Attendance registration in the meat sector - Royal Decrees awaited

On 18 August 2015 the Programme Law of 10 August 2015 appeared in the Belgian official journal. The law provides for, amongst other things, a system for attendance registration in the meat sector. This legislation is a part of the campaign against social fraud.

The Programme Law provides the obligation for undertakings in the meat sector, supposedly as of 1 July 2015, to register all those who are present and “employed” in the place of work. This concerns both employees as well as independent workers, including foreign subcontractors and their employees.

The registration is done by an electronic system or another automatic way of registering. The employer-client must provide a registration system for its workers and contractors.

The registration data will be sent to a database of the National Social Security Office. The social inspectors can ask for these data in the framework of the investigations they carry out.

The employers and clients violating the registration duty will be sanctioned with a penal fine of 600 - 6.000 EUR or an administrative fine of 300 - 3.000 EUR, to be multiplied by the number of persons concerned. The employee, who omits to register, receives an administrative fine of 60 - 600 EUR.

The Programme Law leaves a large number of elements to be regulated by the King through Royal Decrees (RD’s). As long as the government has not issued the necessary RD’s, the registration obligation is not applicable.

While the government has already approved drafts of RD’s, nothing has been published yet. It goes without saying that we will follow this up for you.

Action point
As soon as the necessary RD’s are published, the undertakings in the meat sector must ensure the registration of the presence of employees and independent workers at the place of work.