Objective
The record comes from something other than memory or good intentions. Someone reconstructing last week from their inbox is not measuring working time.
The legal obligation
Belgium is making working-time registration mandatory
Working-time registration and structured B2B e-invoicing are no longer optional for Belgian businesses. Tikkit gets you compliant before the deadline, without changing how your team works.
Where the file stands
Not law yet. Coming anyway.
The obligation was announced in the federal budget agreement of November 2025 and pushed by a Chamber resolution on 5 February 2026. The Minister of Labour sent a draft to the National Labour Council on 26 March 2026, where employers and unions did not reach agreement. Nothing is legally binding until a text is voted and published in the Belgian Official Gazette. But the direction has not moved since November 2025, and the target date is still 1 January 2027.
2027Working-time registration deadline
100%Of B2B invoices go digital via Peppol
MinutesTo produce an inspector export
How we got here
Seven years from a European ruling to a Belgian deadline
Belgium is the last major member state to act on a judgment handed down in 2019. That is why the runway is short.
The Court of Justice rules in CCOO
Case C-55/18: member states must oblige employers to set up an objective, reliable and accessible system measuring the daily working time of each worker. Most countries legislated. Belgium did not.
Loredas closes the escape routes
Case C-531/23: the Court confirms CCOO and holds that the duty covers every worker without exception. The case was about a domestic worker who could not prove her overtime because nobody had recorded it.
The federal budget agreement
Belgium announces a general registration duty for all employers, private and public, from 2027, including flexi-jobbers, students, extras and temporary staff.
Resolution in the Chamber
Document 56K1353/01. Majority MPs ask the government to anchor the measurement of working time in the Labour Act, leave employers free to choose the method, and avoid extra administrative load. A resolution is not binding.
Draft goes to the National Labour Council
No agreement between the social partners. Employers fear administrative burden and lost flexibility; unions call the proposed exclusions too wide and say they conflict with the European directive.
Target entry into force
Every employer records the daily working time of every employee, overtime included, in an objective, reliable and accessible system.
End of the transition window
The announced grace period for employers who still have to put a system in place runs out. On construction sites, registration moves from Check in at work to Check in and out at work: arrival, departure and rest breaks.
Reporting goes daily
LTDS becomes mandatory: wage and working-time data reported at least monthly and in daily detail, gradually replacing the quarterly DmfA. Both run in parallel through 2029; DmfA retires from 2030.
The four tests
What a system actually has to do
The wording comes straight from the Court of Justice and has survived every draft since. Each word is doing work.
Reliable
Hours actually worked, not hours planned. A system that fills itself in from the roster records the schedule and nothing else. Entries have to be traceable, and a correction has to look like a correction.
Accessible
The worker, their representatives and an inspector can all consult the data. Under the rules that already apply to part-time work, records are kept five years and union delegates have a right of access under CAO no. 5.
Daily, per worker
Start, end and breaks, per employee, per day, overtime included. That granularity is the whole point: it is what makes the 38-hour average week and the 11-hour daily rest checkable at all.
Scope
Who is covered, and what is still being argued about
The in-scope side is settled and broad. The carve-outs are the live part of the debate.
In scope
- Every employer, private and public, whatever the size
- Every sector, with no threshold and no small-business exemption
- Flexi-jobbers, students and extras, explicitly named
- Temporary and agency staff on your site
- Overtime, which has to be visible in the record, not derived later
Excluded in the current draft
- Positions of trust and management
- Home workers, teleworkers included
- Travelling staff who work away from a fixed workplace
- Workers in a family business under a parent or guardian
Treat these as unsettled. They are the most contested part of the draft: the unions argue they conflict with Directive 2003/88 and with Loredas, which found that excluding domestic workers was unlawful. If you plan for the exclusions and they narrow, you rebuild in 2027. If you plan without them, you are simply ready.
Already binding
Five obligations that don't wait for 2027
The general duty is new. Registration in Belgium is not, and this is where inspections already find gaps.
Variable part-time schedules
Workers get written, dated notice of their days and hours in advance. The notice stays consultable for as long as it runs, and is kept for a year after it expires.
Every deviation from a part-time schedule
Recorded at the moment work starts or ends: either in a reliable time-tracking system, kept five years and consultable by the worker and the inspectorate, or on the paper deviation register in the model set by the Royal Decree of 8 March 1990.
Sliding schedules
If you let staff work glijdende uren, a time-tracking system is a condition, not an option, and the arrangement belongs in your work regulations. Not having the system is a level-2 offence today.
Sector attendance registration
Checkinatwork on real-estate works from €500,000, ready-mixed concrete delivery, the meat sector, and cleaning on construction sites. Daily, before the person starts work.
Structured e-invoicing
Since 1 January 2026, Belgian VAT-registered businesses exchange B2B invoices as structured documents over Peppol under the Royal Decree of 29 July 2025. A PDF by email no longer counts. Different obligation, same instinct: structured data instead of paper.
What it costs to get wrong
The fine is the small part
Two numbers matter here, and the second one is bigger than the first.
| Level | Criminal fine | Administrative fine |
|---|---|---|
| Level 1 | None | €100 – €1,000 |
| Level 2 | €500 – €5,000 | €250 – €2,500 |
| Level 3 | €2,000 – €20,000 | €1,000 – €10,000 |
| Level 4 | €6,000 – €70,000 | €3,000 – €35,000 |
Amounts under article 101 of the Social Criminal Code, after the surcharge multiplier rose from eight to ten on 1 February 2026, a 25% increase on every band overnight. Level 4 also carries six months to three years' imprisonment. Where the Code says so explicitly the fine is multiplied by the number of workers concerned, capped at a hundred times the amount. Working-time offences sit at level 2 today; the level attached to the new general duty has not been set.
The presumption of full-time employment
Miss the part-time notices or leave the deviation register empty, and article 22ter of the NSSO Act of 27 June 1969 lets the authorities presume the worker was employed full-time, and claim social security contributions on that basis for the whole period. Compared with a level-2 fine, this is the exposure that actually hurts.
Registering too much is also a breach
On 6 September 2024 the Data Protection Authority fined a company €45,000 for clocking staff in with fingerprints. Biometrics are a special category of personal data, consent inside an employment relationship is almost never freely given, and the Authority pointed out that badges, cards and codes do the same job. Tikkit uses none of it: app session, PIN or a QR code at the door.
Tikkit against the requirement
Requirement by requirement
No interpretation, no hedging: this is what the software does about each line above.
| What is required | How Tikkit does it |
|---|---|
| An objective daily record per worker | Employees clock themselves in and out (app, browser, or a QR code at the door), and every event is stored with its own timestamp. |
| Hours worked, not hours planned | Planning lives apart from worked time and never writes into it. The two are compared side by side, per day and per week, and never merged. |
| Breaks recorded, not deducted | Break start and break end are their own events, so a half-hour lunch is something that happened rather than an assumption applied at the end of the month. |
| Overtime visible in the record | Overtime is stored as its own record with a status, keeping what was worked, what was approved and what was recovered distinguishable. |
| Deviations from part-time schedules | Planned versus worked per employee per day, so a deviation shows up on screen instead of on a paper register in a drawer. |
| Five-year retention | Records live in your own tenant, backed up, not on a terminal in a hallway or a laptop that walks out the door. |
| Accessible to the worker | Every employee sees their own hours, week totals, corrections and overtime balance in the app, in Dutch, French or English. |
| Accessible to the inspectorate | Day, week, month and year exports in a couple of minutes, per employee or per department. |
| No unnecessary personal data | No fingerprints, no face recognition. Location capture on QR clock-in is optional and off unless you switch it on. |
| Ready for daily reporting in 2028 | The data already sits at day level per worker, which is exactly the granularity LTDS will ask for. Nothing to reconstruct when the reporting changes. |
Straight answers
Six things employers keep asking
Mostly relief, occasionally not.
Do we have to install a punch clock?
No, and the government has said so explicitly. Any objective, reliable and accessible method qualifies: a badge, an app, software you already run. What matters is that the measurement exists and holds up when someone checks it.
Is a spreadsheet enough?
Almost never. A file everyone can edit afterwards fails the reliability test, and a folder on a shared drive fails accessibility. Paper lists and loose Excel files are precisely what this obligation was written to replace.
Can we just record the roster?
No. A system that fills itself in from the schedule has recorded the plan, not the work. Recording only the deviations from an agreed schedule can be enough (that is how part-time rules already work), but the deviations have to be genuine and entered when they happen.
Our people work from home.
The current draft excludes home workers and teleworkers, and that is one of the exclusions under the most pressure from the unions and from European case law. Plan as if it may not survive.
We're small. Does this really apply to us?
Yes. There is no headcount threshold and no small-business carve-out in anything announced so far, and flexi-jobbers, students and extras are named explicitly. A five-person restaurant is as much in scope as a factory.
What if someone forgets to clock out?
Retroactive registration is meant to stay possible; the point is not to punish a forgotten tap. In Tikkit the manager corrects the entry and the correction is visible as a correction, which is what an auditable system is supposed to look like.
Last reviewed 4 August 2026
Sources
Every figure on this page traces back to one of these. Where sources disagree, we say so above rather than picking the convenient one.
This page summarises public sources on a file that is still moving. It is information, not legal advice, so check with your social secretariat or your counsel before you build a policy on it.
- FPS Employment: Monitoring the performance of part-time workers
- Court of Justice: Loredas, C-531/23 (19 December 2024)
- Social Information and Investigation Service: sanction levels
- Data Protection Authority: biometrics in the workplace
- NSSO: Checkinatwork attendance registration
- Securex: Time registration mandatory from 2027
- SD Worx: 7 questions on mandatory working-time registration
- Partena Professional: resolution submitted to the Chamber
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