VCA training requirements across multiple sites
Updated Facts as of September 2026
Short answer
VCA requires two things for training, and most companies hold only one. Questions 3.2 and 3.3 ask for valid B-VCA and VOL-VCA diplomas. Questions 3.5 and 3.6 separately ask for your own instruction programme and for instruction on each client site before work starts, with attendance lists, for temps and subcontractors too.

You look after safety for eleven locations. Somewhere in the shared drive is a spreadsheet with every worker's B-VCA number and expiry date, colour coded, kept by someone who is genuinely good at it. It is a useful document. It is also why many QHSE managers walk into a VCA audit believing they are covered and walk out with two non-conformities.
VCA references in this guide are as of September 2026: the company checklist VCA 2026/6.1.
VCA is the client's check, not the law
VCA is not legislation. It is a contractual requirement that clients impose. The law is the Arbowet in the Netherlands and the Welzijnswet plus the Codex over het welzijn op het werk in Belgium; VCA is how clients check whether you meet them. The distinction matters because a diploma is a scheme artefact while the underlying duty is legal, and the two are satisfied by different things. While drawing lines: BeSaCC is not a synonym for VCA but a separate, lighter system for limited risks, and treating the two as one in a tender is an easy way to lose a client's prevention department.
The personal diplomas are B-VCA for operational staff, VOL-VCA for operational supervisors and VIL-VCU for coordinators at agencies. Each is valid for ten years, after which the holder sits the full exam again, not a refresher. VCA 2026/6.1 has applied to company certification since 1 July 2026, replacing VCA 2017/6.0; personal diplomas are unaffected. If your rollout rests on a procedure nobody has revisited since 2017, check that first.
Chapter 3 has two halves
Chapter 3 of the checklist is titled "Opleiding, voorlichting en instructie": training, information and instruction. Read its must questions side by side.
| Question | Asks for | Answered by |
|---|---|---|
| 3.2 | A valid B-VCA for operational employees | The diploma register |
| 3.3 | A valid VOL-VCA for operational supervisors | The diploma register |
| 3.5 | Your own health, safety and environment instruction programme, including an onthaal for new and reassigned workers | Your instruction records |
| 3.6 | Instruction on the client's internal rules and procedures before work starts at that location, for temps and subcontractors too, with attendance lists | Per-site, per-person records |
| 3.7 | Communication without language barriers | Instruction in the language each person reads |
The scheme did not write 3.5 and 3.6 as guidance under 3.2. It wrote them as separate must questions, which is the scheme's own statement that certification and site-specific instruction are different obligations. An auditor shown a complete diploma register and nothing else records a deviation on 3.5 and 3.6, and it is not a technicality: it is the section about what your people were told about the building they are standing in.
Chapter 2: the LMRA is trained at the workpost
Chapter 2 repeats the pattern one level up. Question 2.1 is the RI&E, 2.2 the task risk analysis (TRA) and 2.3 the Last Minute Risk Analysis (LMRA) before work starts. All three are must questions and all three are tied to a specific task at a specific place.
How the TRA and the LMRA differ is explained in the LMRA glossary entry. For site instruction, what counts is that the LMRA is a judgement made on this spot, so a worker taught the concept in a classroom still has to be trained at the specific workpost, and again when the task or the site changes.
What sits underneath, and it is not VCA
Strip the scheme away and the duty remains. Belgium's Codex art. I.2-21 requires training directed at the worker's workstation or function, on entry into service, on a change of function and when new equipment or technology arrives, repeated as risks evolve, during working hours. Art. I.2-20 is sharper: only workers who received appropriate instructions may access zones with serious and specific hazards. Appropriate instructions, not a card in a wallet. That turns instruction into an access condition: at the moment someone walks towards that zone, you need to know whether they are cleared.
In the Netherlands, Arbowet art. 8 requires effective information about the work and its risks and instruction adapted to each worker's tasks, and lid 4 requires the employer to supervise that the instructions are followed. A session delivered once with no follow-up does not meet lid 4. The full comparison of both laws is in our guide to workplace instruction law in Belgium and the Netherlands.
Making site instruction work across many locations
Most companies fall back on the diploma register because the alternative sounds impossible: a different instruction for every address, delivered before work starts, evidenced per person. It is manageable once the content is split properly.
Site instruction that survives a 3.6 audit
- Build the company layer once: your own rules, onthaal, PPE policy and incident reporting route are the same everywhere.
- Keep a site pack per address with only what changes: entry rules, traffic routes, permits, assembly points, the client's own prohibitions. Five things, not forty pages.
- Time it against 3.6: instruction dated the Thursday after the job started is a record of the wrong date, so it has to reach people when the assignment is confirmed, which usually means their phone.
- Deliver it in the language each person reads, which is what 3.7 asks and what an I.2-20 position depends on.
- Pull subcontractors into the same record, because 3.6 names them and the consolidated attendance list is what you will be asked for.
- Route incident findings back into the toolbox cycle, so a finding at site three reaches all eleven within the month.
Toolbox meetings are the recurring half of this. Question 4.1 sets a floor of four a year for VCA* and ten for VCA** and VCA Petrochemie, and the auditor asks for dates, topics and attendance lists. How to run them so they carry real content is in our toolbox guide.
The site pack, delivered before the gate
Aristotl takes the documents you already maintain, the onthaal checklist, the site rules a client sent over, the work instruction, the outcome of the last investigation, and turns them into courses of 3-5 minutes that a worker completes on their own phone, with no laptop and no app to install. Your team reviews each course before it is published. Courses are assigned per site or team, so the crew going to that plant receives that plant's rules, and subcontractors join through a link or QR code without a company email. Each worker reads the content in their own language, and a knowledge check shows the site pack landed.
Completion is viewable per site and version in the platform, which gives you the two things chapter 3 is asking about: what was covered and when, and who completed it before work started. VCA diplomas and other external certificates sit in one overview with their expiry dates.
What it does not replace: the LMRA on the spot, the practical instruction at the workpost and the supervision art. 8 lid 4 asks for stay with your supervisors.
Pick the site you are audited on next and one real document, its site rules or its onthaal checklist, and check whether you could hand over an attendance record dated before the first day on site for every person who worked there last month.
Sources
Frequently asked questions
Read next
What is VCA?VCA defined: a client requirement rather than a law, three ten-year personal diplomas, the company levels under scheme 2026/6.1, and why a diploma is not site instruction.Glossary · 1 min read
Toolbox meetings that actually landGuide · 5 min read
What Belgian and Dutch law require for workplace instructionGuide · 5 min read
Safety instruction for staff who work on client sitesGuide · 5 min read
What is an LMRA?Glossary · 1 min read

