Mandatory time registration in 2027? The government's plans
Last updated: September 2026
"Do I need to buy a time clock by January 2027?" Employers ask us that regularly, ever since the government announced that recording working time would become mandatory. The short answer: no. The long answer needs a little more explanation, because the plans are clear, but the law does not exist yet.
The federal government wants every employer to record their employees' working time from 1 January 2027. Exactly how is not yet settled. What you can already do today, however, is.
In this article: what the government is planning, where the legislation stands at the end of September 2026, what your system must be able to do, who would fall outside the rule and how to prepare now.
In short: the government is planning mandatory time registration from 1 January 2027, with time until 31 March 2027 for companies that do not yet have a system. You need a system that is objective, reliable and accessible. A traditional time clock is not mandatory: an app or software can be enough. The law has not been published yet, so the details may still change.
What exactly is the government planning?
The government plans for every employer to have, from 1 January 2027, a system that records the hours worked by its employees. That system must be objective, reliable and accessible. Companies that still have nothing in place on that date would get until the end of the first quarter: from 1 April 2027, everyone would have to comply (Acerta, accessed 28 September 2026).
The decision was taken at the end of 2025, as part of the budget agreement. Securex and Liantis both confirm that the plans apply to all employers (Securex, Liantis, accessed 29 September 2026).
| Date | What would happen |
|---|---|
| 1 January 2027 | Start of mandatory time registration |
| 31 March 2027 | End of the transition period for companies without a system |
| 1 April 2027 | Every company must have a system |
Note the word would. Until the law is published, these remain the dates from the government's plans.
Where does the legislation stand today?
At our last check, at the end of September 2026, we found no published law introducing time registration. In May 2026, a preliminary draft bill was with the National Labour Council for an opinion. The Council of Ministers, the vote in the Chamber and publication in the Belgian Official Gazette still have to follow (Securex, accessed 29 September 2026).
The Law of 18 May 2026, which introduced a series of labour measures on 1 June, does not contain it (FPS Employment, accessed 28 September 2026).
What does that mean for you? That you can prepare for the principles, which are already clear, but that you had better wait for the final text for the details. So always check the date of the last update at the top of this article.
Why is this obligation coming?
Because Europe requires it. On 14 May 2019, the Court of Justice of the European Union delivered a judgment in case C-55/18 (CCOO v Deutsche Bank). Member States must require employers to set up a system that enables the duration of each worker's daily working time to be measured (Court of Justice, accessed 29 September 2026).
The Court derives this from the European Working Time Directive (2003/88/EC), which sets maximum working hours and minimum rest periods. Without such a system, according to the Court, it is impossible to establish objectively and reliably how many hours were worked, when, and how much overtime. With time registration from 2027, the government wants to comply with these European rules (Securex, accessed 29 September 2026).
Do you need to buy a time clock?
No. The government is asking for a system that is objective, reliable and accessible, not a specific device. Securex sums it up like this: "When we talk about the registration of working time, we do not necessarily mean time clock systems but rather a way to measure working time" (Securex, accessed 29 September 2026). According to Liantis, digital tools, apps or other registration technologies can also be enough.
What the system must be able to do
Under the current plans, the system must be able to show when and how long your employees work (Liantis, accessed 28 September 2026). That matches what the Court of Justice requires: measuring the daily working time of each worker.
It would be about the hours actually worked. A schedule that is automatically treated as worked is not enough (SD Worx, accessed 28 September 2026).
Which solutions qualify
Acerta and SD Worx point out that the plans leave room for manoeuvre. If you work with fixed schedules, it would even be enough to record only the deviations from the agreed schedule (Acerta, SD Worx, accessed 28 September 2026).
That is an important nuance if you fear extra paperwork. On that reading, a team that works from 9 to 5 every day does not have to enter everything again each day. But be careful: only the final law will say how far that flexibility goes.
Who does it apply to, and who falls outside it?
The plans apply to all employers, but not to all employees. According to Acerta and SD Worx, a few groups in the private sector would fall outside the obligation.
The planned exceptions
These are:
- employees in a family business;
- employees in a management role or a position of trust;
- sales representatives;
- homeworkers and teleworkers;
- mobile or travelling staff.
What the Court of Justice says
This is where it gets legal. The Court speaks of a system that measures the working time of each worker. Member States do define the practical arrangements themselves, however, and may take into account the specific features of a sector or of certain companies, including their size (Court of Justice, Securex, accessed 29 September 2026). Which exceptions Belgian law finally keeps, we will only read in the final text. So do not blindly count on your whole team being exempt.
What must you already record today?
Time registration is not entirely new territory. In a number of situations it is already mandatory today (Acerta, Liantis, accessed 28 September 2026):
- Flexitime schedules: if you let employees choose when they start and finish, you must use a time registration system.
- Part-time employees: every deviation from their normal schedule must be recorded in a deviation register. More on this in our article on part-time work.
- Certain sectors: some sectors impose their own form of time registration, such as the transport sector.
Do you already have such a system for part of your staff? Then you have a head start. The question then becomes mainly whether you can extend it to everyone.
What penalties are planned?
That is not yet known. None of the sources we consulted mentions penalties or amounts for the new obligation, and we have not yet found any legal text setting them. Only the final law will say what you risk.
What is certain: accurate time registration already protects you now. During an inspection by the social inspectorate or a dispute about overtime, you are in a stronger position with reliable records.
How do you prepare now?
You do not have to wait for the law to get started. The principles are already clear, and introducing a system takes time.
Step 1. Map out who works for you and on which schedule: fixed hours, rotating shifts, part-time, flexitime. That determines which system suits you.
Step 2. Check what you already have to record today, for flexitime schedules and part-timers. That is often the basis of your future system.
Step 3. Choose a solution that is objective, reliable and accessible: an app, software or a digital clocking system. Make sure it records the hours actually worked, not just the planned schedule.
Step 4. Link the registration to your payroll. The hours you record must also end up correctly in payroll. Our article on linking time registration to payroll explains how.
Step 5. Inform your employees in good time about how and when they record their hours, and keep track of the legislation. As soon as the final text is available, align your system with it.
Working with digital registration now also helps you avoid the classic errors that lead to disputes later. Which ones? Read our article on errors in time registration.
What employers should remember
- The government is planning an obligation from 1 January 2027, with time until 31 March 2027 for companies that do not yet have a system.
- The law has not yet been published. In May 2026 a preliminary draft was with the National Labour Council, and the details may still change.
- A time clock is not mandatory. The system would have to be objective, reliable and accessible; an app or software can be enough.
- Real hours, not a theoretical schedule. The system would have to show when and how long your employees actually work.
- Penalties are not yet known. Only the final law will say what you risk.
How Recruit helps you
Time registration and payroll belong together: what you record must be paid correctly. Recruit brings both together on one platform.
With Recruit:
- Clocking app - Your staff clock in and out via the Recruit clocking app, free for Android and iOS, or via the mobile website
- QR scan and geolocation - Clocking in via a mandatory QR scan, linked to the location
- Scheduling and hours in one system - Plan shifts and track hours worked in the same place
- Accurate payroll - Pay aligned with your Joint Committee
- Personal support 24/7 - A dedicated contact who knows your file and your sector
Try Recruit or contact our HR experts for tailored advice.
Frequently asked questions
Will a time clock be mandatory from 2027?
No. The government is asking for a system that is objective, reliable and accessible. That can be a time clock, but also an app, software or another digital system.
Is mandatory time registration already law?
Not yet. At our last check, at the end of September 2026, we found no published law. In May 2026 a preliminary draft was with the National Labour Council; the Council of Ministers, the Chamber and publication in the Belgian Official Gazette follow.
Does this also apply to small companies?
The plans refer to all employers, and the sources we consulted mention no exception for small companies. The Court of Justice does allow Member States to take the size of a company into account in the practical arrangements. The final law will say whether Belgium does so.
By when do I need to comply?
According to the plans, the obligation starts on 1 January 2027. Companies that do not yet have a system will have until 31 March 2027. From 1 April 2027, every company must have a system.
Do I have to record all hours every day?
Not necessarily. According to Acerta and SD Worx, the plans allow you to record only deviations if you work with fixed schedules. The system must still reflect the hours actually worked. The final law will spell this out.
The information in this article is provided for general guidance only and does not replace professional legal advice. Labour legislation changes regularly. Always consult the legislation in force or contact an HR expert for advice suited to your situation.