20 Questions About CIAO and Time Tracking

Does a site supervisor need to clock in? Does the work time tracking system also apply to office workers? And what if someone forgets their badge? We’ve compiled the questions about CIAO that construction companies asked us during and before our webinar on October 29, 2026, along with practical answers for each one.

AllConnects is a Flemish specialist in fleet and asset management. With FLEET.connect, CHECK.connect, and LIVE.connect, companies in the construction, transportation, engineering, and rental industries track their vehicles, machinery, and teams. For the construction industry, we support attendance tracking at job sites and employee time tracking.

CIAO and Time Tracking: Two Systems with Different Purposes

Many questions about CIAO tend to get mixed up, which is understandable. After all, these are two separate systems. One tracks who is present at the construction site, while the other tracks how many hours someone has worked.

CIAO in the Construction IndustryGeneral Work Time Tracking
What are you recording?Who arrives at and leaves a construction site in questionHours Worked
Who is this for?Working on construction sites covered by the regulation, with a total project value of at least €500,000, excluding VATNot limited to blue-collar workers or PC 124; the preliminary draft includes exceptions
Starting when?The RSZ will issue a notice on April 1, 2027. Until then, the current rules for Checkinatwork will remain in effect.Announced on January 1, 2027, with a transition period lasting until the end of March
Current StatusAs set forth in the Program Act of May 30, 2026Preliminary draft; not yet a definitively approved regulation

"Present" does not automatically mean "worked"

Time spent on-site is not automatically the same as the time used for payroll calculations. Work at the depot, travel, and breaks require separate assessment. For your specific work arrangements, your labor relations office or legal advisor remains your point of contact.

Who is required to register, and for what purpose?

1. Do site supervisors and project managers need to check in and out if they visit multiple sites in a single day?

That depends on what they do at the construction site. According to the current interpretation by the RSZ, site supervisors and project managers who only monitor progress and do not themselves perform any work on real property are not required to register for that activity. The distinction between a laborer and a white-collar worker is not, in and of itself, decisive.

If they actually perform such work themselves at a construction site subject to registration, the requirement may apply. If multiple sites are involved, you must then record arrivals and departures at each site. Furthermore, an access log required by the general contractor may be more comprehensive than the legally required attendance log.

Source: RSZ: Checkinatwork · RSZ: FAQ on Attendance Tracking · Framework Act of May 30, 2026, Articles 124–131

2. Does a project manager working under PC 200 who only performs inspections need to check in and check out?

In principle, no. According to the current RSZ FAQ, a project manager who only performs inspections and does not carry out any work on real property is not required to register for that activity. PC 200 is therefore not the reason for the exemption; rather, it is the specific task performed on the job site.

Anyone who also performs hands-on work must therefore reassess their situation. A specific legal role, such as safety coordinator or construction manager, also requires a separate assessment.

Source: RSZ: FAQ on Attendance Tracking

3. Does the work time tracking policy also apply to office workers?

That is possible. The proposed general working-time tracking system is not limited to blue-collar workers or PC 124, so white-collar workers may also be subject to it. The preliminary draft does, however, include exceptions for certain categories of employees. The exact scope will be determined by the final law.

In the meantime, existing obligations remain in effect, such as time tracking for flexible work schedules and the recording of deviations in part-time work.

Our advice: Determine, for each position and work arrangement, what is already required today and what the new law will add later.

Source: NAR: Opinion 2499 · FPS Employment: Part-Time Employees · FPS Employment: Working Hours

4. How do you track the working hours of an employee who works from home?

Attendance tracking at construction sites does not apply here. Furthermore, the status of teleworkers has not yet been definitively determined under the future general working-time tracking system: the draft and the advisory opinion on the matter include discussions regarding their exclusion.

Our advice: If you want to track remote work hours in a practical way, you can do so, for example, by using a personal tracking system on a laptop or through an app. Agree on how work blocks, breaks, and corrections will be tracked, and have HR review which rules align with your remote work policy. Continuous location tracking is not necessary for this.

Our solution: With the PrestaMob app, your employees can track their own work hours on their smartphones. This allows you to monitor the hours of both remote workers and on-site employees within the same platform.

Source: NAR: Opinion 2499 · FPS Employment: Domestic Work and Telework

5. Who is responsible for registering temporary workers: the staffing agency or the client?

Both parties have a role to play. When it comes to attendance tracking at the worksite, the employer’s obligations rest with the user—that is, the company that deploys the temporary worker. The user must ensure that the temporary worker has access to a suitable means of clocking in and is familiar with the procedure. The temporary worker then clocks in on their own.

Our advice: As a temporary staffing agency, work with your client to determine which system will be used, who will follow up on missing entries, and how you will receive the verified performance data for payroll processing. After all, the staffing agency retains its own obligations as an employer, and a CIAO report does not automatically constitute a complete payroll statement.

Our solution: In LIVE.connect, you can group employees by VAT number so that the correct VAT number is always sent to CIAO.

Source: Welfare Act, Articles 31bis–31octies

6. Does a warehouse worker have to clock in and out, and does every worksite fall under the CIAO system?

No, to both questions. A worker who simply works in the company’s own warehouse does not need to clock in and out in CIAO for construction work. However, the time he works remains relevant for payroll and for any existing rules regarding time tracking. You’ll need to assess the future general registration requirement separately.

Not every construction project is covered by the construction regulations. The RSZ specifies a total construction value of at least €500,000, excluding VAT, for the expansion effective April 1, 2027. This refers to the relevant total construction work, not just your own contract. A separate regulation with different conditions applies to cleaning services. If construction work subject to registration is being carried out in the warehouse itself, you must treat that activity separately.

Source: RSZ: Checkinatwork · FPS Employment: working hours · RSZ: CIAO FAQ on cleaning

Registration in Practice

7. Is a site supervisor required to record his or her working hours for each job site?

Not automatically. Make a distinction between your workday (time tracking) and your presence at a job site (CIAO). For internal time tracking, you can record office work, job site visits, and travel as separate activities. Breaking down hours by job site is useful for cost reconciliation, but it is not automatically a general legal requirement for every site manager.

For CIAO, you must first determine whether your activity at a particular construction site is subject to registration, as explained in the first question. Only then should you complete the required registrations for each site.

Our advice: Let HR determine how travel is treated as working time and for compensation purposes under your employment policy. A mobility allowance alone does not answer that question.

Our solution: Do you clock in using the PrestaMob module in the vehicle, or do you use the PrestaMob app? If so, you can use it to track both your work hours and your CIAO registration.

Source: RSZ: FAQ on Attendance Tracking · FPS Employment: Working Hours

8. Can you check in someone from the office who forgot their badge?

Do not assume that a phone call is sufficient. CIAO’s basic principle is that the employee must clock in at the right time when arriving at the worksite. Therefore, the fact that a technical option for data entry exists does not mean that this method is permitted.

That is how we understand the rules today. Regarding the situation with a forgotten badge, we are still waiting for specific confirmation from the RSZ. In the meantime, AllConnects can provide a viable alternative on-site, such as a replacement badge, an app, or a QR code generator.

Our advice: If a record is missing, document the actual time and circumstances and follow the applicable correction procedure. Do not present a later entry as if it had occurred at the original time.

Source: Framework Act of May 30, 2026, Articles 124–131 · Welfare Act, Articles 31bis–31octies

9. Do you need a second time clock for CIAO when using a turnstile?

It's not automatic, but we do recommend it. That's because each module has a single input for a badge reader. If everything is connected to the same module, we can't distinguish between ENTRY and EXIT. That's why we install multiple badge readers in parallel.

Our recommendation: Use two time clocks. Also, make sure that departure times are recorded, that each person is properly identified, and that social security reports are followed up on. Additional time records may be necessary for working hours, such as for breaks on the job site or work outside the entrance gate.

Our solution: We assess on a per-installation basis whether an adjustment is sufficient. We also investigate whether the CREWpad (tablet) could make a difference in the future through software updates.

Source: Framework Act of May 30, 2026, Articles 124–131 · Welfare Act, Articles 31bis–31octies

10. Can workers without a company car also register?

Yes. Registration doesn't have to be done using a company vehicle. A badge on a site vehicle or a suitable app can also work for employees who come to work in their own car, by bike, or by public transportation.

The right choice depends on the job site and the devices available. Also, make sure that employees without a suitable smartphone can check in in person. We tailor the solution to both job site check-in and the time tracking you need.

What does this mean in practical terms for your recruitment efforts?

Together, we'll review your current workflow and determine what adjustments are needed for CIAO and time tracking.

Request a free site assessment

Limosa

11. Is a Limosa notification required in addition to CIAO?

Yes, if the person is subject to the Limosa reporting requirement. This requirement remains in effect alongside the attendance registration requirement. It applies, among others, to certain employees and self-employed individuals who come to work in Belgium temporarily from abroad, with a few exceptions.

The Limosa notification must cover the assignment and be in order before it begins. It does not, therefore, replace a check-in or check-out. Nor do you need to submit a new Limosa notification with every check-out.

Source: Working in Belgium: Limosa

12. Do you need to submit a Limosa notification for each project?

It is not necessary to file a separate report for each job site. A single Limosa report can cover multiple work sites: up to twenty, according to the RSZ. However, the report must correctly cover the individuals, the time period, the clients, and the locations.

In the construction and temporary staffing sectors, you must also specify the work location as precisely as possible. Simply listing a broad region is not sufficient.

Our advice: If there is an additional worksite, check whether a longer assignment requires a supplement, extension, or new notification. This is separate from the attendance records for each worksite.

Source: Working in Belgium: Limosa · Working in Belgium: Place of Employment

Badges, devices, and connectors

13. Will the ConstruBadge be phased out in 2027, and will the LisaBadge work on all systems?

The physical ConstruBadge is going digital, and you’ll need to verify the LisaBadge on each device. Starting in 2027, the physical ConstruBadge will be replaced by a digital version in MyConstructiv. That doesn’t mean the identification badge will disappear entirely. If you use a physical badge to register, be sure to check in advance which alternative works best for your devices.

The LisaBadge is available for various employment statuses and joint committees, including for white-collar employees. The supplier states that it is compatible with most registration systems. Therefore, we cannot promise without testing that it will work on every device: the card reader, the software, and the link to the correct employee must all be compatible.

Source: Constructiv: ConstruBadge digital · TO BE LISA: LisaBadge

14. Can you combine registration via the vehicle and via the app?

Yes, that combination is possible. For example, you can track mobility using the vehicle and record work activities using the PrestaMob app. Be sure to agree in advance on what data each channel will provide.

It is important that the same employee is correctly identified in both systems and that duplicate or conflicting entries are handled appropriately. For CIAO, check-in and check-out times must also match the person’s actual presence. Simply knowing where the delivery van is parked is not enough to ensure this.

Source: Welfare Act, Articles 31bis–31octies

15. Can you also use the PrestaMob app to track and trace shipments?

The app does not replace a vehicle tracker with continuous location history. However, employees can use PrestaMob to track their mobility, trips, and performance. For mobility tracking, you can also combine the app with a vehicle tracking solution.

An integration can also support the administrative processing of job site registrations. For CIAO, however, the established workflow must record and forward employees’ actual arrival and departure times at the required moments. Simply entering work hours retroactively is not sufficient for this purpose. We’d be happy to check with you which app version, features, and settings support your specific setup.

Source: Framework Act of May 30, 2026, Articles 124–131

16. Does the Zen (Conneqtr) integration work with the job site tablet and the time clocks?

Yes, there is an integration with Conneqtr's Zen. Whether your job site tablet and time clock work with it depends on the device, the software version, and the activated integration.

That is why we are reviewing what data is being exchanged and testing the entire registration process, from employee to platform. The existing integration does not automatically mean that all CIAO features will be available on every device starting in 2027.

Work Hours, Reporting, and HR

17. What happens if the 11-hour limit in PC 124 is exceeded, and does everything go to the RSZ?

No, not all time data is sent directly to the RSZ. CIAO forwards the required attendance data. As a result, your complete internal time and payroll records are not automatically sent directly to the RSZ.

Furthermore, 11 hours is not a general daily standard for PC 124. The normal work schedule and the permitted deviations each have their own conditions. Moreover, a long presence on the job site does not necessarily prove that the same amount of time was worked.

If the applicable working hours limit is exceeded, the employer must have the grounds for the deviation and the rest periods assessed. Possible consequences include adjustments to wages or overtime pay, compensatory rest, and—in the event of a violation—penalties for the responsible employer. For the employee, the hours actually worked remain relevant to his or her wage entitlements. A workday exceeding 11 hours therefore does not automatically result in a fine.

Hours actually worked must not be omitted to conceal an overrun. Therefore, do not rely on automatic capping in LIVE.connect; instead, let us review the settings for time tracking, rounding, and payroll export. After all, payroll calculation and retaining the original time entries are two different matters.

Source: Framework Act of May 30, 2026, Articles 124–131 · FPS Employment: Working Hours · FPS Employment: Sector Fact Sheet PC 124

18. Can you record absences?

Our solutions focus on attendance, mobility, and hours worked. You should coordinate leave requests and approvals, sick leave balances, and other absence management matters with your HR partner or payroll service.

We’d be happy to work with you to determine whether an absence code can be included in your AllConnects configuration or processed via an integration. Please note: a missing entry does not automatically mean leave or sick leave. It could also simply be a missing entry.

19. How do you prepare reports for an inspection and for payroll?

This data is derived from two sources: attendance records at the job site and verified performance data for HR. For job site tracking, you want to be able to retrieve the IN and OUT check-ins and their processing status by person, date, and job site. For payroll, you also need the relevant work hours, breaks, travel time, and any corrections.

Our advice:

  • Check with your social secretariat to determine which codes and exports are required.
  • Retain the original entries and ensure that corrections are traceable.
  • Show in your own configuration how to retrieve and run these reports.
  • Also check the access and retention periods for each type of data. After all, a single export file does not replace all the documents that may be requested during an inspection.

Source: Welfare Act, Articles 31bis–31octies

20. What changes do you need to make to your LIVE.connect subscription for CIAO starting April 1, 2027?

That depends on what's included in your subscription and configuration today. Just using LIVE.connect doesn't tell you which registration channels and integrations are active. However, the CIAO upgrade is free for existing users' subscriptions.

Our recommendation: Let us verify whether your current setup supports personal OUT registrations, the correct RSZ integration, and the follow-up of missing reports. We’ll take your badges, vehicles, apps, and construction site equipment into account. We’ll review additional work time tracking separately.

Your account manager will then confirm what can be done through an update, what changes may be necessary, and what subscription terms apply. That way, you'll know in advance what will change for your business.

Source: RSZ: Checkinatwork

Looking for advice for your business?

Would you like to know what this means specifically for your recruitment and employees? We’d be happy to explore this with you.

Request a free site assessment

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Hilde Lavrijssen

Hilde Lavrijssen Marketing Manager at AllConnects. Writes about fleet and asset management, workplace regulations, and what data can and cannot mean for a Belgian vehicle fleet.

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