Compliance training tends to be discussed as content: which topics, how often, which certificate. Auditors and inspectors rarely start there. They start with a name and a date, and they work outwards. That difference is why companies with genuinely good training programmes still collect findings.
Sit on the other side of the table for ten minutes
An auditor has limited time and a checklist. The efficient move is not to read your course material. It is to pick a few workers off the payroll list, preferably ones who started recently or work on the riskiest part of the site, and ask what each of them received and when.
From there the questions are predictable. Was this person instructed before they started work, or after. Was the instruction about this site and this task, or was it the general company induction. What version of the procedure was it based on, and is that the version currently on the wall. Can I see the attendance list. Was it in a language this person reads. And, for the ones that repeat: you set your own interval, so are you meeting it.
Every one of those is answered from a record, not from a course. Which means the export is the product. Filter by date range, site, role or course version, and hand over a list with a timestamp per person. Reconstructing that from mailboxes and folders during audit week is the burden most operators are actually trying to shed.
Four frameworks, and only two of them are law
Being precise about this earns credibility with exactly the reader who decides.
VCA is not a law. It is a contractual requirement from clients. The law is the Arbowet in the Netherlands and the Welzijnswet plus the Codex in Belgium. VCA is how clients check whether you comply with those. Worth knowing that the current company certification scheme is VCA 2026/6.1, in force since 1 July 2026, replacing 2017/6.0, and that personal diplomas remain valid. Those personal diplomas, B-VCA for operational staff, VOL-VCA for operational supervisors and VIL-VCU in the agency world, are valid for ten years and then require a full re-examination rather than a refresher.
The Codex is law in Belgium. Art. I.2-21 requires sufficient and appropriate training aimed at the worker's workpost or function, on entry into service, on change of function and on new work equipment or new technology, repeated and adapted as risks evolve. Art. I.2-20 sets an access rule: only workers who have received appropriate instructions may enter zones with serious and specific hazards. Note the wording. Appropriate instructions, not a diploma.
The Arbowet is law in the Netherlands. Art. 8 requires effective information about the work and its risks, instruction adapted to the worker's distinct tasks, and supervision of compliance with the instructions given. It prescribes no form of proof. Say that plainly, then say the consequence: without a registration you cannot demonstrate article 8.
Two must questions a diploma folder does not answer
Chapter 3 of the VCA checklist is called "Opleiding, voorlichting en instructie" and it contains separate must questions for the two things. Question 3.2 covers a valid B-VCA for operational staff and 3.3 a valid VOL-VCA for supervisors. Question 3.5 separately requires a company specific VGM information and instruction programme, including an onthaal or introduction programme for new and reassigned workers. Question 3.6 separately requires instruction on the internal rules and procedures at clients, for temporary workers and subcontractors as well, before work starts on that location, demonstrably, with attendance lists.
That these sit as distinct must questions is the scheme itself saying the diploma is not enough. A folder of valid diplomas answers 3.2 and 3.3 and leaves 3.5 and 3.6 open.
The Belgian onthaal is unusually concrete
Most training obligations are written as results. The onthaal is written as a procedure. Codex art. I.2-15 requires the employer to organise the onthaal of every worker and to entrust it to a member of the hierarchical line. Art. I.2-11, second paragraph, 9° goes further: organise the onthaal of every beginning worker and designate an experienced worker charged with guiding them, and the designated member of the hierarchical line signs a document under his name showing that the necessary information and instructions regarding wellbeing at work were given.
Three hard elements: every beginning worker, a named buddy, and a signed document per person. This is not a best practice, it is a duty to hold evidence, and it is the first thing a Belgian inspector can check without interpreting anything.
Certified food sites add a layer, not a different logic
Regulation 852/2004, Annex II, Chapter XII requires food handlers to be supervised and instructed or trained in food hygiene in line with their occupational activity, and those responsible for the HACCP procedure to have received adequate training in applying HACCP principles. It prescribes no course, certificate, duration or repeat interval. For certified sites the specificity comes from the standard: BRCGS Food Safety Issue 9, clause 7.1.1 requires all personnel, including agency supplied staff, temporary staff and contractors, to be appropriately trained prior to commencing work and adequately supervised throughout. IFS Food version 8, clause 3.3.3, wants records containing a participant list with signature, date, duration, content and trainer name. Neither standard sets a fixed repeat interval, so the site sets its own and is then judged against it.
Recertification is a cadence you own
Almost nothing in this field carries a legally fixed refresh interval. B-VCA runs ten years. Beyond that, the intervals in your programme are yours: you set them, and the finding comes when you quietly stop meeting them.
Aristotl builds the courses from the regulated procedures you already maintain, preserving the source version against the record, and runs the cadence per learner and per site: a validity period per certification, renewal windows that open automatically with reminders before expiry, and a retraining on change of role. Knowledge checks and scenario questions test what the worker would do at the point of decision, which is what "adequate supervision" and "effective instruction" are asking about. Automatic translation per learner covers the language question before it is asked, and VCA 3.7 makes communication without language barriers a must in its own right.
Bring the framework you are audited against next and one site's worker list, and we will show you the export you would hand over.