What is the 2027 time registration obligation?
The 2027 time registration obligation is a new Belgian law requiring every employer to use an objective, reliable, and accessible system to record how many hours each employee actually works. It replaces the current situation where many SMEs rely on paper attendance sheets, verbal agreements, or an Excel file updated by hand every month.
In practice, this means you'll need a system — such as time registration software — that automatically and verifiably records when an employee starts and stops working, before 1 January 2027.
Why is this becoming mandatory?
This obligation did not appear 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 is practically impossible to verify whether an employer respects maximum working hours and minimum rest periods. Several EU member states have since converted that ruling into national law. Belgium is now following, with 1 January 2027 as the deadline.
Who does it apply to?
- Every Belgian employer, private or public — regardless of sector.
- Every company size: there is no minimum of, say, 10 or 50 employees.
- Full-time, part-time, flexible, remote, hybrid, and mobile employees all fall under the same rule.
- Sector-specific exceptions are under discussion, similar to existing rules in construction, cleaning, and meat processing — but the default rule is universal.
What's confirmed, what isn't yet
Confirmed
- ✓Applies to every employer, regardless of sector or size
- ✓The system must be objective, reliable, and accessible
- ✓No mandated technology — you choose the method
- ✓Deadline: 1 January 2027
Not yet decided
- ?The exact data to be retained, and for how long
- ?Access rights for employees and labour inspectors
- ?The technical bar for "objective and reliable"
- ?Penalties for non-compliance
Does Excel or a paper list comply?
Almost certainly not. An Excel file or paper attendance list is filled in by hand and can't be independently verified after the fact — which is exactly what "objective and reliable" is designed to rule out.
Read the full breakdown: does Excel comply with the law?How to prepare your SME
- 1
Map out how you currently register hours — paper, Excel, or not formally at all.
- 2
Choose a method that fits your size: an RFID badge, digital punch clock, or webapp — not necessarily an enterprise HR suite.
- 3
Make sure part-time hours, leave, and exceptions are handled correctly — this is where most basic punch-clock apps fall short.
- 4
Test the system well before 1 January 2027 — whoever waits until the last quarter of 2026 will be competing with every other company for the same installation slots.
- 5
Make sure there's a monthly report your accountant or payroll office can use directly.