On July 24, 2025, the Social Information and Research Service (SIRS ) published new guidelines on theprohibition of subcontracting work.
These clarifications are intended to provide a better framework for practices in the construction sector, and to avoid arrangements where a subcontractor is limited to a purely administrative role.
🔹 Background and objective of the measure
As of January 1, 2025, any subcontractor awarded a works contract may no longer entrust all the work to another company.
Subcontractors must play an active role in the execution of the work, and may not limit themselves to coordinating or supervising the site.
The aim of this measure is to step up the fight against cascading subcontracting and to ensure that each party involved makes a genuine contribution to the work.
🔹 Total subcontracting: now prohibited
This prohibition only applies to work entrusted entirely to a third party.
A subcontractor remains in compliance with the law if it carries out even a small part of the work itself.
On the other hand, the delivery of materials alone does not constitute sufficient participation.
In particular, SIRS will check:
- the presence of personnel assigned to the work,
- possession of the necessary equipment and technical resources,
- and actual construction activities.
🔹 Simple site coordination is no longer enough
Companies that limit themselves to planning, organizing or communicating between the parties, without actually carrying out any work, will be considered to be in breach of the law.
According to the guidelines, coordination tasks include :
- site planning,
- organization and progress monitoring,
- communication between stakeholders,
- risk and deadline management.
🔹 Things to remember
To comply with the regulations, a subcontractor must carry out a specific part of the work himself.
Neither the simple supply of materials, nor the administrative or technical management of the worksite are sufficient to meet this obligation.
🔹 Read more
The complete SIRS guidelines can be consulted here:
👉 SIRS – Construction sector, version of 24/07/2025
(See point 19, “In-house inspection”).