What’s changing?
Today there is no general obligation in Belgium to record working time, only in specific cases such as flexible working hours. The federal government wants to change that: under the current plans, from 1 January 2027 every employer must record the daily and weekly working time of their employees. Employers without a system by then get until 1 April 2027.
It isn’t law yet. The government submitted a preliminary draft to the National Labour Council, which gave its opinion on 30 September 2026 without agreement between employers and unions. The government and Parliament still have to approve the bill, so details may still change.
Why is this happening?
In 2019, the Court of Justice of the European Union ruled that the European Working Time Directive (2003/88) can only be enforced if employers actually record working time. After all, maximum working hours, rest periods and overtime can’t be checked without figures. Belgium is now putting that ruling into practice.
What must the system be able to do?
A traditional time clock is not required. A digital tool is enough, as long as it meets three conditions:
The system has to show how long each employee worked per day and per week. For employees on a fixed schedule, the draft allows you to record only the deviations, as long as the actual hours can be derived. The draft doesn’t yet say whether breaks must be shown separately. Loose paper lists or a spreadsheet that anyone can edit will struggle to meet these requirements.
Who does it apply to?
All employers, large and small, in both the private and the public sector. So if you employ even one person, it applies to you too.
Not every employee is covered. The draft excludes managers, employees in positions of trust, teleworkers and mobile staff. That list isn’t final yet.
How does Flexance help?
Your employees record their day and breaks on their phone or in the browser: in the office, in the workshop or on site. You can change a time afterwards, but always with a reason, and every change stays visible. You export the overviews for your payroll provider or for an inspection. Want to know what each project costs later on? Switch to the Basic plan.
The legislation is still being drafted and details may change. This page is not legal advice; if in doubt, ask your payroll provider (sociaal secretariaat / secrétariat social). We will update this guide as soon as the final text is known.