Brussels, 24 September, (Brussels Morning Newspaper) – Belgian employers could face a general requirement to record employees’ daily and weekly working time from 1 January 2027 under legislation currently being discussed. The proposed Belgium working hours reform would cover most public and private employers and require records that objectively and reliably establish how long employees work.
Working-time proposal remains under discussion
The federal government has committed to introducing broader working-time registration in 2027. Employment Minister David Clarinval’s official policy announcement says that all employers will need a system for recording working time that is “simple and flexible”.
However, the latest guidance from Belgian business organisation UCM makes an important distinction: the measure remains part of a preliminary draft law that is still under discussion. The precise legal requirements therefore depend on the final legislation.
If adopted in its current form, the obligation would start on 1 January 2027. Employers without a compliant system would have until the end of the first quarter of 2027 to adapt.
Employers could choose how hours are recorded
The proposal does not prescribe a single technological solution.
According to UCM’s current assessment, working-time registration would not necessarily have to be electronic. Existing systems could remain in use if they satisfy the future law’s requirements for objective and reliable measurement.
Employers with predetermined schedules could potentially record only departures from those schedules. Existing sectoral timesheets and records already required for certain variable or part-time arrangements are among the examples that could meet the proposed standard.
The system would measure both daily and weekly hours, providing evidence relevant to schedules, rest periods and overtime.
European rulings underpin Belgian changes
The Belgium working hours proposal follows Court of Justice of the European Union case law requiring member states to ensure that employers can measure employees’ working time.
UCM says the purpose is to bring Belgian legislation into line with European jurisprudence requiring a system capable of measuring each employee’s daily and weekly working time.
The European standard is significant because working-time protections are difficult to enforce without reliable evidence of the hours employees actually perform.
Some workers could be excluded
The proposed rules are broad but not necessarily universal.
UCM says the current draft covers employers in both public and private sectors but envisages exceptions for certain categories, including managerial staff, sales representatives and some mobile workers. Those exemptions remain subject to the final legislation.
Businesses have time to assess existing systems
For employers, the immediate task is to determine whether existing payroll, scheduling and attendance arrangements could satisfy the proposed requirements.
UCM’s latest advice stresses that the final rules still need clarification and says businesses can already examine their organisation and HR processes while awaiting the completed framework.
Final legislation will set the requirements
The next key development will be adoption of the legislation and confirmation of its final scope.
The government’s stated objective is working-time registration from 2027, but the current proposal should not yet be presented as an unconditional legal requirement. The final text will determine exactly which employers and workers are covered and what records businesses must maintain.
