Working time registration becomes mandatory in Belgium on 1 January 2027: what it means for your company

From 1 January 2027 every Belgian employer must record the hours its staff actually work. Not the planning, not the schedule: the real hours. This article lays out who the obligation applies to, what counts as valid registration, what you must keep and what you can already do this autumn.

What exactly changes on 1 January 2027

From that date every Belgian employer must have an objective, reliable and accessible system to record the working time of its employees. Those three words are not plucked from thin air: they come from a 2019 judgment of the European Court of Justice in the case CCOO versus Deutsche Bank (C-55/18). That judgment obliged member states to impose such a system. Belgium took six years to get there.

The announcement came in the federal budget agreement of 27 November 2025. The main lines emerging from it and from the draft bill:

• The obligation takes effect on 1 January 2027.
• Whoever has no suitable system by that date gets a transition arrangement until the end of the first quarter of 2027.
• The recorded data must be kept for five years.
• It concerns the working time actually performed, not the planned time.

The law does not exist yet

This is the part missing from much of the coverage and it is exactly the part to keep in mind when you take a decision now. There is no voted law today. What does exist is a draft bill that was sent to the National Labour Council for advice on 26 March 2026. The Council issued its opinion on 30 September 2026, without agreement between the social partners. After that still follow approval by the government, the vote in parliament and publication in the Belgian Official Gazette. Only with that publication does the obligation become legally fixed.

That does not mean you can sit back. The government has repeated the date several times and the direction is clear. It does mean that the date, the scope and the exceptions can still shift and that anyone telling you today that the details are settled is getting ahead of things.

What at the time of writing is certainly not settled are the minimum technical requirements and the sanction regime.

Does this apply to my company too?

The obligation targets employers, so companies with staff on the payroll. If you have no employees, nothing changes for you. If you work with self-employed subcontractors, the obligation applies to their employership and not to yours, though you will probably want to track their hours for other reasons.

No lower limit in headcount has been announced. A company with three people on the payroll falls under it just as much as one with three hundred. For small companies that is the most annoying part of the news: the administrative burden is relatively larger while the budget is smaller.

Which employees may fall outside

At employer level there is no exception. At employee level there is. The draft bill excludes categories whose working time is not measured or not determined in advance, or who set their own hours. According to the social secretariats that saw the draft, these are:

• employees in a leading position or a position of trust;
• sales representatives;
• homeworkers and teleworkers, both structural and occasional;
• mobile staff, meaning those who mainly work outside the fixed establishment and structurally travel to clients or intervention sites for it;
• family businesses in which only blood relatives and relatives by marriage work under the authority of father, mother or guardian.

For many SMEs that is no detail. An installation company with five technicians on the road and two people in the office looks at a completely different exercise if mobile staff falls outside the scope.

Just do not count on that list surviving. The unions objected to it during the advisory process, arguing that the European Court of Justice ruled in the Loredas judgment of 19 December 2024 that the registration duty applies to all employees, homeworkers included. An exclusion that contradicts that case law does not necessarily hold. As long as the advice of the National Labour Council and the final text are not there, this is an expectation and not a certainty.

Room is left to align the system with how a company works. For some organisations a digital system in which everyone clocks in and out is the logical choice. For others an arrangement suffices in which only the deviations from a fixed schedule are recorded. The latter is considerably lighter. It is worth checking whether your situation qualifies for it.

What does and does not count as valid registration

This is where most companies get it wrong. This is also where the costs sit.

A schedule is not a registration

Many companies have a planning tool or a schedule at their social secretariat and assume that covers them. It does not. A schedule says what someone would work. The law asks what someone has worked. A system that copies the hours automatically from the planning registers the planning and not the performance.

Concretely: if a technician was scheduled from 8 to 17 but stayed until 19 because of a breakdown, your system must be able to show 19. If it cannot, you are registering a fiction.

At the construction companies we guide we see hours entered on average three days late. On Friday the week gets reconstructed, mostly from memory and sometimes with help from the planning. That is exactly why filling in afterwards does not work: what ends up in the system is a memory of the planning and not a registration of what happened. Nobody notices the difference until the moment someone asks about it.

The three requirements from the judgment

Excel does not qualify

That is not an opinion and not a sales pitch either. It follows directly from what "reliable" means.

The explanation the social secretariats use is unambiguous: a system is objective and reliable when the registrations cannot be manually adjusted afterwards, are recorded automatically and are verifiable at an inspection. Those are three properties a spreadsheet by definition does not have.

A cell in Excel is designed to be overwritten. Whoever entered eight hours on 3 March and changes it to ten on 20 April leaves no trace whatsoever. There is no timestamp of the entry itself, only of the last time someone saved the file. There is no difference between what was registered and what was later made of it.

That is precisely the problem the legislator wants to solve. A registration that can be silently adjusted afterwards proves nothing. Then registering is pointless.

Mind the wording, because it matters in a discussion: Excel is not named in the law. Whoever points that out is technically right and materially wrong. The criterion is that the data cannot be changed unnoticed. Excel fails on that by design. The same goes for paper timesheets and for a shared Google Sheet.

Correcting is allowed, by the way. An employee who forgot to clock out must be able to fix that. The difference is that the correction stays visible: who changed what when and why. That is called an audit trail. It is the only thing that turns a registration into evidence.

The five-year retention period

Five years is long. It is also the point where loose files break down fastest, because in five years staff changes, laptops break and accounting packages get replaced.

So when choosing a system, think beyond the recording itself. Also ask:

• Where is the data stored and in which country?
• Can I export it if I change vendor?
• What happens to my history if I cancel the subscription?
• Who can access it and can that be traced afterwards?

Those last two questions are also GDPR questions. Working time data is personal data and with sickness or leave registration you even end up at health data. Stricter rules for access and retention apply there.

The transition arrangement: postponement, not cancellation

Whoever has nothing on 1 January 2027 gets until the end of the first quarter. That sounds more reassuring than it is, for two reasons.

First, three months is little when you still have to choose, purchase, set up and let your people get used to it. Introducing a system is for the most part not a technical project but a habit project.

Second, everyone then runs to the same vendors at the same time. The four months around the turn of the year will be the busiest in the existence of every time registration provider. Whoever decides in October gets attention. Whoever decides in February ends up on a waiting list.

Buy, have built or do nothing

There are three realistic routes. Which one is yours depends on how you work today and on what you want to do with those hours once they are recorded. Choosing the wrong route usually costs you more than the obligation itself.

1. A standard package

For most companies this is the right answer. It is also the fastest. If you recognise the following, you need not look further:

• your people work fixed hours, mostly at the same location;
• you want to record hours and do nothing further with them;
• your social secretariat already offers a module that connects to your payroll;
• a monthly amount per employee is no objection.

Officient, Protime and Shiftbase are known names in this segment. Your social secretariat almost certainly has one of its own. Look at that last one first, because an existing link with your payroll saves you the most work later.

2. Something built on how you work

This only becomes interesting when registration is not the goal but the starting point. Think of:

• hours that must be linked to sites, projects or files, because you want to use that link for post-calculation;
• a way of working that does not fit the boxes of a package and that you do not want to adapt to the software;
• the wish to expand later towards budget monitoring or project oversight without putting a second system next to it;
• a workforce that grows, making a price per user per month weigh heavily over time.

That last point is the little calculation that is rarely made. A subscription of 5 euros per employee per month costs 900 euros per year with fifteen people, every year again, with a price increase you can do nothing about. A one-off investment is higher but stops. Where the break-even point lies depends on your size and on how much functionality you need. That is exactly the kind of calculation you want to make beforehand instead of afterwards.

3. Change nothing

That option exists too, though you rarely hear it from someone with something to sell. If you work with a small team on fixed hours and you keep track today in a way that is objective, reliable and accessible, you are fine. Test your approach against the three requirements above before you purchase anything.

What you can do now

Four steps, in this order. The first two cost you nothing.

1. Write down how it goes today. Who notes what, where does it end up and who looks at it? At most companies this already proves harder to answer than expected. That answer determines the rest.
2. Test your current way against the three requirements. Objective, reliable, accessible. If you fail on one, you know what has to change.
3. Determine whether you only want to comply or also want to improve something. Whoever only wants to comply buys a package. Whoever wants to attach post-calculation or project oversight chooses differently.
4. Decide before November. Not because that is the deadline, but because after that you end up in the rush.

This page is kept up to date

The law has not been voted and the implementing decrees do not exist either. We follow this weekly and update this text as soon as anything changes about the date, the scope, the exceptions, the retention period or the sanctions. At the top you see when we last checked.

Is something wrong, or do you know something that should be here? Let us know and we will process it.

Sources: judgment of the European Court of Justice of 14 May 2019 in case C-55/18 (CCOO versus Deutsche Bank) · judgment of 19 December 2024 in case C-531/23 (Loredas) · federal budget agreement of 27 November 2025 · proposal for a resolution implementing the working time directive (Chamber, doc. 56K1353) · request for advice from the Minister of Work to the National Labour Council of 26 March 2026 on the draft bill · publications of the social secretariats and the FPS Employment, Labour and Social Dialogue.

This article is general information and no legal advice. For the application to your specific situation, consult your social secretariat or an employment lawyer.