CIAW in construction — chain & liability
Adding a subcontractor to Checkinatwork
With Checkinatwork (CIAW), your responsibility doesn't end with your own crew. As main contractor, you share responsibility for making sure your subcontractors and the self-employed workers on your site are registered correctly too. If something goes wrong, the inspectors look at you. Here's exactly how the chain works and how to cover yourself.
How do you add a subcontractor?
Note: “adding” means two different things, and they often get mixed up.
In the declaration of works
That's where you state which subcontractors come on site. Only the declarant can change the declaration; if you bring in a subcontractor yourself, you pass it on to the contractor above you. More about the declaration of works.
In the attendance registration
There you don't add a company, you register people. Every employer registers their own staff on the site number; self-employed workers register themselves. So as main contractor you can't simply enter their attendance on their behalf — you have to make sure they do it.
Who has to register whom?
The registration obligation runs through the entire subcontracting chain. Each link has its role:
Main contractor
Has final responsibility for organising registration across the whole site. Must make sure that all contractors and subcontractors comply with the registration obligation.
Subcontractor
Registers the attendance of their own employees, before they start and every working day. Passes the obligation on to their own subcontractors.
Self-employed / freelancer
In principle responsible for their own registration. Make it clear in the contract who registers.
What do you risk as main contractor?
Responsibility for attendance registration lies first and foremost with the contractor who declares the works. If a subcontractor doesn't register their employees, you as main contractor can be held liable and even face criminal prosecution — even though the mistake wasn't yours.
For a missing or late registration, every party involved — main contractor and subcontractor, employees and self-employed workers — can receive an administrative or criminal fine, per person concerned. You'll find the amounts in the fines section of our CIAW explainer.
How to cover yourself
- Put in the contract who does the registering — especially with self-employed workers.
- Make sure every subcontractor has a registration system that works.
- Keep your own overview: know at any moment who is on your site.
- Choose a system that brings your subcontractors along effortlessly.
Frequently asked questions
How do I add a subcontractor to Checkinatwork?
Which subcontractors come on site is set out in the declaration of works — and only the declarant can change it, so if you bring someone in yourself, you report that to the contractor above you. In the attendance registration itself you don't add a company, you register people: every employer registers their own staff on the site number, and self-employed workers register themselves.
Is the main contractor responsible for registering subcontractors?
The main contractor (the declarant of the works) has final responsibility for organising attendance registration on the site. If a subcontractor fails to register their staff, the main contractor can be held liable and even face criminal prosecution.
Does a subcontractor have to register their own employees?
Yes. Every employer in the chain — main contractor and subcontractors alike — must register the attendance of their own employees before they start work on site, and do so again every working day.
Do self-employed workers and freelancers have to register?
Self-employed workers are in principle responsible for their own registration. Because the main contractor shares liability, it's best to state clearly in the contract who does the registering.
How do you keep track of all your subcontractors?
With AutoCheckIn you add subcontractors and freelancers just as easily as your own people. They are automatically checked in and out on site, and one dashboard shows you live who is present — your own crew and your subcontractors'. €7 per user per month excl. VAT; set someone to inactive and billing for them stops.
Read also
- What is Checkinatwork (CIAW)?
- Registering for Checkinatwork with the NSSO (RSZ/ONSS)
- From what amount is Checkinatwork mandatory?
- Declaration of works or Checkinatwork: what's the difference?
This page is general information, not legal advice. The exact responsibilities and penalties are set out in the NSSO regulations and the Social Criminal Code; check your specific situation with your social secretariat or accountant.