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Mandatory time tracking in Belgium from 2027

As of January 1, 2027, all Belgian employers must have a system in place to register the working hours of their employees. This measure is part of the federal budget agreement and stems from European case law on working time.

Why is time tracking becoming mandatory?

The obligation follows a 2019 ruling by the European Court of Justice. In this Spanish case, the Court ruled that European working time regulations can only be enforced if working time is effectively measured. Each EU member state must ensure that employers implement an objective, reliable, and accessible system to record each employee's daily working hours.

The Belgian government is now implementing this requirement with the following objectives:

  • Worker protection: Accurate recording of overtime and rest periods.
  • Labor law compliance: Better oversight of maximum working hours.
  • Transparency: Clarity on hours worked for both employee and employer.
  • Fraud prevention: Combating undeclared work and social fraud.

Who does this apply to?

The registration requirement will apply to all employers in both public and private sectors. This means that large companies, SMEs, and small businesses alike must prepare.

Possible exemptions

European regulations allow for exemptions for certain categories of workers, such as:

  • Executives with autonomy over their working time
  • Sales representatives and field workers
  • Employees with flexible schedules who manage their own time

The specific exemptions for Belgium are yet to be determined.

What systems are permitted?

The government leaves the form of time registration flexible. Employers can choose from various solutions:

  • Digital time clocks or badge systems
  • Mobile apps for time tracking
  • Software integrations with existing HR systems
  • Manual registration via forms or spreadsheets

The system must be objective, reliable, and accessible to both the employer and the employee. Billing.eu.com will comply with all requirements of this new obligation in time.

Current situation in Belgium

Research by HR services group Liantis shows that time registration is currently mainly used by large companies:

  • 100+ employees: 76.99% use time registration
  • 50-99 employees: 54.26% use time registration
  • Fewer than 10 employees: less than 10% use time registration

For small businesses, the new legislation represents a significant adjustment.

Reactions from the field

Employer organizations have responded critically to the measure:

  • UNIZO calls it "an additional source of administrative burden" in a country with already strict working time regulations.
  • Voka speaks of "pure Kafka" and an "incomprehensible additional administrative burden."

However, others see benefits: time registration can help avoid disputes about hours worked and offers protection for both employer and employee.

Preparation

The obligation comes into effect on January 1, 2027. How can you prepare?

  1. Evaluate your current situation

    • Are you already using time registration?
    • Does your current system meet the requirements?

  2. Choose a suitable system

    • Compare different solutions (digital vs. manual)
    • Consider ease of use and integration with existing software

  3. Inform your employees

    • Communicate about the new requirement in a timely manner
    • Provide training on using the system

  4. Consult your social secretariat

    • They can advise on the best approach for your situation

Already using Billing.eu.com for your invoicing? Then you're all set! We will provide time tracking for all your connected employees in time.

Penalties for non-compliance

Employers who do not comply with the registration requirement may face fines and other sanctions. The exact amounts and penalties are yet to be established in the implementing regulations.

Summary

From January 1, 2027, time registration will be mandatory for all Belgian employers. The form is flexible (from digital time clocks to apps) but the system must be objective and reliable. Billing.eu.com will provide time registration that meets the requirements in time.

Have questions about how this affects your business? Contact your social secretariat or HR service provider for personalized advice.