From 1 January 2027, virtually every Belgian employer will have to record their people's working time. Not as a paper formality, but in a system that is objective, reliable and accessible. This guide breaks down where the obligation comes from, who it applies to, and the six requirements your registration has to meet.
This post summarises the EU Working Time Directive in plain language. It is not legal advice — have all information verified by your legal partner or payroll provider.
The European Working Time Directive (2003/88/EC) has been around for more than twenty years. It sets out how many hours may be worked per week at most, how much daily and weekly rest a worker is entitled to, and what protection applies to night work. Solid rights on paper — but rights you can only invoke if you can demonstrate how much you actually worked.
That was exactly where it broke down. In 2019, the Court of Justice of the European Union considered a Spanish case in which a trade union had taken the bank employing its members to court: that bank recorded only absences, never hours worked. The Court held that without objective registration, a worker is effectively powerless. No figures, no proof; no proof, no enforceable right.
That judgment put the ball in the Member States' court. Some countries adapted their legislation fairly quickly; Belgium did so only partially for a long time, with obligations limited to specific situations such as flexible working hours, part-time deviations and a handful of sectors. The federal government is now extending that line into a general obligation. Hence the date of 1 January 2027.
The starting point is broad: all employers, regardless of sector or size. Whether you are a consultancy with eighty consultants, an installation business with fifteen technicians on the road, or a non-profit with three staff — you fall under the rules. Both the private and the public sector are in scope.
There is, however, a set of exceptions in play. They largely mirror the categories that already fall outside the classic working-time rules today:
For some employers this is not news at all. Anyone working with flexible working hours has needed a registration system since 1 July 2024 — and enforcement there has tightened since. Anyone employing part-time workers has kept a deviation register for longer still. And in the cleaning sector, electronic attendance registration has applied since 1 January 2025. The transport sector has had its own regime for decades.
What 2027 changes is that the exception becomes the rule. Recording is no longer something you do because you run a particular kind of schedule, but because you employ people.
The Court of Justice spoke of a system that is objective, reliable and accessible. Those three words sound abstract, but they have very concrete consequences for what your registration looks like. Below we translate them — together with the practical obligations that come with them in the Belgian context — into six requirements. Work through them one by one against your current approach. Every requirement you cannot tick off with a clear conscience is work to do.
You record time worked. Not the time that was scheduled.
This is the requirement most businesses underestimate. A schedule is an agreement: it says what you expect. Registration is a finding: it says what actually happened. A system that automatically writes 8 hours per working day into your administration every month records nothing — it simply repeats your planning.
Objective means the measurement is independent of whoever has a stake in it. Not the worker's recollection on the last day of the month, not the manager's estimate, not the schedule sitting in the HR department. The registration has to reflect reality, including the days on which that reality departed from the schedule.
What goes in has to be correct — and can't quietly shift afterwards.
Reliability is about the quality of the capture itself. Data has to be correct, it has to arrive complete, and it must not be able to change unnoticed. A shared Excel file on a network drive fails on all three counts: anyone can overwrite, formulas break, and nobody notices.
Reliable also means recorded close to the moment. The longer the gap between the work and the registration, the more you end up reconstructing. A team that fills in weekly delivers figures considerably closer to the truth than a team trying, on the third of the following month, to remember six weeks of work.
Every change tells you who made it, what changed and when.
Corrections are part of the deal. Someone forgets to enter a day, a manager spots that work was booked to the wrong project, a leave day was recorded incorrectly. That is normal. What is not normal is that such a correction leaves no trace.
An auditable system keeps the history. For every change you see the old value, the new value, the author and the timestamp. That protects two parties at once. The worker, because their hours cannot be quietly trimmed after the fact. And the employer, because in a dispute or an inspection you don't have to rely on what someone believes they remember — you simply show the log.
Workers must be able to view their own hours. At any time.
This is the requirement most often overlooked, and at the same time the one that follows most clearly from the European judgment. Registration exists to protect the worker. A system only the HR department can get into does not do that: you cannot invoke your rights on the basis of figures you never get to see.
Accessibility operates at three levels. The worker must be able to consult and check their own recorded time. The employer must be able to report on it. And the labour inspectorate must be able to obtain the data when it asks — within a reasonable time, in a readable form.
Start, end, breaks, overtime, night work, deviations. The whole picture.
The registration has to make it possible to check whether the working-time rules were respected. That is also the yardstick for completeness: can someone establish, on the basis of your data, that the maximum weekly working time, the daily and weekly rest periods and the night-work rules were observed? If not, you are recording too little.
Concretely, that means at minimum the start and end time of the working day, the total time actually worked, and the deviations from the agreed schedule. Exactly how breaks will be treated, and what applies to travel, on-call duty and remote work, are among the points the implementing texts still have to clarify.
Keep it for years, and still collect no more than you need.
Recording is half the job. The data also has to last: current communications point to a retention period of five years. That means you are making a decision today about data you will still need to be able to produce in 2032 — including for people who moved on long ago.
And that brings in the other half. Working-time data is personal data. The GDPR asks that you collect no more than necessary, that you limit access to those who genuinely need it, and that you erase the data once the period has expired. The duty to retain and the duty to minimise sit alongside each other, not in opposition.
The concrete sanctions regime will be set out in the implementing legislation. But the direction is clear, and it can be inferred from how existing registration obligations are already enforced today: missing or deficient registration leads to findings by the social inspectorate, with administrative or criminal fines as a result.
The least-discussed risk may well be the biggest: your evidentiary position. In a dispute over overtime, in a conflict following a dismissal, or in a claim before the labour court, everything turns on who can demonstrate what was worked. Without reliable registration you arrive at that table empty-handed — and that rarely works out in your favour.
You have less than a year. The rollout also touches more processes than you might think at first glance. A workable order:
The general obligation takes effect on 1 January 2027. Current communications also mention a transition period until 31 March 2027 to get your system operational. Certain situations — such as flexible working hours since 1 July 2024, or the cleaning sector since 1 January 2025 — are already subject to a registration obligation today.
No. The legislation does not prescribe any specific technology. Badges, a PIN code on a kiosk, a mobile app or a web application are all acceptable, as long as the system is objective, reliable and accessible and accurately reflects the time worked.
In practice, rarely. A spreadsheet can store figures, but it does not show who changed a value or when, and it does not protect the data against unnoticed edits. On the reliability and auditability requirements, Excel almost always comes up short.
Exceptions for home workers and remote workers are part of the discussions, but the precise scope around structural and occasional remote work was not yet final in August 2026. For now, do not assume hybrid workers automatically fall outside the rules.
Current communications point to a retention period of five years. Because this is personal data, the GDPR applies alongside it: limit access to those who genuinely need the data, collect no more than necessary, and erase it once the period has expired.
The concrete sanctions will be set out in the implementing legislation, but existing registration obligations are already enforced today with administrative and criminal fines. At least as important is your evidentiary position: in a dispute over overtime or in proceedings before the labour court, you are in a weak position without registration.
This guide starts from the European source texts: the Working Time Directive and the Court of Justice judgment that created the registration obligation for Member States.
This blog post is a summary and interpretation of the European Working Time Directive and the related case law, written for a general audience. It is not legal advice and not a complete rendering of the legislation. The Belgian implementing texts were moreover still in preparation in August 2026, so details may change. Have all information on this page verified by your payroll provider, your legal partner or a lawyer before basing decisions on it. Tito accepts no liability for decisions taken on the basis of this text.
We make Tito for service businesses that have kept their hours in spreadsheets until now. Registration per employee and per day, an audit trail that keeps every change with who, what and when, PDF and CSV exports, and an auto-fill that completes a whole month in seconds — because a system that costs too much time doesn't produce reliable data.
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