From 2027, every minute counts: mandatory time registration for every Belgian company

Current situation

Currently, there are already some obligations regarding time registration, but only for specific working arrangements or certain categories of employees. A general obligation for all companies is not yet part of Belgian labour law.

European pressure prompts Belgium to take action

The discussion about a general obligation originated in a 2019 ruling by the European Court of Justice. It ruled that European rules on working time are only enforceable if working time is recorded objectively, reliably and accessibly.

A recent ruling by the Court reinforced this pressure, meaning that Belgium can no longer postpone the introduction of such an obligation. The government therefore considers a legal obligation to be inevitable.

No traditional time clock, but a flexible solution

Although the new measure imposes a general obligation, there is still room for flexibility. Companies do not have to resort to the traditional time clock. Digital applications, mobile apps or even retroactive recording are also sufficient.

Nevertheless, this obligation conflicts somewhat with recent reforms on working hours that were intended to make the labour market more flexible, such as:

• the abolition of the obligation to include all work schedules in the employment regulations;

• the abolition of the minimum weekly working hours;

• the relaxation of the rules on night work;

• the extension of the number of voluntary overtime hours.

At first glance, mandatory time registration seems to be at odds with this flexibility. However, a comprehensive registration system also has advantages. It provides legal certainty during inspections, makes working hours more transparent, prevents discussions about overtime and contributes to more efficient payroll administration. Its introduction will require effort on the part of some companies, but at the same time it will offer opportunities to optimise internal organisation.

Practical tips: what can you do today?

Although the concrete legislation is still pending, it is advisable to start working now on a future-proof time registration policy.

• Assess the current situation

  • What tools are already in use today (e.g. Excel, planning software, badge systems, etc.)?

  • Which functions or teams already record hours, and which do not?

• Identify risks and pain points

  • Are there departments where overtime could give rise to discussion?

  • Are there any roles with a high degree of flexibility (e.g. working from home, variable hours) that make registration more challenging?

• Evaluate digital alternatives

  • Explore tools that are scalable and integrate with payroll processing (HRIS systems);

  • Ensure ease of use for both employees and managers;

  • Check which solutions meet European requirements for reliability and accessibility.

• Conduct a cost-benefit analysis

  • What is the cost of implementing a new system?

  • What are the benefits (e.g. time savings, fewer discussions, better planning)?

• Involve social partners

  • Inform internal consultative bodies (Committee for Prevention and Protection at Work, Works Council) about the obligation;

  • Gather feedback on workability and desired functionalities.

• Draw up basic internal procedures

  • Consider agreements on working from home, variable working hours, project work, company cars, etc.

  • Create a first draft of a policy on time registration.

• Test & train

  • Let managers gain experience with registration and follow-up;

  • A pilot project can reveal any teething problems before the policy becomes mandatory.

Conclusion

It is essential for employers to develop a comprehensive and workable time registration system in good time. Those who take the right steps today will not only be able to ensure smooth implementation, but also efficiently tackle the legal and organisational challenges that will inevitably arise.

Our specialists in HR and social-legal advice are happy to support you in:

• choosing a compliant registration system;

• drawing up policies and procedures;

• social dialogue and implementation processes.

Please note: this information is subject to the official legal texts.