CCNL Multiservices 2026: GPS presences, obligations and risks

CCNL Multiservices 2026: the GPS time sheet is no longer optional

The update of the CCNL Multiservices and the circulars of the National Labor Inspectorate for the last 18 months have redesigned the obligations of cleaning, supervisory, maintenance and facility management companies regarding attendance recording.

The result? Many SMEs in the sector are technically non-compliant without knowing it

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What does the current regulatory framework say

The starting point is Legislative Decree 66/2003 (implementing the EU Working Time Directive), which requires employers to keep documentation of the actual working hours for each employee.

In the multiservice sector, this is combined with:

• CCNL Multiservices: obligation to record attendance for each work site
• INL Circular 2023: clarifications on the documentation requirement for workers on multiple sites
• Transparency Decree (Legislative Decree 104/2022): obligation to communicate monitoring systems to workers

The critical point for field service: if an operator works on 3 different sites on the same day, you must document the attendance for each site separately — the total daily hours are not enough.

The concrete risks of non-compliance

In the case of an INL inspection with 20 workers on 15 sites, the theoretical exposure may exceed €60,000 — for deficiencies often unknown to the owner.

Why is the Excel sheet not enough

Many businesses still use Excel sheets or paper records. The problem is not only practicality: it is documentary unreliability

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In case of inspection or litigation, an Excel sheet does not prove:
— That the time was recorded in real time (and not filled in afterwards)
— That the worker was actually at the declared site
— That the data has not been modified after registration

The GPS system with a cryptographic hash solves all three problems: each stamp is timestamped in real time, geolocated to the site, and cryptographically inviolable.

Case study — HR manager, cleaning company 35 employees (Turin):
“The INL inspector asked us to demonstrate the presence of each operator on each site for a period of 90 days. With GeoTapp I exported everything in 10 minutes. Without that system, I would have spent weeks reconstructing the data — if that was possible

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How GPS automates compliance

GeotApp TimeTracker automatically manages all document obligations:

1. Site stamping: each entry/exit is associated with the specific site with GPS
2. Automatic attendance register: available in PDF/Excel export for each period
3. Compliant storage: data on EU server, configurable retention
4. Worker information: the system automatically sends the mandatory communication at the first access

GDPR and GPS in the employment relationship

An often overlooked point: GPS tracking of workers requires a documented balance of interests, not just information.

GeoTapp manages this aspect automatically through:
— Full information to the worker with digital signature upon onboarding
— Tracking active only during working hours (not out of shift)
— Access to their data by the worker (portability)
— Automatic cancellation according to configured retention policy

Everything is documented and verifiable in the event of a GDPR inspection or trade union dispute.

Checklist: Are you in good standing?

Check these points for your business:

• [] Does each worker have one stamp per site (not just daily total)?
• [] Are attendance data kept for at least 2 years?
• [] Can you reconstruct the time on each site for any day in the last 6 months?
• [] Have the workers been informed of the attendance recording system?
• [] Is the GPS system GDPR compliant (working hours only)?

If you answered ‘no’ to even one, you are potentially exposed.

Conclusion: compliance isn’t a cost, it’s insurance

Companies that implement certified attendance systems do not do so out of fear of the inspector. They do it because an orderly system protects everyone: the company from sanctions, the workers from unfair disputes, the customers from doubts about the quality of the

service.

With GeoTapp, compliance is automatic. You don’t have to remember to do anything: the system produces documentation while your technicians are working

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What Are You Actually Risking in the Event of an Inspection

Penalties for not keeping working time documentation are not symbolic. The National Labor Inspectorate may impose fines ranging from 120 to 600 euros for each worker for whom documentation is absent or inadequate. If you have ten employees and the three-month documentation does not comply, you are talking about thousands of euros in penalties that add up to the legal costs and the time lost to manage the inspection

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But the biggest risk isn’t the fine itself — it’s what happens next. An inspection that finds documentary irregularities opens a file that can lead to more in-depth checks on all personnel management. And in sectors such as cleaning, surveillance and facility management, where overtime, variable shifts and multiple construction sites are the norm, fragmented or imprecise documentation is

a constant risk.

The Difference Between ‘Compliant’ and ‘Protected’

Being technically compliant with the regulations is not the same thing as being protected in the event of a dispute. A properly filled out paper time sheet is “compliant” — but in the event of an appeal by an employee who claims to have worked unrecognized hours, that sheet alone is not enough. You have no way of proving that the data reported correspond to reality, because there are no objective data to confirm them

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With GeoTapp, each stamp is a system data with GPS, immutable timestamp and anti-spoofing verification. You’re not just filling out a log — you’re creating verifiable evidence of every moment of presence. If an employee files an appeal, you have the entire history of stamps with the certified position available for each working day. Not “our log says X” — but “the GPS system says X, with these coordinates, at this timestamp, verified by this certificate

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Implement Compliance Without Adding Bureaucracy

The paradox of compliance is that many companies avoid it because they think it requires more administrative work. In reality, an integrated digital attendance system such as GeotApp reduces administrative work instead of increasing it. The technician rings with the telephone — a gesture he already does normally — and the system automatically produces all the documentation required by law: entry and exit times per construction site, weekly and monthly summary per employee, accessible record in case of inspection

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You no longer have to collect paper sheets, you no longer have to copy data from one system to another, you no longer have to prepare special reports before inspections because the report is already ready automatically. Compliance becomes a by-product of normal operating flow, not an additional activity. And this completely changes the relationship of SMEs with labor legislation: from a burdensome obligation to an automatic process

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