Mandatory Time Recording from 2027: What Does It Mean for Your Business?

As of 1 January 2027, all Belgian employers will be required to record the working time of their employees. This measure was announced by the federal government in its budget agreement concluded at the end of November 2025. What will change in practice, and how can your organisation prepare?

Why Is This New Obligation Being Introduced?

The measure is not a purely Belgian initiative. It stems from a European legal requirement. The Court of Justice of the European Union has ruled that Member States must require employers to implement a system capable of recording employees' daily working time in an objective, reliable and accessible manner. Without such a system, employees may find it difficult to enforce their rights relating to maximum working hours and minimum rest periods as protected by the Working Time Directive and the Charter of Fundamental Rights of the European Union.

In the absence of clear legislation, Belgium has seen diverging case law. Some labour courts have placed the burden of proof regarding unpaid overtime on employers who cannot produce reliable time records, while others have taken the view that it is for the legislator to establish such obligations and that employers should not be penalised for the absence of a legal framework. The forthcoming legislation aims to bring greater legal certainty and consistency.

What Will Change from 2027?

From 1 January 2027, employers are expected to have a time-recording system that meets the following requirements:

• Objective: it must accurately reflect time actually worked and prevent unilateral manipulation;

• Reliable: recorded data must be accurate and safeguarded against unauthorised alteration;

• Accessible: both employees and labour inspection authorities must be able to consult the recorded information.

It is important to note that the legislative framework is still under development. On 5 February 2026, a draft resolution was submitted to the Chamber of Representatives advocating maximum flexibility for employers and cautioning against the introduction of unnecessary administrative burdens. The precise rules, exemptions and sanctions will only become clear once the legislation has been formally adopted and published.

What Does This Mean for Employers?

The obligation does not necessarily imply a return to traditional clocking-in systems. Nor does it mean that all time elapsed between check-in and check-out will automatically qualify as working time or overtime requiring remuneration.

Employers will remain free to implement solutions that fit their operational reality. Depending on the organisation’s structure, this may involve a mobile time-registration application, badge-based access technology, workforce management software or another digital solution tailored to different employee groups, such as remote workers, field technicians, employees with fixed or variable workplaces, and staff working on client sites.

Nevertheless, the new requirement presents a broader cultural challenge. Many organisations have evolved towards performance-driven environments built on trust, autonomy and outcomes rather than hours worked. Mandatory time registration introduces a renewed focus on time input, which some may perceive as a step backwards. Employers will therefore need to strike a careful balance between regulatory compliance and maintaining employee engagement and trust.

At the same time, accurate time tracking can provide valuable insights. It can help address discussions regarding overtime, improve workforce planning, monitor workload levels and support employee wellbeing by promoting a healthier work-life balance.

Our Recommendation

Do not wait until the legislation is enacted before evaluating your approach to time recording. Consider which systems are already in place and identify any departments, functions or employee populations that may be particularly affected once objective time registration becomes mandatory.

Once the legal framework has been finalised, a crucial next step will be to align internal policies, procedures and documentation accordingly. This may include:

• updating employment regulations and workplace policies to reflect time-recording procedures and overtime arrangements;

• reviewing HR and payroll processes, including overtime approval workflows and payroll integration;

• ensuring that managers and employees clearly understand their respective responsibilities.

If you would like to assess the impact of this upcoming obligation on your organisation or begin preparing today, please do not hesitate to contact us.