A practical Belgian decision guide to all CIAW carve-outs, sector thresholds, and edge cases, so you only register the workers you legally have to.
Belgian compliance teams burn hours every month registering attendance that the law never actually demands. The Check-in at Work (CIAW) obligation has a long list of exemptions hidden in sector-specific rules, threshold tables, and inspection circulars, and getting them wrong cuts both ways: register too little and you risk fines of up to €6,000 per worker per day; register too much and you waste payroll admin on people who never needed to be on the list. This guide walks through every CIAW exemption, sector threshold, and grey area, so you know exactly when to use a digital Check-in at Work solution and when you can safely skip it. We focus on the rules that matter most to contractors, cleaning companies, meat-processing plants, and the directors who sign off on their NSSO declarations.
Quick Navigation
- What CIAW actually is, and what “exempt” means in practice
- Exemptions by sector and threshold
- Worker-type exemptions (volunteers, self-employed, family workers)
- Location-based and project-based carve-outs
- Quick reference table: who is in, who is out
- How to document an exemption (so RSZ accepts it)
- Future changes, what 2027 will mean for exemptions
- Managing CIAW exemptions with Technology
- Frequently Asked Questions
What CIAW Actually Is, and What “Exempt” Means in Practice
Check-in at Work (Aanwezigheidsregistratie or CIAW) is the Belgian electronic attendance-registration obligation administered by the NSSO (RSZ). Every worker covered by the obligation must be registered before entering the worksite, and contractors in scope are jointly liable for their subcontractors’ declarations. The rules sit alongside the older Limosa declaration for posted workers and feed into the upcoming 2027 daily working-hours mandate.
“Exempt” does not mean “informal”. An exemption means the law does not require an electronic CIAW declaration for that specific worker on that specific site, but it almost always still requires you to keep some other form of evidence (a paper register, a Limosa A1, a Dimona declaration, or a Confederation-of-Construction badge). When in doubt, default to registration. Our CIAW FAQ walks through the most common misconceptions.
Why exemptions exist at all
The legislator deliberately carved out small jobs, low-risk sectors, and certain worker categories so that CIAW would not crush small contractors with paperwork. The thresholds (€500K, €30K, €5K) are reviewed regularly, most recently for the cleaning and meat sectors. Expect more adjustments as the 2027 EU working-time ruling is transposed.
Exemptions by Sector and Threshold
CIAW thresholds are sector-specific. Below the threshold, the electronic registration obligation does not apply, but record-keeping still does.
Construction (joint sub-committee 124)
- No subcontractor on site and total works value < €500,000 → CIAW not required.
- One subcontractor and works value ≤ €5,000 → CIAW not required.
- Two or more subcontractors on the same site → CIAW always required, regardless of value.
- Official reference: Confederation of Construction guidance.
Cleaning (joint sub-committee 121)
- Cleaning contracts below €30,000 (excl. VAT) → CIAW not required.
- Above €30,000 → CIAW + CIAO (entry and exit times) since 2025. See our overview of the Check-in and Out at Work expansion.
Meat processing (joint sub-committee 118.03 and 118.07)
- Activities below €5,000 → CIAW not required.
- Above €5,000 → full CIAW obligation applies.
Other sectors
Most other sectors (transport, utilities, manufacturing) fall outside CIAW entirely, though the 2027 daily working-time obligation will reach much further. Today, the focus stays on construction, cleaning and meat.
Worker-Type Exemptions
Even on a site that triggers CIAW, certain worker categories are excluded from the electronic declaration:
- Self-employed inspectors and consultants who do not perform construction activities themselves (architects, surveyors, safety coordinators visiting briefly), exempt, but their visit must usually be logged in the site logbook.
- Suppliers delivering materials without performing assembly or installation work, exempt during the delivery window only.
- Volunteers and family workers under specific legal definitions, exempt, but only if the relationship is documented in advance.
- Trainees and students under formal school agreements in some configurations, partially exempt depending on the contract type.
- Posted (foreign) workers with a valid Limosa A1, must be Limosa-declared, but Limosa does not replace CIAW. They are registered under both regimes when CIAW applies.
| ⚠️ Watch-out: The exemption for “brief deliveries” is one of the most-disputed at inspection. If your supplier helps unload, secures materials, or installs anything, they cross the line into “performing construction activities” and CIAW kicks in. |
Quick Reference Table, Who Is In, Who Is Out
| Worker / situation | Construction site > €500K | Cleaning contract > €30K | Meat plant > €5K | Documentation required |
| Direct employee of main contractor | ✅ Register | ✅ Register | ✅ Register | CIAW + Dimona |
| Direct employee of subcontractor | ✅ Register | ✅ Register | ✅ Register | CIAW + Dimona |
| Self-employed (active worker) | ✅ Register | ✅ Register | ✅ Register | CIAW + self-employed status |
| Self-employed (consulting only) | ❌ Exempt | ❌ Exempt | ❌ Exempt | Site logbook entry |
| Supplier (delivery only) | ❌ Exempt | ❌ Exempt | ❌ Exempt | Delivery note |
| Posted worker (EU/EEA) | ✅ Register | ✅ Register | ✅ Register | CIAW + Limosa A1 |
| Trainee (school agreement) | ⚠️ Conditional | ⚠️ Conditional | ⚠️ Conditional | Check contract type |
| Volunteer (legally defined) | ❌ Exempt | ❌ Exempt | ❌ Exempt | Volunteer agreement |
Conditional cases require legal review, when in doubt, register.
Location-Based and Project-Based Carve-Outs
Some carve-outs depend on where or how the work happens:
- Off-site prefabrication: Work performed in a permanent workshop (not on the customer’s premises) is generally outside CIAW. The moment those elements are installed on site, the on-site team becomes CIAW-relevant. Our construction industry overview shows how mixed off-site/on-site teams are typically handled.
- Maintenance under the threshold: Recurring small maintenance jobs (each under the construction value threshold) are exempt, but if the same contract bundles them above €500K cumulatively, the exemption falls away.
- Internal moves on a single private property: Works performed by an owner’s own staff on the owner’s own property, with no subcontractors, fall outside the construction CIAW scope.
- Public-works exceptions: Defence and intelligence-related sites have their own classified registration regimes; in those cases CIAW is replaced, not exempted.
How to Document an Exemption (So RSZ Accepts It)
NSSO inspectors do not assume an exemption, they audit for it. A defensible exemption file contains:
- The signed contract or purchase order showing total value under the threshold.
- A list of all workers and subcontractors on site, with status (employee / self-employed / supplier / consultant).
- For self-employed: a copy of their KBO / CBE registration.
- For posted workers: the Limosa A1 print-out.
- For volunteers and trainees: the formal agreement.
- A short note explaining which exemption applies and why.
You can keep all of this digitally inside your Time Registration platform, or, if you only need attendance for compliance, inside your Check-in at Work tool, so the file is one click away when an inspector arrives.
Future Changes, What 2027 Will Mean for Exemptions
The CIAW exemption landscape is going to shrink, not grow:
- January 2027 brings the EU-driven mandatory daily working-time obligation for all employers. Even CIAW-exempt sectors will need a daily working-hours record.
- Cleaning is widely expected to see the threshold lowered further in the 2026/2027 review window.
- Meat sector thresholds are under scrutiny after recent inspection campaigns.
- Chain-liability in construction is being tightened: even with valid exemptions, main contractors will increasingly need to prove they verified each subcontractor’s status. Our construction pillar tracks the legislative calendar.
Managing CIAW Exemptions with Technology
Compliance officers don’t need a bigger spreadsheet, they need one inspector-ready source of truth.
Suivo, a Belgian Workforce Management company with over 15 years of experience, offers a comprehensive Check-in at Work solution that handles both registrations and exemption files in one place. Their platform helps you:
- Decide per site whether CIAW applies, using a configurable threshold rule
- Capture each worker’s status (employee, self-employed, posted, supplier) at onboarding
- Attach Limosa A1s, KBO numbers and contracts as supporting evidence
- Synchronise registrations directly to NSSO with CIAW
- Roll exit times into the CIAO obligation for cleaning via Check-in and Out at Work
- Feed verified hours into payroll through SD Worx, Partena, Acerta and Odoo integrations
- Hand inspectors a single export covering every worker, site and exemption claim
- Manage chain-liability evidence across all subcontractors
Suivo’s IoT platform integrates seamlessly with existing payroll and ERP systems, helping companies like Hoogmartens and B&R Bouwgroep maintain compliance across hundreds of sites. Every registration is verified at the moment it happens, no backdating, no local edits, no disputed timestamps.
“We used to argue with inspectors about which workers were in scope. Now every status, every contract value and every Limosa is one click away. The exemption discussion takes minutes instead of half a day.”
– Compliance Officer, mid-size construction group in Limburg
Take Action Today
Don’t let an unclear exemption catch your team unprepared. Start by mapping your current sites against the thresholds, document the status of every worker on each site, and centralise the supporting paperwork so an inspector never has to wait.
For more information about Check-in at Work exemptions, contact Suivo at +32 3 375 70 30 or visit their Check-in at Work solution page to discover how their smart tools help Belgian companies decide, document and defend each CIAW exemption with confidence. You can also browse the Suivo product range or request a demo.
Download the Free CIAW Exemption Checklist
Want to navigate CIAW exemptions with more confidence? Our Compliance Checklist gives you a simple, practical overview to apply each exemption correctly, document it for inspection, and stay compliant under the 2027 changes.
Inside, you’ll find:
- The biggest pitfalls around CIAW thresholds today
- How Suivo helps you map workers, capture status and prove compliance
- Real-life success stories from Hoogmartens, Cegelec and B&R Bouwgroep
- Practical solutions for workforce, asset and fleet management
Frequently Asked Questions
Is a one-day site visit by a self-employed safety coordinator subject to CIAW?
No, as long as the coordinator performs only inspection or advisory work and does not carry out construction activities. They should still be logged in the site logbook, and proof of their self-employed status (KBO number) should be kept. Our CIAW FAQ covers more of these edge cases.
What happens if I rely on an exemption and an inspector disagrees?
The burden of proof sits with the employer. If your supporting documentation is incomplete, the inspector can re-classify the worker as CIAW-relevant and apply administrative fines starting at €300 per worker per day. A centralised Check-in at Work record keeps the proof inspection-ready.
Does the €500,000 construction threshold include VAT?
No, the threshold is calculated excluding VAT, based on the total value of the works on a single site under a single contractual relationship. For complex multi-phase contracts, see the construction industry overview.
My cleaning contract is exactly €30,000. Am I exempt?
No. The cleaning sector threshold is “above €30,000”, which is interpreted strictly. Contracts of exactly €30,000 fall outside the obligation, but any indexation, scope-creep or addendum that crosses the line triggers CIAW + CIAO from the moment of the change. See Check-in and Out at Work for the cleaning-specific entry/exit rules.
Do volunteers on a construction-related charity project trigger CIAW?
Only if they are paid or if their activity falls outside the legal definition of volunteering. True volunteers under a formal volunteer agreement are exempt, but the agreement must be on file. The construction industry overview explains how to handle mixed paid/volunteer teams.
Will the 2027 working-time mandate change CIAW exemptions?
The 2027 mandate runs in parallel: it requires a daily working-hours record for every employee, including those exempt from CIAW. Most companies will use a single Time Registration platform that handles both obligations, so the practical effect is that “exempt from CIAW” no longer means “no electronic record at all.”
