Starting in 2027, working time recording will become mandatory in Belgium: every employer will need to be able to prove how many hours their employees actually work. The federal government is aiming for an entry into force on January 1, 2027, with full compliance required by April 1, 2027, at the latest.
In this guide, we distinguish between what is confirmed and what is still under discussion, and we detail what this mandatory time tracking means in practice for your teams, both in the office and in the field.
In brief
- Status: obligation decided and drafted in a preliminary bill, but not yet voted on as of this update.
- Target timeline: entry into force on January 1, 2027, with the system operational byApril 1, 2027.
- Who: all employers, both private and public, regardless of company size. Certain roles may be excluded.
- How: flexible format. The system must be objective and reliable; a time clock is not mandatory.
- Already confirmedOn construction sites, real-time IN and OUT clocking via Check In and Out at Work is becoming mandatory on April 1, 2027.
What is the current status of the law on working time recording?
The requirement was decided during the federal budget agreement at the end of 2025 and subsequently drafted in a preliminary bill by Minister of Employment David Clarinval. Here are the key stages:
The text still needs to be voted on and then published in the Belgian Official Gazette. The dates of January and April 2027 therefore remain policy objectives, but April 1, 2027, is the best target date for your preparations. The Partena Professional FAQ regularly provides updates on progress.
Why is clocking becoming mandatory?
The requirement stems from European law. In May 2019, in the CCOO case (C-55/18), the Court of Justice of the European Union ruled that rules on maximum working hours and rest periods only make sense if the time actually worked is measured. Each Member State must therefore implement an objective, reliable, and accessible system. The Court confirmed this position in December 2024 in the Loredas judgment.
Belgium had never transposed this rule in a general manner. It is doing so now, at a time when it is also relaxing working time regulations. More flexibility requires more traceability.
Who is affected by mandatory clocking?
The requirement applies to all employers, in both the private and public sectors, with no size threshold. An SME with five workers is affected just as much as a large company.
According to the preliminary draft, certain categories of workers would be excluded: management personnel and positions of trust, commercial representatives, teleworkers, and itinerant personnel, i.e., workers who regularly travel to clients or intervention sites.
Itinerant personnel: are your workers truly excluded?
This is the most sensitive issue for field-based companies, and the answer is far from simple.
- The definition remains vague. A worker who carries out several jobs a day for different clients fits the idea of mobile staff well. A worker assigned to the same site for several weeks does not.
- The exclusion is being challenged. Unions are opposed to it, and the text may still change before the vote.
- It does not remove your other obligations. Even if excluded from general registration, these workers must be paid for all hours worked, overtime caps remain in effect, and site attendance must still be declared.
- The burden of proof remains a significant risk. In the event of a dispute over overtime, an employer without a registration system will be in a weak position.
Our advice: do not rely on this exclusion for your mobile teams. Recording their hours as well protects you and simplifies payroll.
Is a time clock mandatory? What you will need to record
The actual duration of work
The system must establish the daily and weekly duration actually worked by each employee.
No, a time clock is not mandatory
Mobile app, badge, software, or terminal: no specific method is imposed, and no time clock is mandatory. UCM summarizes it as follows:
"Registration does not necessarily have to be electronic."
Source: UCM
In practice, a digital solution for recording working hours remains the easiest to keep up to date and to present in the event of an inspection.
Possibly, only deviations from the schedule
If a schedule is communicated in advance, recording deviations (lateness, overtime, early departure) might be sufficient. However, a schedule that simply reproduces planned hours without reflecting the hours actually worked will not be enough.
In compliance with GDPR
The retention period has not yet been set; a five-year period is often mentioned. For biometric time clocks, the Data Protection Authority imposes a strict framework. Always provide an alternative, such as a badge or an app.
Is your current working hours recording system sufficient?
Perhaps. An existing system can be kept if it records working time in an objective and reliable manner. Several sectors already have their own obligations, which remain in force:
Construction: April 1, 2027 is already confirmed
According to the RSZ/ONSS, every worker on the relevant construction sites will have to record their own arrival and departure in real time via Check In and Out at Work. We detail this change in our article Check-in@Work 2027: what changes for you. If you fall under Joint Committee 124, also consult our Joint Committee 124 guide.
What are the risks if you are not ready?
The specific penalties for the new obligation are not yet known. However, the Social Penal Code already sanctions certain failures, such as the lack of tracking for flexible working hours.
The most concrete risk already exists: being unable to prove hours worked. In 2020, the Brussels Labour Court ruled in favor of an employee who claimed 34 hours of overtime, because the employer did not have a recording system in place. Case law is not unanimous, but once the law is in effect, the absence of a system will be difficult to defend. Reliable recording therefore primarily protects the employer.
Increased flexibility makes this tracking all the more necessary. Since April 1, 2026, a worker can perform up to 360 voluntary overtime hours per year, 240 of which are net (see the FPS Employment). With the annualization of working time in the works, these tallies quickly become unmanageable in a spreadsheet.
Checklist: 6 steps to be ready before April 1, 2027
- Map out your teams(office-based, construction site, mobile, part-time) and note how their hours are tracked today.
- Check your current obligations: Checkinatwork, flexible hours, written agreements for voluntary overtime.
- Test the reliability of your data: do you record actual hours worked or only scheduled hours?
- Choose your tools by team: mobile app for the field, badge or terminal for the workshop.
- Prepare the GDPR and social aspects: inform your employees, consult your representative bodies, and update your work regulations.
- Link time tracking to payroll to avoid double entry for your payroll provider.
Will your current system hold up in 2027?
Let's review your needs together during a free demo.
How T-Report helps you comply with mandatory time tracking
T-Report is Belgian scheduling and time-tracking software designed for field teams:
- Reliable time tracking at the source, from the mobile app, a time clock or a smartwatch.
- Schedules and actual hours in a single tool with the Scheduling & Time Tracking module: discrepancies appear automatically.
- Integrated site declarations : Check-in@Work and Check-in/Out.
- Absences and leave in one place, with an export for your payroll provider.
This article is provided for informational purposes only and does not constitute legal advice. It will be updated as the text evolves.
Frequently asked questions about mandatory time tracking 2027
When does time tracking become mandatory in Belgium?
The government plans to make time tracking mandatory for all employers starting January 1, 2027, with full compliance required by April 1, 2027. As of this update, the legislation has not yet been passed.
Is a time clock mandatory?
No. There is no mandatory method: mobile apps, badges, software, or any other objective and reliable system will work. The recording does not even need to be electronic.
Are small businesses affected?
Yes. There is no size threshold: all private and public employers are covered.
Does this apply to technicians who visit customers on-site?
The preliminary draft plans to exclude mobile staff, but this exclusion is being challenged and its definition remains to be clarified. In any case, the employer must correctly pay for hours worked and comply with overtime limits.
Is recording overtime hours enough?
If a schedule is provided in advance, recording the deviations may be sufficient. The schedule alone, without the actual hours worked, will not be enough.
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