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What Belgian and Dutch law require for workplace instruction

Updated

Short answer

Both countries require instruction aimed at each worker's own job and risks. Belgium's Codex adds concrete triggers (entry, change of function, new equipment), working hours and a signed onthaal document per new worker. The Dutch Arbowet art. 8 requires effective, task-specific instruction and supervision that it is followed, but prescribes no form of proof.

A supervisor in a hard hat shows a new worker how the guard on a machine opens, with an open binder and a phone on the bench beside them.
Instruction the law recognises: about this workstation, for this person, before the work starts.

Compliance training tends to be discussed as content: which topics, how often, which certificate. Inspectors and auditors rarely start there. They start with a name and a date, and work outwards. Was this person instructed before they started, about this site and this task, on the version of the procedure currently on the wall, in a language they read? Every one of those questions is answered from the law's own wording, and from a record.

Two laws, the same question

In Belgium the duty sits in the Welzijnswet of 4 August 1996 and its implementing Codex over het welzijn op het werk. Codex art. I.2-21 requires every worker to receive sufficient and appropriate training on welfare at work, aimed at their workstation or function: on entry into service, on a change of function, and when new work equipment or new technology is introduced. It is repeated and adapted as risks evolve, given during working hours, and not at the worker's expense. Art. I.2-20 adds an access rule: only workers who received appropriate instructions may enter zones with serious and specific hazards. Appropriate instructions, not a diploma.

In the Netherlands, Arbowet art. 8 requires that workers are effectively informed about the work and its risks (lid 1), that instruction is effective and adapted to their distinct tasks (lid 2), and that the employer supervises compliance with the instructions given (lid 4). Lid 4 is the one that quietly decides most inspections: issuing an instruction is not supervising it.

Two columns, Belgium and the Netherlands, aligned row by row: what triggers instruction, who owns it, when it must happen, what record the law asks for, and the language it must be understood in.
The same duty, organised differently. Belgium names triggers and a signed record; the Netherlands leaves the proof to you.
Belgium (Codex)Netherlands (Arbowet)
TriggerEntry, change of function, new equipment or technology, evolving risks (I.2-21)Effective and kept effective for the tasks the worker does (art. 8)
OwnerThe employer; the onthaal is entrusted to a member of the hierarchical line (I.2-15)The employer, who must also supervise compliance (art. 8 lid 4)
WhenOn entry and at each change; during working hoursBefore and while doing the work; no timing fixed in law
RecordA document signed by the line manager per new worker (I.2-11)No form prescribed; without your own record you cannot show it
AccessOnly instructed workers in zones with serious and specific hazards (I.2-20)Follows from effective instruction and supervision

The Belgian onthaal is a procedure

Where most training duties are written as results, the onthaal is written as a procedure. Codex art. I.2-15 entrusts it to a member of the hierarchical line, and art. I.2-11 adds an experienced worker who accompanies each beginning worker and a document that the designated line manager signs for each person, so one group attendance list does not cover it. The term is explained in the onthaal glossary entry, and what it asks of supervisors in our guide on the line manager's duty.

The Dutch duty has no template

The Netherlands has no equivalent signature obligation, and it should not be claimed. Article 8 imposes the duty without prescribing any proof. That is uncomfortable rather than comfortable: the duty exists, and how you demonstrate it is entirely your own design. Without a record of who was instructed, on what, when and in which language, you cannot show that article 8 was met for a specific person on a specific date, and lid 4 asks you to show more than that: that you checked the instruction is being followed.

Temps: the user company instructs the workstation

Agency workers sit in a triangle. In both countries the company where the work is done carries the instruction about that workstation and its risks: in Belgium the user company, through the werkpostfiche it completes with the agency; in the Netherlands the hirer, who counts as the employer for the Arbowet. The agency's general induction does not replace it. How to run that before a temp's first shift is in our guide on onboarding temp workers, and the form itself in the werkpostfiche entry.

Language is part of "effective"

Neither law accepts instruction the worker cannot follow. The Arbowet asks for effective instruction, the Codex for appropriate training, and instruction in a language someone does not read meets neither. Which language Belgian law requires for work documents in each region is a separate question with its own rules, covered in our guide on the language of work instructions.

What the frameworks on top add

FrameworkLaw or contractWhat it adds to instruction
Codex (BE)LawTriggers, working hours, onthaal with signed document, access to hazardous zones
Arbowet (NL)LawEffective, task-specific instruction and supervision of compliance
Regulation 852/2004Law (EU)Food handlers instructed or trained in hygiene in line with their work
VCAContractSeparate must questions for diplomas, own instruction programme and site instruction
BRCGS, IFSContractTraining before work starts, documented programme, records, effectiveness

The law almost never fixes a course, a certificate, a duration or an interval. The schemes are more specific, but they are contracts: a client or a retailer asks for them. Our VCA guide covers the scheme most contractors meet, and our guide on refresher intervals the few places where an interval is fixed.

How Aristotl handles it

Aristotl builds courses of 3-5 minutes from the procedures and instructions you already maintain, and each worker completes them on their own phone, in their own language, with a knowledge check. Your team reviews every course before it is published. Courses are assigned per site or team, temps join through a link or QR code without a company email, and completion is viewable per person, per site and per version in the platform, so the question "was this person instructed, on what, and when" is one look.

The Belgian onthaal can run as a checklist with a signature step for the line manager, and the checklist day log exports as CSV or PDF. What stays with you: the practical instruction at the workstation, the buddy, and the supervision art. 8 lid 4 asks for.

Take the last three people who started on your riskiest site. For each of them, check whether you could show what they were instructed on, when, by whom and in which language.

Sources

  1. Codex over het welzijn op het werk, Book I, Title 2 (art. I.2-11, I.2-15, I.2-20, I.2-21)
  2. FOD WASO: Codex over het welzijn op het werk
  3. Arbeidsomstandighedenwet, article 8
  4. Regulation (EC) No 852/2004 on the hygiene of foodstuffs, Annex II, Chapter XII
  5. VCA checklist 2026/6.1 (Stichting Samenwerken voor Veiligheid)

Frequently asked questions

Yes. Under Codex art. I.2-11, the designated member of the hierarchical line signs a document, under their own name, showing that the necessary welfare information and instructions were given to the new worker. It is one document per person, not one attendance list for a group.

No form of proof is prescribed. Article 8 requires effective information and instruction adapted to each worker's tasks, and supervision that the instructions are followed. Without a record of your own, you cannot show that article 8 was met for a given person on a given date.

No. VCA is a certification scheme that clients require by contract. It checks whether you meet the legal duties in the Codex and the Arbowet, and it adds its own must questions on instruction, such as site instruction before work starts.

Mostly not. The Codex requires training to be repeated as risks evolve and the Arbowet requires it to stay effective, without an interval. A few specific regimes do fix one, such as the yearly refresher for Belgian first-aiders.

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