Does the 2027 time registration obligation apply to my business?

Yes. The obligation applies to every Belgian employer, private or public, regardless of headcount. Sector-specific derogations are being discussed, but the default rule is universal.

By when does my time registration system need to be ready?

By 1 January 2027. The exact technical requirements haven't been fully published yet, but the deadline itself is fixed.

Is a spreadsheet or paper sign-in sheet still allowed?

Almost certainly not. The system must be objective, reliable, and accessible — an honour-system spreadsheet or paper list can't be independently verified after the fact.

Do I need to use a specific system or technology?

No. The law doesn't mandate a specific technology. A digital time clock, RFID badges, an app, or a biometric system are all acceptable, as long as the result is objective and reliable.

How much does a time registration system cost for a KMO?

It depends on the vendor and the method chosen. Exalise currently runs a pilot programme with indicative per-employee pricing — get in touch for a concrete proposal for your team.

Belgium's 2027 Time Registration Law: What Every KMO Needs

If you run a small or medium business in Belgium, you’ve probably already heard the headline: from 1 January 2027, every employer — private or public, five employees or five hundred — will be legally required to keep an objective, reliable record of how many hours each employee actually works.

What you may not have heard is how little of the fine print is actually settled yet, and how much of the advice already circulating online is guessing at details the government hasn’t published. This post is our attempt to separate what’s confirmed from what isn’t, and to explain why we think most KMOs should start preparing now rather than waiting for the last piece of paperwork to land.

Where this obligation actually comes from

This isn’t a Belgian invention out of nowhere. It traces back to a 2019 ruling by the European Court of Justice, which found that without a system to measure daily working time, it’s effectively impossible to verify whether an employer is respecting maximum working hours and minimum rest periods — rights that are supposed to be guaranteed under EU law. Several member states have since translated that ruling into national obligations. Belgium is doing the same, with the deadline set for 1 January 2027.

What’s confirmed

A few things are already clear from the government’s own communication:

It applies to every employer, regardless of sector or headcount. There’s talk of sector-specific derogations similar to the ones that already exist for construction, cleaning, and meat processing — but the default is universal.
The system must be “objective, reliable, and accessible.” A paper sign-in sheet or an honour-system spreadsheet almost certainly won’t meet that bar going forward — there’s no way to independently verify either one after the fact.
You get to choose the method. The law doesn’t mandate a specific technology. A digital time clock, RFID badges, an app, or a biometric system are all explicitly mentioned as acceptable approaches, as long as the result is objective and reliable.
It covers everyone — full-time, part-time, flexible, remote, hybrid, and mobile staff all fall under the same requirement.

What isn’t decided yet

Here’s where a lot of the content already published by other vendors gets ahead of the facts. As of early 2026, the government still hasn’t finalised:

Exactly what data has to be recorded and for how long it must be retained.
What access rights employees and labour inspectors will have to the records.
The precise technical bar for “objective and reliable” — whether specific certifications or standards will apply.
Penalties for non-compliance.

We’d rather tell you honestly that these details are still pending than invent a compliance checklist we can’t back up. What we can tell you is that whatever the technical fine print ends up being, a system built around individual RFID badge taps, timestamped and stored automatically, with a full audit trail of every clock-in and clock-out, is about as close to “objective and reliable” as a record can get — and it’s a foundation you can adapt once the exact rules are published, rather than a system you have to rebuild from scratch.

Why this is harder for a KMO than it looks

Large companies already have HR departments, payroll software, and IT budgets built for exactly this kind of project. A business with 8, 20, or 40 employees usually doesn’t. The owner, or one person doing HR alongside three other jobs, is the one who’ll have to make this work — which means the system has to be genuinely simple to run, not just simple to install.

It also means the usual advice — “just buy an enterprise workforce management platform” — is bad advice for this segment. Those platforms are priced, configured, and supported for companies with dedicated HR teams. Onboarding one to track the hours of a 12-person bakery or workshop is like buying an industrial dishwasher for a home kitchen: technically it works, but you’ll spend more time and money fighting the tool than the problem it was meant to solve.

The opposite mistake is just as common: reaching for the cheapest possible punch-clock app because “it’s just clocking in and out.” Those tools usually can’t handle a part-time employee’s variable hours, someone on parental leave, or a public holiday override — and they rarely produce a report your accountant or payroll office can use without reformatting it by hand. You end up doing in a spreadsheet exactly what the tool was supposed to replace.

What we built instead

We built Exalise Time Management because we needed exactly this — not a scaled-down enterprise suite, not a bare-bones punch clock, but the specific set of features a business under 50 employees actually uses: RFID clock-in, real work schedules that account for part-time hours and leave, and a monthly overview built to hand straight to HR or payroll.

We didn’t just design it and ship it. We ran it ourselves for three months, with ten employees, at Esma NV — a real manufacturing business, not a demo environment. Esma’s team includes part-time staff and people on parental leave, so the schedule engine had to handle real exceptions from day one, not just a default nine-to-five. And at the end of each month, the business needed one clean report it could send straight to its HR office, not a spreadsheet someone had to rebuild by hand. That pilot is the reason the product looks the way it does today.

The result is a system where an employee taps an RFID badge to clock in or out — no PIN, no app, no login — and the record is timestamped, stored, and visible to management within a second. Schedules, overtime, absences, and late arrivals are calculated automatically. We’re still finishing the last pieces, which is why we’re rolling it out through a pilot programme first, with indicative per-employee pricing instead of a quote you have to wait on.

What to do now, not in December 2026

Every KMO that waits until the last quarter of 2026 to look for a system is going to be competing for the same installation slots, the same hardware lead times, and the same vendor attention as every other business doing the same thing at the same time. Getting a reader installed, badges issued, and staff onboarded takes very little time on its own — but it takes longer when everyone is trying to do it in the same six weeks.

If you already know you’ll need something by 2027, the cheapest and least stressful time to start is now, while it’s still a quiet decision rather than an urgent one.

Get started

Tell us how many people you employ and how you’re currently tracking hours — paper, spreadsheet, or nothing formal at all — and we’ll show you exactly how Time Management fits, what it costs for a business your size, and how quickly we can get a reader installed. No enterprise sales process, no quote you have to wait a week for.