Question 1

Who has to check in and out?

Accepted Answer

In professional cleaning, the obligation applies to own employees, subcontractors and temporary workers, regardless of company size. In construction, registration currently applies on sites above the legal threshold; the NSSO is targeting 1 April 2027 for the full IN and OUT obligation, definitively confirmed by a Royal Decree.

Question 2

How do you know someone was really at the work location?

Accepted Answer

With every registration, a geofence confirms that the employee is at the stated location. The GPS privacy policy is configurable, so you register no more than necessary.

Question 3

Which certificate is used to sign the declarations?

Accepted Answer

Your own company's NSSO certificate. We store it encrypted and use it solely to sign your declarations.

Question 4

What happens if the NSSO rejects a declaration?

Accepted Answer

Every declaration is tracked until it is definitively accepted or rejected. In case of a rejection, you see in plain language what went wrong, so it can be corrected.

Question 5

Does the app also work for employees who don't speak Dutch?

Accepted Answer

Yes. The app is multilingual and works with a short PIN login, so checking in and out takes one tap in the employee's own language.

Question 6

Can a supervisor manage registrations directly?

Accepted Answer

Yes. In the web portal you can search and filter registrations, and also check people in and out directly, with roles and rights per manager.

Question 7

Does the obligation also apply to small cleaning companies?

Accepted Answer

Yes. In professional cleaning (joint committee 121) the obligation applies regardless of company size, including for subcontractors and temporary workers.

Question 8

Our teams work at many different locations each day. Is that supported?

Accepted Answer

Yes. Every location is set up as its own workplace with its own geofence. Employees check in and out at each location, and everything comes together in one overview.

Question 9

How do employees register when they clean in the evening or at night?

Accepted Answer

In the same way: with a short PIN login in the app, also outside office hours. The declaration is sent to the NSSO automatically within the legal deadline.

Question 10

What about cleaning in buildings with poor mobile coverage?

Accepted Answer

The registration is stored on the device and sent as soon as there is a connection again, so the check-in and check-out times stay correct.

Question 11

Do we have to follow up our subcontractors' registrations?

Accepted Answer

In cleaning, registrations for subcontractors and temporary workers are mandatory too. You see them in the same overview, so you know who was actually present.

Question 12

What changes from 1 September 2024?

Accepted Answer

Since 1 January 2024 an extended notification obligation applies to maintenance and cleaning works on buildings, regardless of the value of the works or the use of subcontractors. The NSSO launched the online service Check In and Out at Work for this; registering was already possible from January 2024, but the obligation itself only takes effect from 1 September 2024 (subject to two Royal Decrees still to be published).

Question 13

What does presence registration involve?

Accepted Answer

All natural persons at a workplace with maintenance or cleaning activities must register: employees, self-employed people, (sub)contractors, temporary workers, posted workers, apprentices and trainees. They check in at the start of their activities and out at the end, and also at the start and end of rest breaks. Employers and clients share the responsibility: they must inform staff, provide a registration system and ensure correct data transfer to the NSSO — but they may not register themselves or in advance on behalf of the person doing the work. When moving to another workplace, checking in and out has to be done again.

Question 14

For which works is registration mandatory?

Accepted Answer

For maintenance or cleaning activities that clean immovable property for a third party — so specifically joint committee 121 (cleaning), but also other sectors that meet that definition. A Declaration of Works must always be made as well, since 2024 without a threshold amount. It does not apply to: public and private sectors cleaning with their own staff, sports associations (non-profits) using a volunteer or association worker, and service voucher companies (JC 322.01).

Question 15

What are the possible sanctions?

Accepted Answer

Non-compliance can be punished with a level 1 or level 3 sanction: an administrative fine of €400 to €4,000, or a criminal fine of €800 to €8,000, each time multiplied by the number of employees concerned.

Question 16

How do you register?

Accepted Answer

Either through the NSSO's electronic application, or through Multi-Track's registration system. Recorded are: the identity of the person, the employer, any intermediary party, the capacity (status) of the person, the address of the workplace and the times (start and end, breaks included).

Question 17

Who has to provide the registration system?

Accepted Answer

The client must provide the device to subcontractors, unless an equivalent alternative is agreed contractually. Every (sub)contractor must both use the device and pass it on to its own subcontractors, and must ensure that self-employed people have a compatible means of registration. The employer is responsible for issuing badges to its employees. For temporary workers these obligations rest with the user (the hiring company).

Question 18

What if a mistake is made?

Accepted Answer

Employees must report errors to their employer within 30 days of the registration date. Within that same 30 days the employer can request a correction from the NSSO, with supporting evidence.

Question 19

What is the legal basis?

Accepted Answer

Programme Act of 26/12/2022, title 4, chapter 1 (art. 22–48) and chapter 2 (art. 49, §9 art. 30bis of the act of 27/06/1969).

Question 20

From when do construction companies also have to check out?

Accepted Answer

The NSSO is targeting 1 April 2027 for the full IN and OUT obligation, definitively confirmed by a Royal Decree. Registering today means being ready in time.

Question 21

Does registration apply on every site?

Accepted Answer

Today registration applies on sites above the legal threshold. We set up each site as a workplace with a geofence, so nothing has to be followed up manually.

Question 22

Do subcontractors on our site have to register too?

Accepted Answer

Yes. Every company in the chain registers its own employees. As main contractor you see in one overview who was actually present on site.

Question 23

What about chain liability?

Accepted Answer

You remain co-responsible for correct registration throughout the chain. The overview per site and per company helps you spot missing registrations quickly.

Question 24

Does the extension also cover the delivery of ready-mixed concrete?

Accepted Answer

Yes, the extension does cover the delivery of ready-mixed concrete. It does not cover cleaning activities, which have their own regime.

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