Mandatory working-time recording in Belgium from 2027: what employers need to know
Status as of 22 October 2026. We will update this page once the law is voted and published.
Belgium plans to make working-time recording mandatory for every employer. A draft bill by labour minister David Clarinval adds a new article 38quinquies to the Labour Act (Arbeidswet): employers must record each employee’s actual daily and weekly working time objectively and reliably. The planned start is 1 January 2027, with a working system required by 1 April 2027. The text has not been voted yet: the National Labour Council’s advice of 30 September 2026 was divided, and the government and parliament still have to decide.
Where does the obligation come from?
On 14 May 2019 the Court of Justice of the European Union ruled in CCOO (C-55/18) that member states must require employers to set up an objective, reliable and accessible system measuring each worker’s daily working time. Belgium announced the general obligation in its budget agreement of late November 2025; the minister requested the National Labour Council’s advice on 26 March 2026, and advice no. 2.499 followed on 30 September 2026 without agreement between employers and unions.
What has to be recorded?
- The actual time worked, per day and per week, for every employee.
- In a way that is objective and reliable — data that cannot simply be changed unilaterally.
- Accessible to the employee and to labour inspectors.
- Employers with a fixed or variable schedule may record only the deviations from it, provided actual working time can be derived. A schedule showing planned hours alone is not enough.
- Free choice of system: software, a badge, an app — a classic time clock is not a legal requirement.
Who is covered, who is excluded?
Private and public employers alike, regardless of sector or size. The draft excludes managers, employees in positions of trust, teleworkers and travelling staff. Unions want those exclusions removed, a record of breaks and ten-year retention; employers want more time (at least a year after publication) and recognition of existing records such as Dimona. Retention is not fixed yet; payroll providers expect five years, in line with other social documents.
What it means for hospitality
Belgian restaurants already record time in three ways, and those stay in place: attendance registration through the registered cash register system (GKS) — GKS 2.0 is mandatory since 1 July 2026 — Dimona declarations (per day with start and end time for occasional workers and flexi-jobs), and the deviation document for part-time staff. The new rule adds a general record of actual working time for every employee on top. The Dutch guide Urenregistratie in de horeca compares all four.
How Cilurzo Planning helps
Cilurzo Planning is staff scheduling and time recording built for Belgian hospitality teams, and records time the way the draft requires:
- Objective — every employee clocks in with a personal code on the venue’s tablet, optionally with a location check.
- Reliable — the raw clock-in is always kept next to any rounded time, and every correction is logged under the name of whoever made it.
- Accessible — employees see their own worked hours in their login; you export them per period for Partena, SD Worx, Acerta or Securex.
- Rota plus deviations — the published rota is the baseline, actual time sits next to it.
It does not replace the GKS cash register or Dimona declarations; it is the time record next to them.
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Frequently asked questions
Is working-time recording mandatory in Belgium from 2027?
That is the government’s plan: a draft bill requires every employer to record working time objectively and reliably from 1 January 2027, with 1 April 2027 as the deadline for a working system. As of 22 October 2026 it has not been voted and may still change.
Do I need a time clock?
No. The draft leaves the choice of system to the employer, as long as it records actual daily and weekly working time objectively and reliably.
Is a staff rota enough?
Not on its own. You may start from a fixed or variable schedule and record only the deviations, but a schedule with planned hours only does not meet the requirement.
Does it replace the GKS attendance registration in hospitality?
No. As far as is known, the GKS attendance registration, Dimona declarations and the part-time deviation document all remain in force alongside the new obligation.
Sources
- Court of Justice of the EU, judgment C-55/18 (CCOO), 14 May 2019 — curia.europa.eu
- KMO Partners on the draft bill and National Labour Council advice no. 2.499 (7 October 2026, Dutch) — kmo.partners
- Partena Professional FAQ (Dutch) — legalnews.be
- Beci, “Working time: mandatory time recording from 2027” — beci.be
This page is for information only and is not legal advice. Dutch version: Verplichte tijdsregistratie vanaf 2027.