Romania is the sixth-largest source of posted workers into Belgium and one of the most construction-concentrated. Romanian nationals make up 10 percent of all posted workers in the Belgian construction sector, essentially level with Dutch, Portuguese, Ukrainian and Polish workers. If you run a Romanian construction firm working Belgian sites, presence registration is not a back-office formality, it is the thing inspectors check first.
Key takeaways
- Romanian firms posting to Belgium need an A1 certificate per worker, a Limosa declaration filed before work starts and a named liaison person.
- An A1 certificate does not replace the Limosa declaration: a Belgian inspector will ask for both.
- Treat every crew rotation as a compliance event: each new worker needs an A1 check, a Limosa entry and site registration before travelling.
- Check-in-at-Work applies every day on works on immovable property worth 500,000 euro or more, and covers entry and exit from 1 April 2027.
Where Romania sits in the Belgian market
Romanian companies filed for 10,548 posted persons into Belgium in 2023, 4.6 percent of the Limosa total, and account for around 3 percent of posting companies active in Belgian construction. Among posted workers specifically in Belgian construction, Romanian nationals number 6,121, or 10.0 percent of the total, placing Romania in the top five nationalities on Belgian building sites.
Unlike Poland or Slovakia, Romanian postings skew towards employed workers rather than self-employed status: posted Romanian self-employed persons in Belgian construction number only 701, against 6,121 posted workers. That means the employer obligations, rather than the self-employed formalities, are where your exposure sits.
The four things you must have
Work backwards from your mobilisation date, because two of these depend on third parties.
1. A1 certificates, applied for at Casa Naţională de Pensii Publice (CNPP) before departure, one per posted worker, covering the full planned period. They prove your people stay in the Romanian social security system rather than becoming liable for Belgian contributions. See what Belgian inspectors check on an A1. 2. Check-in-at-Work access, if Check-in-at-Work will apply. Without a Belgian company number (CBE) or portal access you can still register presence by scanning the QR code on the LIMOSA-1 in the mobile service, but only to register, not to consult or cancel. Full access needs a CBE number and secure portal access, which take time to arrange, so start early. 3. The Limosa declaration, filed at limosa.be before the first day of work. It produces a LIMOSA-1 receipt each worker must be able to show to the Belgian client. Full detail in our Limosa guide. 4. A liaison person, whose identity and contact details you give to the Belgian Labour Inspectorate, and who can actually be reached about the posting.
Does the A1 replace the Limosa declaration?
No, and this is the most expensive misunderstanding in cross-border work.
The A1 answers which country’s social security system applies. Limosa answers whether Belgium knows your worker is on its territory. They are issued by different bodies for different purposes. An employer holding a valid A1 still has to file a Limosa declaration before the work starts, and an inspector will ask for both.
Crew rotation and the paperwork that does not follow
The characteristic Romanian posting pattern in Belgium is a sizeable crew on a longer programme, with rotation. Workers go home, others come out, and the site headcount stays roughly constant while the individuals change.
That is exactly the pattern Belgian inspections are built to catch. The declaration names individuals. So does the A1. So does the daily site registration. When a rotation happens and only the internal roster is updated, the three records drift apart, and an inspector comparing the people on site against the declared list finds a discrepancy within minutes.
Treat every rotation as a compliance event, not a scheduling one: new worker means a new A1 check, a new Limosa entry and site registration under their own identity, arranged before they travel rather than in the week after they arrive. The most common finding is not an undeclared company, it is a declared company with an undeclared person on site.
When does Check-in-at-Work apply?
Registration is mandatory for works on immovable property, excluding cleaning, where the total value of the works reaches 500,000 euro excluding VAT. The threshold applies whether that value is reached at the start of the works or during them, and it attaches to the works as a whole, not to your own contract value. The delivery of ready-mixed concrete and certain meat-sector activities are covered too; for the meat sector no minimum amount applies.
Three points that catch foreign contractors:
- It is daily. Registration must happen before the person begins work, every working day, for every person on site. It is not a one-off enrolment.
- Responsibility is shared. It lies both with the party sending the worker and the party doing the work, and the two must agree who registers and verify it happened. Assuming the main contractor covers you is not a defence.
- “Works on immovable property” is broad, reaching well beyond new-build into renovation, fit-out, technical installation and groundworks.
From 1 April 2027, a Programme Law adopted on 30 May 2026 extends the obligation to registering both entry and exit, for works on immovable property and for the supply of ready-mixed concrete, which is already in scope today. Sign-in sheets will not carry you past that date.
The differences between the systems are set out in Limosa, Dimona or Check-in-at-Work.
What it costs to get wrong
Failing to file a Limosa declaration is a level 4 offence, the heaviest category in the Belgian Social Criminal Code, carrying the possibility of imprisonment alongside financial penalties.
Fines rose on 1 February 2026, when the Act of 19 December 2025 raised the multiplier applied to social criminal fines from 8 to 10. For some infringements the amount is multiplied by the number of workers involved, up to a maximum of 100, which is what turns one administrative gap on a ten-person crew into a serious figure.
There is a commercial cost too. Your Belgian client is exposed through joint and several liability for your workers’ wages, and through the withholding obligation: where a contractor has social or tax debts, the client must withhold 35 percent of each invoice excluding VAT for social security debts and 15 percent for tax debts, checked at checkinhoudingsplicht.be. Since 30 October 2026, clients in construction and cleaning also withhold 15 percent where the contractor has unpaid self-employed social contributions. A subcontractor who creates that problem does not get invited back. Our guide for main contractors explains the liability that lands on the main contractor.
Keeping the paperwork and the site in agreement
The hard part of cross-border work is not understanding the rules. It is keeping the file in your home office and the reality on a Belgian site aligned, week after week, as crews rotate and programmes move.
Two habits do most of the work. Treat every crew change as a compliance event: a new person means a new A1 check, a new Limosa entry and site registration under their own identity, arranged before they travel. And capture presence digitally at the moment someone arrives, tied to the person and the project, so the site record matches your declarations by default and you can produce a specific past day on request without reconstructing it.
Suivo’s check-in-at-work is used on Belgian sites where several subcontractors work side by side, and runs on the same workforce management platform as time tracking, so the data you capture for compliance also feeds hours and project costing instead of sitting in a separate system.
See how B&R Bouwgroep manages registration across Belgian sites.
A note on language
Belgian inspections and official correspondence are in Dutch, French or German, depending on the region, not Romanian. Most Romanian construction postings are to Flemish sites, so make sure your named liaison person can deal with Dutch, or appoint a Belgian representative who can.
The same framework applies to crews from any country, and our companion guide for foreign employers walks through all of it.
Frequently asked questions
What does a Romanian company need to post workers to Belgium?
You need an A1 certificate for each posted worker from CNPP before departure, a Limosa declaration filed before the first day of work, and a liaison person whose details are passed to the Belgian social inspection. On sites that fall under Check-in-at-Work, each person must also be registered every working day.
Does an A1 certificate replace the Limosa declaration?
No. The A1 shows which country’s social security system applies, while Limosa tells Belgium your worker is on its territory. Different bodies issue them for different purposes, and a Belgian inspector will ask to see both.
How should you handle crew rotation on a Belgian site?
Treat every rotation as a compliance event, not just a scheduling change. The Limosa declaration, the A1 and the daily site registration all name individual workers, so each new worker needs an A1 check, a Limosa entry and site registration under their own identity, arranged before they travel.
What happens if a foreign contractor does not file a Limosa declaration?
Failing to file a Limosa declaration is a level 4 offence, the heaviest category in the Belgian Social Criminal Code, with possible imprisonment as well as fines. For some infringements the fine is multiplied by the number of workers involved, up to a maximum of 100.
Book a free demo
If you are bringing Romanian crews onto Belgian sites and want presence registration that satisfies an inspector without slowing your work down, we will show you how it runs day to day. Book a free demo.
