Mandatory working time registration from 1 January 2027

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Mandatory working time registration from 1 January 2027
The federal government provides, from 1 January 2027, for an obligation for companies to register the working time of their employees. The recent budget agreement does not yet contain a concrete implementation of this time-registration obligation. Nevertheless, companies can already prepare at this time and adapt their work regulations.

At present, according to Belgian law, there is no general obligation to register working hours. In a number of situations, the law does require the use of a system in which working time is recorded. Thus, registration is mandatory for flexible schedules. Also for part-time work all deviations from the normal schedule must be recorded and in some sectors the legislator also requires a type of time registration.  

The new measure from the budget agreement follows case law of the Court of Justice of the European Union in 2019 and 2024. In these judgments the Court rules that each Member State within the European Union must ensure that employers set up an objective, reliable and accessible system to record the daily working time of employees. The Court is of the opinion that the European Working Time Directive is enforceable only on the condition that working time is measured. The Brussels Labour Court already followed the case law of the Court of Justice in 2020.

If the federal government develops an obligation in line with the case law of the Court of Justice of the European Union, companies will be free to choose an objective, reliable and accessible working‑time registration system. It appears to be the federal government’s ambition to implement the time‑registration obligation as flexibly as possible and not to require companies to use a time clock. This is also evident from the resolution submitted to the Chamber on 5 February 2026. The legislator appears primarily to want to establish that employers must record working and rest times in such a way that monitoring compliance with the legislation is possible. It is by no means intended to subject employers to all manner of complex administrative requirements. 

Companies that do not yet have an objective, reliable and accessible working‑time registration system can already prepare for the upcoming obligation. We recommend that you evaluate your current time‑recording system in light of European case law and verify whether your work regulations mention this system.

How can BDO Advisory help? 

We can assist in drafting a proper work regulation or in reviewing it and, if necessary, amending existing work regulations. BDO supports companies in this process and ensures that everything runs smoothly, including, if necessary, with the trade unions. 

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