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Limosa: place of work

Since 23 October 2023, new functions have been introduced in the Limosa application. These make it possible to enter or add up to 20 places of work in a single L1 declaration.

The International Relations Department has prepared an analysis of the concept of “place of workˮ to help you enter this information correctly when submitting your Limosa declaration.

What does the law say?

Firstly, it should be noted that Article 140 of the Programme Law of 27 December 2006 stipulates that the King shall determine the groups of data that must be included in the prior declaration referred to in Article 139.

Furthermore, Article 1 of the Royal Decree of 20 September 2017 amending the Royal Decree of 20 March 2007 states: Art. 4, § 1 . For posted employees, the declaration referred to in Article 140 of the aforementioned programme law of 27 December 2006 includes the following categories of data: [...] 8° The place where the services are provided in Belgium. [...]

Finally, the Royal Decree of 19 March 2013 explains why it is necessary to indicate the place of employment: Art. 1 , 7°: The place in Belgium where the work is provided. This information is important to enable the inspection services to locate posted workers and, consequently, to monitor them.

How do you correctly indicate the place of work?

The place of work (maximum twenty per declaration) must always be indicated as precisely as circumstances allow.

The online application allows you to communicate your location in four different ways:

1. “Companyˮ: you must select this option if the activities are carried out at a fixed location during the entire period of posting. The name of the company and its full address must be given. In a single declaration, you can indicate up to twenty places of work where the worker will be active during the period declared, without having to specify exactly when the worker will be occupied at each of the places. As a result, there is no need to submit a different Limosa declaration for each place of work.

   If the activities are carried out at a specific location, this must be mentioned accurately and completely.

   Example: Let's take the example of a worker who comes to repair lifts at the NSSO. In this case, you must provide the address of the NSSO in the declaration.

2. “Teleworkingˮ: this option must be selected in the case of teleworking from Belgium. This applies to both occasional teleworking and structural hybrid working (where part of the time is spent working from Belgium and part of the time is spent in the employer's offices abroad). You must indicate here whether the physical place of work is a private address and give the street, house number and municipality.

   Example: An employee combines 4 days at the office in France and 1 day teleworking from his home in Belgium. In this case, you would enter the employee's home address, checking that it is a private address.

3. “Siteˮ: however, you may not have a concrete address for the place of work, but the name of a commune or town where the worker will be employed. If so, you can indicate the few details you have for identifying the site, such as the name of the site and the postcode and/or municipality.

   Example: A worker installing new traffic lights in the port of Antwerp. In this case, it is impossible to give a specific address. However, it is clear that he will always work in the port. You can therefore indicate the port as the site and Antwerp as the municipality.

4. “Regionˮ: if it is impossible to specify an address or a site because the activities will take place in too many different places, specifying a region will suffice. In this case, you should always give a specific first place of work (company, site) where the worker will start work. You can then add one or more regions. Systematically indicating “regionˮ per convenience, even though the activities will only take place in one or a few places does not reflect reality.

   Example: Let's take the example of a sales representative campaigning for new customers in Flanders. He will visit various shops over the course of a year, depending on the interest shown and the appointments made. It is impossible to mention all the sites at the beginning of the declaration. However, the first (potential) customer is known. The first appointment should be indicated as the place of work, while the region “Flandersˮ can be used as the second place of work.

Because of the risk of fraud and the need to know the exact places of employment and their duration, the temporary work sector and the construction sector (except in exceptional situations) must declare the exact places of employment in accordance with Art. 5 of the Royal Decree of 20/03/2007 (in French).

For the two sectors mentioned above, it is therefore not sufficient to mention the region as the place of work.