Belgian legal framework
Working time recording in 2027: what has been announced
The federal government is preparing a general requirement to record working time. Here is what we know today, what is still open, and how a small business can prepare for it without rushing.
Updated on 18 October 2026 — The text has not been adopted yet. This page will be updated at each stage.
Summary
- A general requirement to record working time has been announced for all employers, including very small businesses.
- Timetable currently planned: entry into force on 1 January 2027, with a transition period until 31 March 2027.
- The text is a preliminary draft bill. It has been neither voted on nor published in the Belgian Official Gazette.
- The choice of system would be free: no time clock imposed, but recording must be objective, reliable and accessible.
- For fixed schedules, recording could be limited to deviations from the schedule.
Why record working time?
In 2019, the Court of Justice of the European Union ruled that Member States must require employers to set up a system for measuring the duration of each worker's daily working time (CCOO judgment, C-55/18, 14 May 2019). The aim is to make it possible to check compliance with the maximum working hours and rest periods laid down by Directive 2003/88/EC.
Belgium had not yet turned this requirement into a general obligation. Today, recording is only required in certain situations: part-time work with variable hours, certain sectors, certain types of employment status. The federal government now intends to make the principle general.
The timetable currently planned
- 14 May 2019
Judgment of the Court of Justice of the EU (CCOO, C-55/18).
- 5 February 2026
Motion for a resolution tabled in the Chamber (DOC 56 1353/001).
- 30 September 2026
Opinion No 2.499 of the National Labour Council on the preliminary draft bill, with no agreement between the social partners.
- Upcoming
Approval of the text by the government, vote in Parliament, publication in the Belgian Official Gazette.
- 1 January 2027
Entry into force currently planned.
- 31 March 2027
End of the announced transition period. A suitable system should be in place by 1 April 2027.
These dates are not final. In their opinion, the employers' organisations asked for a longer lead time, of at least one year after publication. Until the law is published, no date is legally binding.
Who would be concerned?
Concerned
In principle, all employers in the private and public sectors who employ staff, whatever their size. A business with two workers would therefore be covered in the same way as a large company.
Exclusions mentioned (not final)
- management and positions of trust;
- sales representatives;
- home workers and teleworkers;
- mobile workers.
The exact scope of these exclusions will depend on the final text. The same business could have some workers who are concerned and others who are not. Have your situation checked by your social secretariat.
What would have to be recorded, and how?
According to the preliminary draft as presented publicly, the employer would have to record, for each worker concerned, the working time actually performed, in an objective and reliable way. The system would also have to be accessible, in particular in the event of an inspection.
The choice of tool would be left to the employer: an app, software or even a manual record. No time clock would be imposed.
What could "accessible" mean? The final text will specify this. For a worker, in any case, it is reassuring to be able to view their hours and confirm them. In Cloketa, each worker sees their own hours worked and validates their statement every month, with a reservation if need be, before the employer closes the month. Validation requires a personal account: a worker who only clocks in at a clocking station can receive their statement as a PDF. This is a practical response to the accessibility requirement as announced, without prejudging the final text.
An important point for small businesses: when workers follow a known fixed or variable schedule, the employer could limit recording to deviations from that schedule, provided that the time actually worked can be deduced from it.
Still open Several points have not been publicly settled at this stage: how long data must be kept, workers' access to their own records, detailed recording of breaks, and penalties. Trade unions are calling for stricter requirements; employers for more flexibility.
Requirements that already exist and would not disappear
The general requirement would come on top of recording obligations already in force, which have their own rules and official tools.
Construction
Checkinatwork. Attendance must be declared every day on construction sites worth at least €500,000 excl. VAT. According to information published by Partena, recording entries and exits (check-in and check-out) on these sites would be postponed to 1 April 2027. Check your situation with your social secretariat.
Cleaning
Check In and Out at Work (NSSO). Since 1 September 2024, the start, end and breaks of cleaning activities must be recorded. Any thresholds and exceptions should be checked with your social secretariat.
Students and flexi-jobs
Work is covered by specific Dimona declarations, with their own rules on hours.
Variable part-time work
Deviations from the schedules of part-time workers with variable hours must already be recorded.
Cloketa does not replace Checkinatwork, Check In and Out at Work, Dimona or any other official declaration. It organises the internal recording of working time.
How to prepare without waiting until the last minute
Take stock
Who works a fixed schedule? Who has variable hours, split shifts, work at customers' premises? Also note who manages hours today, and how.
Choose a method for each profile
For a fixed schedule, recording deviations only could be enough. For days that vary, actual clocking is more reliable.
Decide who approves what
Who corrects a forgotten clocking? Who accepts an extra hour? A simple rule avoids discussions at the end of the month.
Inform your team and your social secretariat
Workers must be informed about the system and about how their data is processed. Depending on your situation, your work rules may need to be adapted and the consultation bodies consulted.
Test before the deadline
A few weeks of trial are enough to fine-tune schedules, breaks and habits before it becomes mandatory.
What Cloketa does, and what it does not do
What Cloketa does
- record working time through actual clocking or an automatic schedule, handling only the deviations;
- keep a record of corrections: original value, reason, author, decision;
- produce reports by worker and by period, and an inspection export with integrity check;
- give each worker access to their own hours worked, and have them validate their statement every month;
- close each month: a signed inspection file for the month is generated automatically (to download: it is kept for the duration of the contract, up to 5 years), and the payroll export can be downloaded for your social secretariat;
- follow how the text evolves and adapt the software once it is adopted.
What Cloketa does not do
- provide legal or HR advice;
- replace Checkinatwork, Check In and Out at Work, Dimona, payroll or your social secretariat;
- guarantee that a record will be accepted during an inspection;
- decide for you who is covered by the requirement.
Frequently asked questions about the 2027 requirement
Is recording working time already compulsory?
Not yet in general. An obligation has been announced for 1 January 2027, but the text is a preliminary draft bill, neither adopted nor published.
Read the full answer : Is recording working time already compulsory?
What if the 2027 law requires something Cloketa cannot do?
If Cloketa cannot reasonably be adapted to an essential legal requirement, you can terminate free of charge and be refunded pro rata.
Read the full answer : What if the 2027 law requires something Cloketa cannot do?
Does Cloketa guarantee that my company will meet its obligations?
No. Cloketa is a working time recording tool. Meeting your obligations as an employer remains your responsibility.
Read the full answer : Does Cloketa guarantee that my company will meet its obligations?
Will a time clock have to be installed?
No, according to what has been announced: employers would be free to choose their system, as long as it is objective, reliable and accessible. No physical time clock would be required.
Read the full answer : Will a time clock have to be installed?
What do I need to do before rolling out Cloketa in my company?
Inform your workers, consult the staff representative bodies if you have any and, where necessary, amend your work regulations. Your social secretariat can guide you.
Read the full answer : What do I need to do before rolling out Cloketa in my company?
Does Cloketa replace my social secretariat, my payroll, Dimona or Checkinatwork?
No. Cloketa is not an official application, a social secretariat or payroll software. It does not make any declarations on your behalf.
Sources
- National Labour Council — Opinion No 2.499 of 30 September 2026 (opens in a new window) (in French)
- Chamber of Representatives — Motion for a resolution DOC 56 1353/001 (5 February 2026) (opens in a new window) (in French and Dutch)
- Directive 2003/88/EC concerning certain aspects of the organisation of working time (opens in a new window) (eur-lex.europa.eu)
- Court of Justice of the EU — Judgment of 14 May 2019, CCOO, C-55/18 (opens in a new window) (curia.europa.eu)
- Social security — Checkinatwork and Check In and Out at Work (opens in a new window) (socialsecurity.be)
- Partena Professional — postponement of attendance recording on construction sites to 1 April 2027
Free trial
Prepare calmly, ahead of the deadline
Try Cloketa with your team for 14 days and see which method suits each person.
Important information Cloketa is a working time recording tool. It does not provide legal or HR advice and does not replace any official declaration or application. Each employer remains responsible for their own obligations: if in doubt, consult your social secretariat or an adviser. The information on this page reflects the status of the draft on the update date shown. It may change before the text is adopted.