Construction is the sector where time registration is a legal obligation before it is a payroll tool, and the obligation changes on 1 April 2027.
The two regimes, and which one applies to you
Check in at Work (CIAW) is the current regime for works in immovable state. Registration is daily and happens before the person starts work. The threshold is EUR 500,000 excluding VAT for works started after 29 February 2016, and EUR 800,000 for works started between 1 April 2014 and 29 February 2016.
Check in and out at work (CIAO) replaces it for those works from 1 April 2027, under the Programmawet of 30 May 2026, articles 124 to 131. It adds a mandatory out registration, prohibits pre-registration, and must be performed by the worker in real time. The EUR 500,000 threshold is unchanged.
They are different regimes with different dates. The EUR 30,000 and EUR 5,000 figures that circulate alongside them belong to the separate cleaning regime, which was never part of CIAW. Both are set out on the RSZ Check in at Work page, verified 10 August 2026.
From that date, attendance on works in immovable state worth EUR 500,000 excluding VAT or more moves from Check in at Work to Check in and out at work: registration becomes in and out, in real time, performed by the worker. The practice most sites run today, a supervisor signing in the crew from a list at the start of the day, stops being compliant. That single change is the reason to look at this now rather than in March 2027.
Key takeaways
- From 1 April 2027, qualifying sites move to Check in and out at work: in and out, real time, by the worker. Pre-registration is prohibited.
- Every worker on a site in scope needs their own means of registering, including subcontractors you do not employ.
- Scope is decided per site by the value of the works, so one company can have sites in and out of scope simultaneously.
What exactly changes on 1 April 2027?
| Now | From 1 April 2027 | |
|---|---|---|
| What is registered | Presence | In and out |
| Timing | Before work starts | Real time |
| Who performs it | Employer, contractor or worker | The worker |
| Pre-registration | Permitted | Prohibited |
| Threshold | EUR 500,000 excl. VAT | Unchanged |
Red marks what changes for a site in scope. Source: Programmawet of 30 May 2026, articles 124 to 131, and the RSZ.
The legal basis is the Programmawet of 30 May 2026. Worth being precise about the date, because it is widely reported wrongly: the law set an outside date of “at the latest from 1 January 2027” and left the exact date to Royal Decree, and the RSZ then fixed 1 April 2027. It moved back, not forward.
Cleaning is a separate regime and has had its own in, out and rest-break duty since 1 September 2024, following the works-declaration thresholds rather than the construction ones.
Why does “by the worker” cause the most disruption?
Because it removes the workaround almost every site depends on.
Registering a crew centrally is administratively sensible and satisfies a pre-registration duty. Real-time registration performed by the worker means each person has to do it themselves, which turns registration from an office task into a site design question: where is the reading point, how long is the queue at 07:00, and what happens when someone forgets.
Two practical consequences:
- Reader placement becomes a compliance decision. A reader that adds ninety seconds to everyone’s morning is a reader people route around, and the route around it is non-compliant.
- Subcontractors need their own means of registering. You cannot issue company phones to a firm on site for three weeks, and badges for a short subcontract are rarely proportionate. QR or NFC points that their own workers scan are usually the answer. We have covered the liability side in registering subcontractors and third parties.
How do you register a crew that arrives together?
Throughput, not features. Thirty people arriving in a five-minute window at ten seconds a scan is a five-minute queue at the gate in February.
What works on real sites:
- Badge or terminal at the permanent depot, where the crew starts.
- QR or NFC points on the site itself : a few euros each, no power, no network, deployable in minutes and removable at handover.
- The app for supervisors and technicians who move between sites during the day.
- Offline buffering everywhere. Sites lose signal. A method that blocks the worker produces a paper list, and the paper list becomes the record.
Permanent hardware at a location chosen for a project rather than for the business is the recurring mistake. A powered reader at a yard gate is a real cost and it does not move with you.
What else does construction registration have to carry?
Hours in this sector are not only a payroll input.
Site or project, because hours are a costing input and the allocation has to be captured at the moment rather than reconstructed on Friday. Distance context, because a mobility allowance in construction depends on travel to site, and its value comes from the applicable joint committee agreement rather than from a national figure. Employer attribution, so subcontracted hours are visible as a separate line rather than folded into your own labour totals.
And critically: the statutory registration and the payroll registration should be one action. Two systems means two chances to disagree, and the version an inspector sees should not be a reconstruction assembled afterwards.
Which sites are actually in scope?
Scope is decided per site, by the value of the works there, EUR 500,000 excluding VAT for works started after 29 February 2016, and sites have to be declared in the works declaration.
So a contractor can be running one site in scope and three that are not, with different obligations on each, at the same time. Checking the threshold per site rather than assuming a company-wide answer is part of contract administration, not a system setting.
Frequently asked questions
What replaces Check in at Work in 2027?
Check in and out at work, from 1 April 2027, for works in immovable state worth EUR 500,000 excluding VAT or more. Registration becomes in and out, in real time, performed by the worker, and pre-registration is prohibited. Cleaning has run a separate in-and-out regime since 1 September 2024.
Can a site manager still register the crew?
Not on sites in scope, from 1 April 2027. Registration has to be real time and performed by the worker themselves. That means every person on the site, including subcontracted workers, needs their own means of registering, which is a site design question rather than a software setting.
How do you register subcontractors on a construction site?
QR or NFC points that their own workers scan with their own phones are usually the most proportionate answer for short subcontracts. Nothing to issue, nothing to install, and the record lands in your site register alongside your own staff, which is what an inspection asks for.
Does time registration work on a site with no mobile signal?
It should. The registration must be captured locally and synced when the connection returns, timestamped at the moment of the action rather than the upload. Test it in flight mode rather than accepting the assurance. A method that blocks the worker produces a paper list.
What this does not solve
Registration does not make a subcontractor compliant. It evidences attendance and says nothing about their own declarations, employment obligations or insurance.
It does not decide what a mobility allowance or an overtime hour is worth either. Those come from the applicable joint committee agreement, and they differ between committees, which is why a contractor with several committees cannot assume one rule set.
And it does not tell you whether a site is in scope. That follows from the value of the works and the declaration, and it is a question for your contract administration.
Suivo registers by badge, terminal, app, QR, NFC and in-vehicle unit including offline, keeps employer attribution per worker, and reports Check in at Work and Check in and out at work directly to the RSZ. It is not a payroll engine and does not calculate wages.
Next step: the construction industry overview sets out how site registration, crews and costing fit together.
Related: The 2027 CIAO change · Time registration in construction
