There are two routes for non-EU workers on a Belgian site. A Belgian employer that hires a non-EU worker for more than 90 days applies for a gecombineerde vergunning (single permit). A company established in the EEA or Switzerland that posts its own non-EU staff to Belgium usually needs no permit under the Vander Elst exemption, but only if strict conditions are met and a Limosa declaration is filed first. In both routes, the worker still has to register on sites that fall under Checkinatwork.
That daily registration is where Suivo helps: the Check in at Work app is built for sites with many third parties, including subcontractors and foreign workers.
Two different routes: hiring a non-EU worker vs posting non-EU staff from an EU company
The route depends on who employs the worker, not on where the worker comes from.
| Situation | Route | Permit needed? | Social security | Limosa |
|---|---|---|---|---|
| Belgian company hires a non-EU worker, more than 90 days | Single permit | Yes, single permit | Belgian (Dimona and DmfA) | No |
| Belgian company hires a non-EU worker, 90 days or less | Work card | Yes, work card | Belgian | No |
| Company established in the EEA or Switzerland posts its own non-EU worker | Vander Elst exemption | No, if all conditions are met | Sending state, with an A1 | Yes, before the start |
| Non-EU company posts its own worker directly | Permit route via a Belgian representative | Yes, unless an exemption applies | Home state if a bilateral agreement applies | Yes, before the start |
| Ukrainian with temporary protection, hired in Flanders | Exempt residence category | No | As for any Belgian hire (Dimona) | No |
Two examples:
- A Polish subcontractor sends a Ukrainian welder it employs in Poland. That is a posting. The Vander Elst conditions apply, not the single permit.
- A Brazilian company sends a worker directly. The Belgium-Brazil social security agreement can in principle keep the worker under Brazilian social security, within the agreement’s posting limits. But the Vander Elst exemption covers only EEA and Swiss employers, so a work authorisation is still needed unless another exemption applies.
What is the single permit (gecombineerde vergunning), and who applies?
The single permit is one permit for both work and residence. According to the Immigration Office (DVZ), it applies to non-EEA and non-Swiss nationals who will live and work in Belgium for more than 90 days. Work of up to 90 days still uses the work card (arbeidskaart) procedure.
Who applies. According to the Working in Belgium one-stop counter:
- only an employer established in Belgium, or a natural person with main residence in Belgium acting for the employer, can apply;
- a foreign employer can apply only through such a Belgian representative, after registering with the Crossroads Bank for Enterprises (KBO);
- the employer gives the worker’s INSZ or temporary INSZ, which it can request through belgianIDpro if the worker has none.
Timing.
- If the worker has no Belgian residence permit yet, the application is filed before the worker is in Belgium, with some exceptions.
- The worker may start only when both the work and the residence parts are approved.
- Once the region declares the file admissible, it has 15 days to send it to DVZ. The region and DVZ then have 4 months to decide. If no negative decision follows in time, the permit is deemed granted.
- An incomplete file gets 15 days to be completed.
Annex 46. When DVZ grants the permit, the decision takes the form of annex 46 (bijlage 46), or annex 47, the certificate DVZ issues when no negative decision was taken within the decision period. The worker registers at the municipality within 8 working days of arriving in Belgium with a passport, the annex 46 or 47 and the work and residence decisions.
What is a Vander Elst posting, and what are the conditions?
The Vander Elst exemption is named after a ruling of the EU Court of Justice. According to the Flemish government, no work authorisation is needed for a non-EEA/non-Swiss worker employed by a company established in the EEA or Switzerland who comes to Belgium temporarily to provide services, provided the Limosa declaration is fully in order and the worker:
1. resides in that EEA state or Switzerland with a right of residence or a residence permit of more than 3 months;
2. works legally there, with a permit valid at least for the duration of the work in Belgium;
3. has a regular employment contract;
4. has a passport and residence permit valid at least as long as the service, so they can return.
Social security. Within the EEA, the worker stays under the sending state’s system if the posting is expected to last no more than 24 months and the other posting conditions are met, according to the RSZ. The proof is the A1 certificate. See our guide to the A1 certificate.
Residence still applies. The exemption covers the work permit, not residence. For postings under 90 days, the worker needs an arrival declaration (annex 3) at the municipality, unless exempt, for example when staying in a hotel. For more than 90 days, the worker requests an A card at the municipality.
Short activities are not a shortcut. Flanders exempts a closed list of short business activities, such as meetings, fairs and audits, and some Limosa-exempt tasks. None of these covers construction site work. On a site, rely on the Vander Elst route or a permit. See Limosa exemptions for details.
Where Flanders, Wallonia and Brussels differ
Work authorisation is a regional matter. You apply in the region where the worker will work: Flanders, Wallonia (outside the German-speaking area), Brussels-Capital or the German-speaking Community. The residence part is always decided by the federal DVZ.
Flanders, as of September 2026, according to the Flemish government:
- Fee: since 1 September 2026, a fee of EUR 180 per single-permit application, first or renewal. Pay it within 15 days or the file is closed. The processing period starts only after payment. It comes on top of the federal residence fee.
- Application window: a first application at least 1 month and at most 6 months before the start. No retroactive authorisation. A renewal with the same employer for the same job: at least 2 and at most 6 months before expiry.
- Waiting times before the work part is examined (indication, updated monthly): 2 weeks for highly qualified workers, and 4 weeks for first applications in the medium-skilled and “other” categories. The DVZ residence part then takes about 15 to 16 weeks for a first application.
- Digital: since 1 May 2026, work-card applications (90 days or less, and cross-border workers) run through the one-stop counter, and the employer receives a digital authorisation that serves as work card and work permit. Au pairs are the exception.
Brussels: according to the Flemish integration agency AGII, Brussels applies the same Vander Elst conditions as Flanders.
Wallonia and the German-speaking Community: check waiting times, fees and conditions with the regional service before you plan a start date. This article uses the Flemish figures.
What Limosa and Checkinatwork still require
Limosa. Before work starts, the foreign employer must declare every worker who is not under Belgian social security and comes to work temporarily in Belgium, according to Limosa. This applies worldwide, not only to EU employers. Self-employed people must declare in construction, meat and cleaning. Read our Limosa declaration guide.
The Belgian client’s duty. Before work starts, the Belgian client must check the L1 certificate, directly or through the subcontracting chain. If the L1 cannot be shown, the client must report “missing L1” to the RSZ electronically before work starts.
Checkinatwork. On sites of EUR 500,000 or more, posted workers are registered daily like everyone else. According to the RSZ:
- a posted worker can register, or be registered, by scanning the QR code on the Limosa L1, with no secured access;
- that route only registers: it cannot view or cancel;
- for full access, a foreign contractor needs a Belgian company number and a main access manager with a Belgian national register or BIS number. Registration with the Crossroads Bank for Enterprises and obtaining a digital key take time, so start early.
From 1 April 2027, according to the RSZ, construction attendance moves to Check in and out at work, with registration at arrival and departure. The RSZ says more details will follow. Our hub for foreign employers working in Belgium tracks the changes.
Documents to keep on site
Social inspectors check posted third-country nationals’ passports, residence and work documents, the Limosa certificate and the A1. Keep this set ready for every non-EU worker:
Posted worker (Vander Elst route)
- Passport, valid for the whole service
- Residence permit of the sending EEA state or Switzerland (more than 3 months)
- Work permit of the sending state, valid for the whole Belgian job
- Employment contract with the sending company
- Limosa L1 certificate
- A1 certificate
- Annex 3 (short stay) or A card (more than 90 days), where required
- Checkinatwork registration for each day on site
Worker hired with a single permit
- Passport and single permit (residence document)
- For work of 90 days or less: the work authorisation instead (a PDF in Flanders)
- Dimona declaration
- Checkinatwork registration for each day on site
Common mistakes that lead to fines
1. Treating “EU company” as “EU worker”. A Polish or Portuguese employer does not make its non-EU staff exempt. The Vander Elst conditions apply to each worker.
2. No Limosa before day one. The exemption depends on a Limosa declaration that is fully in order. A missing Limosa declaration is a level 4 offence. For offences from 1 February 2026, the administrative fine is EUR 3,000 to EUR 35,000 per worker.
3. The client does not check the L1. A Belgian client that fails to report a missing L1 commits a level 3 offence: EUR 1,000 to EUR 10,000 per worker (administrative).
4. Expired sending-state permits. If the worker’s residence or work permit in the sending state ends before the Belgian job, the exemption fails.
5. Mixing up temporary protection and posting. Ukrainians with temporary protection can work in Flanders without a work authorisation. That protection has been extended until 4 March 2028 (Council Implementing Decision (EU) 2026/1912 of 30 July 2026). But a Ukrainian posted by a Polish firm is a posted worker: the Vander Elst conditions apply, as for any other non-EU worker. In a 2022 article on its inspections, FOD WASO reported many invalid postings of Ukrainians through Polish firms, mainly in transport and construction.
6. Using short-activity exemptions for site work. They do not cover construction.
7. Starting before the single permit is granted. The worker may start only when both the work and residence parts are approved.
8. Letting a posting run past the Limosa end date. File a new declaration before the declared period ends.
Fines are multiplied by the number of workers. On a crew of eight, the risk adds up quickly. Before you pay a foreign subcontractor, also check its withholding status (inhoudingsplicht). For all 2027 dates, see the compliance calendar for foreign contractors.
Frequently asked questions
What are the rules for foreign workers in Belgium?
EU, EEA and Swiss nationals can work freely. Non-EU workers need a work authorisation, usually the single permit for more than 90 days, unless an exemption applies, such as the Vander Elst exemption for staff posted by a company established in the EEA or Switzerland. Posted workers also need a Limosa declaration before they start.
What is a gecombineerde vergunning?
The gecombineerde vergunning (single permit) is one permit that covers both the right to work and the right to stay for non-EU nationals who will work in Belgium for more than 90 days. The employer applies through the regional one-stop counter, and the region and the federal Immigration Office decide.
What is annex 46 of the single permit?
Annex 46 (bijlage 46) is the decision of the Immigration Office (DVZ) granting the single permit, or annex 47, the certificate DVZ issues when no negative decision was taken within the decision period. With it, the worker registers at the municipality within 8 working days of arrival in Belgium, or of receiving it if already in Belgium.
Does a posted non-EU worker need a single permit?
Not if the Vander Elst conditions are met: the worker is employed by a company established in the EEA or Switzerland, lives and works there legally, has a regular contract and valid documents, and the Limosa declaration is in order. Otherwise a work authorisation is needed.
Can a foreign company apply for a single permit?
Only through a representative established in Belgium, after registering with the Crossroads Bank for Enterprises (KBO). Only employers established in Belgium, or a natural person with main residence in Belgium acting for the employer, can file.
Keep every worker on your site accounted for
Permits and Limosa decide who may work. Daily registration proves who did. Suivo registers your own crews, your subcontractors and their foreign workers on the same site record.
