrain, in any contract with personnel or a facility, "from requiring the payment of liquidated damages, employment fees, or other compensation should the health care personnel be hired as a permanent employee of a health care facility."

That last condition is a flat ban, with no pro rata or facility-paid exception. If you staff Missouri hospitals or nursing homes, strip conversion fees and buy-out clauses from those contracts; the general patterns you would be replacing are in temp-to-perm conversion fee. The statute provides for revocation or nonrenewal, including revocation on 15 days' notice for supplying fraudulently credentialed staff; I found no specific fine in it. Temporary nursing staffing agencies must also report disciplinary actions against nurses to the licensing board within 15 days under § 383.133.

PEO registration with the Secretary of State

House Bill 1719 of 2018 created the Missouri PEO registration in RSMo 285.700 to 285.750, enforced by the Secretary of State. Under § 285.715, no person may provide, advertise or hold itself out as providing professional employer services unless registered. Providing temporary help services is excluded from the definition.

Fees are from 15 CSR 30-130.030; the Secretary of State's PEO page lists the same application fees. Applicants file an audit no older than 13 months, renew within 180 days after fiscal year end, and keep positive working capital or post security equal to the deficiency plus $100,000. Penalties for knowingly operating unregistered include denial or revocation and an administrative penalty of up to $1,000 per material violation (§ 285.750).

A separate unemployment rule, RSMo 288.032, makes clients of an employee leasing firm jointly liable for unemployment contributions on leased workers unless the lessor posts a bond or other security of at least $100,000. It does not apply to private employment agencies that provide their own employees on a temporary help basis and pay contributions as the employer.

Employer accounts and the temp reassignment rule

• Workers' compensation. Required at five or more employees, or one or more in construction, counting family members (RSMo 287.030). A staffing firm reaches five quickly. Knowingly failing to insure is a class A misdemeanor plus a penalty of up to three times the annual premium or $50,000, whichever is greater, and a repeat offense is a class E felony (§ 287.128). See staffing agency insurance requirements.
• Unemployment insurance. Through the Division of Employment Security. Liability starts at $1,500 in wages in a quarter or one worker in 20 weeks (§ 288.032), and the division asks for notice within 30 days of becoming liable.
• Temp reassignment. Under RSMo 288.050, "A temporary employee of a temporary help firm will be deemed to have voluntarily quit employment if the employee does not contact the temporary help firm for reassignment prior to filing for benefits," but only if the worker was advised of the obligation and that benefits may be denied. Put a signed notice in every onboarding packet.
• Entity and tax registration. Foreign corporations need a certificate of authority from the Secretary of State, fictitious names are registered there too, and employers register for withholding with the Department of Revenue.
• E-Verify. Missouri's E-Verify law changed in 2026; see E-Verify requirements in Missouri.

I found no Missouri farm labor contractor, talent agency or day labor statute as of October 2026. If you also place across the state line, compare Illinois, which licenses fee-charging agencies and registers day and temporary labor agencies.

When a client asks for your Missouri license number

Vendor portals and procurement questionnaires often carry a state agency license field for every state. For a Missouri staffing or search firm outside health care, the accurate answer is that no such license has existed since 1999. Offer what does exist instead: your Secretary of State charter or certificate of authority number, your Division of Employment Security account number, a workers' compensation certificate, and, where it applies, your DHSS supplemental health care services agency registration or your PEO registration. Cite the 1999 repeal of chapter 289 so the reviewer can check it. That usually closes the question in one reply.

A Missouri checklist

MISSOURI CHECK — [date] — owner: [name]

Model:
  [ ] Employer-paid direct hire or search: no state license
  [ ] Candidate-paid fees: no license; contract reviewed by counsel
  [ ] Temp/contract, we employ: employer accounts below
  [ ] Health care personnel to hospitals/LTC (incl. app): DHSS registration
  [ ] Co-employment of client workforce: SOS PEO registration (285.715)

If health care staffing:
  Registration $830 / renewal $700 per location        [ ]
  Back-wage escrow or letter of credit                 [ ]
  Conversion fees removed from all contracts           [ ]

Employer accounts:
  Workers' comp (5+ employees)                         [ ]
  DES account; reassignment notice signed (288.050)    [ ]
  DOR withholding; SOS registration                    [ ]
Next review: [date]