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CIaO obligation: attendance registration in cleaning, construction, and beyond


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CIaO (Check In and Out at Work) is the online service of the RSZ that allows every person working in a target sector to register their arrival, breaks, and departure in real time. For cleaning activities on real estate for third parties, CIaO has been mandatory since September 1, 2024. From April 1, 2027, the obligation will extend to work on real estate valued at 500,000 euros and to the supply of ready-mixed concrete.

The big difference with the old Checkinatwork: registration can no longer be done in advance by the employer. The employee checks in themselves, checks out themselves, at the exact location, at the exact moment. That may seem like a detail. In practice, it changes your entire field and planning process.

On this page, we answer the questions we most often receive from cleaning companies, contractors, facility service providers, and their social secretariats.

What is CIaO exactly?


CIaO stands for Check In and Out at Work. It is the electronic attendance registration of the National Social Security Office in which employees, self-employed individuals, temporary workers, and interns report the start, end, and breaks of their activities. The responsibility lies both with the entity that employs someone and with the person performing the work.

The legislator's objective is threefold: to combat black labor and social dumping, to provide inspection services with an accurate picture of who is present at any time, and to protect fair competition between companies that do register correctly and those that do not.

Legal basis

a. Cleaning: Program law of December 26, 2022, title 4, chapter 1, articles 22 to 48 and chapter 2, article 49 (article 30bis, §9 of the law of June 27, 1969), further elaborated in the law of November 5, 2023.
b. Extension to construction sites and concrete: Program law of May 30, 2026, title 6, chapter 1, articles 124 to 131, published in the Belgian Official Gazette of June 1, 2026. Article 130 amends article 132/1 of the Social Penal Code.

What is the difference between CIaO and Checkinatwork (CAW)?


Checkinatwork has existed since April 2014 and requires one registration per day: the check-in, before the start of the work. CIaO requires a complete check-in and check-out, including breaks, in real time. Today, both systems run alongside each other. From April 1, 2027, the attendance registration for work in immovable property will move from CAW to CIaO.


Important for cleaning companies: anyone performing cleaning or maintenance activities listed on a Declaration of Works registers via CIaO and not via CAW. Registrations in CAW are not transferred to CIaO.


CAW

CIaO

Registration

Only IN

IN, OUT, and breaks

Moment

Before the start of the work

Real time, at each start and end

Who registers

May be done by employer or contractor

happen

The person themselves, at the workplace

Check in in advance

Allowed

Prohibited

Sectors today

Working in real estate from 500,000

euros, meat sector (without threshold)

Cleaning activities on real

estate for third parties

From April 1, 2027

No longer usable for work in

real estate

Working in real estate from 500,000

euros and delivery of ready-mixed concrete

Who is subject to the CIaO obligation in the cleaning sector?


You fall under CIaO if it concerns activities aimed at cleaning a property on behalf of a third party, for which a Declaration of Work is required according to article 30bis. Both your own employees and subcontractors, freelancers, temporary workers, and interns must register, regardless of their position.

Specifically: cleaning of offices, hospitals, schools, shops, industrial sites, common areas of buildings, windows, facades, and technical installations, carried out at a client.

About the threshold amounts. The obligation is related to the declaration obligation of the main contract. In the absence of an executive royal decree, the usual 30bis conditions apply: declaration is required for work above 30,000 euros without subcontractor, above 5,000 euros with one subcontractor, and also below 5,000 euros as soon as you work with two or more subcontractors. It is the value of the main contract, cleaning and non-cleaning combined, that determines whether CIaO applies to your performance. If you work in subcontracting, then the contract value of your own assignment is not decisive.

Practical consequence: many cleaning assignments for third parties fall within the scope, including small ones. In case of doubt, it is better to register than not.

What changes on April 1, 2027, for the construction sector?


From April 1, 2027, every natural person at a temporary or mobile construction site from 500,000 euros excluding VAT must register in and out via CIaO. Three things fundamentally change: there will be a mandatory check-out, registration may only be done in real time at the exact location, and the employer may no longer register on behalf of the employee in advance.

What does that mean operationally?

  • Your badge-at-the-gate routine is no longer sufficient if, in practice, registrations are entered in bulk by a site manager or planner.
  • Everyone on site counts, not only construction workers: technicians, inspectors, suppliers carrying out work, team leaders and self-employed subcontractors.
  • Responsibility applies throughout the entire contracting chain. The contractor responsible for the Declaration of Works must ensure that a registration method is available. Every contractor and subcontractor in the chain must also ensure that registrations are completed correctly.
  • The obligation goes beyond the “construction sector”. It applies to any sector where substantial works involving immovable property are carried out: steel construction, timber construction, electrical works, HVAC, roofing, demolition, concrete works and industrial installation.
  • The delivery of ready-mixed concrete is explicitly included within the scope.

From that date, you can no longer do the attendance registration for work in immovable property in Checkinatwork.

Which other sectors are facing in and out registration?


In addition to cleaning and construction, in and out registration will also be introduced in the moving sector, no later than January 1.2027.De The meat sector already has a registration obligation via Checkinatwork without a threshold amount. Sector federations expect that the logic will further expand to include cold chain logistics and waste processing.

The direction is clear. What started as a measure for large construction sites is gradually becoming the standard for every service on location at a client. Therefore, anyone choosing a registration solution today should not opt for a solution that only fits today.

What data do you need to register?


For each person and each workplace, you must register at least:

1. The identification of the person (INSZ or national register number, or Limosa number for foreign workers).
2. The identification of the employer or the self-employed.
3. The workplace, linked to the Declaration of Works.
4. The time of the IN-registration at the start.
5. The beginning and the end of each break.
6. The time of the OUT-registration at the end of the activity.

Registration can be done via the RSZ portal, the mobile application of the RSZ, or through a web service of your own system. If your employee registers via a linked system, such as an app or a badge, the data is automatically sent to the social security database, and they do not have to do anything twice.

What are the penalties if you do not register?


Non-compliance is punished under the Social Penal Code with a sanction of level 1 or level 3. Level 1 means an administrative fine in the range of 80 to 800 euros, usually for the employee who does not register while they were provided with the means to do so. Level 3 affects the employer or their appointee and can lead to an administrative fine of 800 to 8,000 euros or a criminal fine of 1,600 to 16,000 euros.

Two details make the difference between a fine and a problem:

The fine is multiplied by the number of involved persons. A team of ten unregistered employees is not a single fine, but ten times the same fine.
In the case of a work accident or health damage, the sanction can rise to level 4.

The grace period in the cleaning sector ended on April 30, 2025. Since May 1, 2025, sanctions are effectively being imposed.

Amounts in the Social Penal Code are subject to indexing and decimals. Consult the current amounts with the RSZ or your social secretariat.

Who is responsible: the employer, the main contractor, or the employee?


The responsibility is shared. The employer, main contractor, or subcontractor who employs someone must provide a working registration tool and ensure correct registration. The person performing the work must register themselves in real time. If the employer has fulfilled their obligations, they are not liable for the forgetfulness, error, or refusal of an employee.

That last sentence is your most important protection mechanism. It only works if you can demonstrate that you have provided the means, that you have informed your people, and that you follow up on who does not register. A solution that makes missing registrations visible is therefore not a luxury but evidence.

How should you prepare? A 7-step checklist

Map out your contracts

Which assignments fall under the Declaration of Works? Which projects exceed 500,000 euros?

Determine which system applies for each assignment

CIaO, CAW, or from April 2027 CIaO for both.

Check the identification details

Check all your employees and subcontractors, including Limosa for foreign workers.

Choose a registration method that works in real time and on site

A tool that works in the hands of the employee themselves

Inform your employees

Inform them in their own language, including regarding the break registration. This is a communication project at least as much
as an IT project.

Make agreements with your chain

From subcontractors and temp agencies, in writing.

Organize daily
follow-up

Follow up on missing registrations so that you correct before the inspection comes.


And then the elephant in the room: who is going to do this every day?

This is where things start to get difficult. The legislation is clear about the required outcome and completely indifferent to your operational reality. A cleaning crew visiting six locations in one day has to register twelve times, not including breaks. A construction site with sixteen subcontractors creates sixteen chains of responsibility. And the schedule can change before your coffee even gets cold.

Companies that try to solve this manually through the RSZ portal end up at the same point: someone in the office filling in gaps afterwards. That is exactly what the new rules want to exclude. 

person using laptop on white wooden table

How MyVIRO solves the CIaO obligation


MyVIRO is an Employee Self Service platform where your employee checks in and out at the workplace themselves, from their own device. The registration starts with the person and the moment, which is exactly what the legislator imposes from 2027. What is today a compliance obligation becomes simply the way your people start and end their day in MyVIRO.

What that concretely means:

  • Real-time check-in and check-out, including breaks, by the employee themselves at the correct location.
  • One method for all your sectors. Cleaning today, recruiting from April 2027, moving, maintenance: the same app, the same habit, no second system.
  • Visibility on missing registrations, so you can correct and demonstrate that you have met your obligations.
  • Multilingual, because your teams are too.
  • More than just CIaO. MyVIRO is primarily an ESS tool: schedules, documents, absences, and communication with your employees are all in the same environment. You are not buying a fine avoider, you are getting one.
  • White label available for social secretariats and service providers who want to serve their clients under their own brand.

    The question is not whether you will register. The question is whether you will have a second administrative layer in 2027, or just an app where your people are already tapping every morning.

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Frequently asked questions about CIaO


Since September 1, 2024. The online service has been available since January 1, 2024, and there was a transition period without sanctions until April 30, 2025. Since May 1, 2025, the obligation is fully in effect and violations are sanctioned.

CIaO follows the reporting obligation of the main contract. Since this reporting obligation applies from low amounts as soon as subcontractors are involved, the majority of cleaning assignments for third parties fall within the scope. Assess per main contract, not per performance.

Yes. Employees, freelancers, subcontractors, temporary workers, and interns all register, regardless of their role. Even those who are only present briefly.


Yes. CIaO explicitly requires the registration of rest breaks, in addition to the start and end of the activity. This is one of the main differences with Checkinatwork.


No. Registration must be done by the individual themselves, in real time, at the workplace. For work in immovable property, advance registration by the employer is explicitly prohibited from April 1, 2027.


From that date, you can no longer register attendance for work in immovable property via Checkinatwork. Those registrations will move to CIaO. Checkinatwork will continue to exist for the application areas that do not transition, such as the meat sector.


A sanction of level 1 or level 3 from the Social Penal Code, with administrative fines up to 8,000 euros or criminal fines up to 16,000 euros, multiplied by the number of persons involved. In the case of a workplace accident, this can escalate to level 4.

Both are allowed. You can use the RSZ portal or the RSZ app, or your own system that communicates with the social security database via web service.
In that latter case, your employee simply registers in your app and the flow happens automatically.

Probably yes. The obligation is tied to the concept of work in immovable property, not to your joint committee. Metal construction, timber construction, electrical engineering, HVAC, and roofing work fall under this as soon as the site reaches the threshold of 500,000 euros.


Yes. MyVIRO is built around self-check-in and check-out by the employee and is already being used today to comply with CIaO. The same method covers the expansion of April 2027, without a second system.


PULSO app screenshot

Start today.

Mandatory time registration will not wait.


Belgian legislation is evolving towards mandatory time registration for all employees.
Companies that invest in the right solution now can avoid the 2026 implementation rush
and will be better prepared than those that wait. MyVIRO is available today and can
be operational tomorrow.
No credit card. No commitments. Your data remains in Belgium.


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Ready to turn Check In/Out into a complete employee app?


MyVIRO helps you start with digital registration and grow towards employee self-service, back-office control and further automated processing.

No standalone time clock. No extra Excel files. No administration that only gets corrected afterwards.


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Sources


  • RSZ, Check In and Out at Work: socialsecurity.be
  • RSZ, Checkinatwork and the expansion from April 1, 2027: socialsecurity.be
  • RSZ, Frequently Asked Questions about Check In and Out at Work (pdf)
  • Program Law of December 26, 2022, title 4
  • Program Law of May 30, 2026, title 6, chapter 1, art. 124 to 131
  • Law of June 27, 1969, art. 30bis

Author: Jean-Philippe Delberghe at MyVIRO. Published on 08/09/2026. Last updated on 08/09/2026.

This page is an informative explanation and not legal advice. Legislation evolves. Consult the official information from the RSZ at socialsecurity.be or your social secretariat for your specific situation.