Belgian transport companies invest heavily in tachograph compliance. The digital tacho records driving time, speed, rest periods, and activity modes, and transport managers know their download intervals and infringement rules well. But the tachograph has a gap that the NSSO regularly exploits during inspections: it records what happens behind the wheel, not the full working day. Loading at the depot before departure, waiting at a customer site, completing delivery paperwork, and driving the company car to a pickup point are all working time under Belgian and EU law. None of them appear in tachograph data. Here is how to close that gap with Suivo’s combined tachograph and workforce time registration solution.
What the tachograph does and does not cover
EU Regulation 561/2006 requires digital tachographs in most commercial vehicles over 3.5 tonnes used for road transport of goods or passengers. The tachograph records:
- Driving time: hours at the wheel.
- Rest periods: daily rest (minimum 11 hours, reducible to 9 hours three times per week) and weekly rest (minimum 45 hours).
- Other work: time the driver is not driving but is still on duty, for example sitting in the cab during loading.
- Availability: time when the driver is available but not required to be at their post, for example waiting for a ferry.
What it does not record:
- Time spent in the depot before departure (vehicle checks, briefing, paperwork).
- Time spent at a customer site waiting for unloading if the driver has left the cab.
- Administrative work completed in the office between runs.
- Any activity by the driver when they are not in a tachograph-equipped vehicle (for example, driving a van below 3.5 tonnes, which is common for last-mile delivery).
These uncovered hours are genuine working time under both Belgian law and EU Directive 2002/15 on the organisation of working time for persons performing mobile road transport activities.
EU Directive 2002/15: the working time rules that go beyond the tacho
Directive 2002/15 (implemented in Belgian law) sets maximum working time for road transport workers:
- Maximum 60 hours in a single week (provided the average over 4 months does not exceed 48 hours).
- Average 48 hours per week over a 4-month reference period.
- Night work: workers doing night transport (between 00:00 and 04:00 for goods transport) must not exceed 10 hours in any 24-hour period.
The tachograph captures driving hours but not the full working time picture needed to verify compliance with these limits. Belgian labour inspectors (SIOD/TSW) and NSSO auditors cross-reference tachograph data with time registration records to check whether workers consistently work beyond the directive’s limits. Without separate time registration, transport companies have no data to present for the non-driving portions of the working day.
When tachograph exemptions create a bigger gap
Not all transport work requires a tachograph. Common Belgian transport exemptions include:
- Vehicles used for short-distance distribution (often below 50 km from the operator’s base).
- Vehicles under 3.5 tonnes gross vehicle weight.
- Concrete mixers and construction material delivery vehicles (often exempt or partially exempt under Regulation 561/2006 Annex exceptions).
- Agricultural and forestry vehicles.
For these vehicle categories, there is no tachograph at all, yet the workers driving them are still entitled to working time protections and the employer still has NSSO declaration obligations. Without tachograph data as a baseline, time registration must come from somewhere else: either a manual timesheet system or a digital time registration platform.
Belgian companies in the concrete and building materials supply chain, such as ready-mix concrete plants delivering to construction sites across Flanders and Wallonia, frequently fall into this category. Their drivers may be out of scope for tachograph rules but still need accurate time records for payroll, social security, and audit purposes.
PC 140: the joint committee that governs transport working time
Belgian transport workers covered by Joint Committee 140 (road transport) have sector-specific collective agreements (CAOs) on working time, rest, overtime, and night work allowances. Key aspects relevant to time registration:
- Overtime threshold: normal working time in PC 140 is 38 hours per week. Hours above this trigger overtime pay at sector-agreed rates.
- Night work supplement: night transport workers are entitled to additional compensation; accurate start and end times are needed to determine which hours qualify.
- On-call and standby time: some transport workers are on call but not actively working; Belgian law and PC 140 have specific rules about how this time is counted and compensated.
None of this can be correctly calculated from tachograph data alone. A transport company that uses tachograph data as its only time record is almost certainly miscalculating pay for non-driving time, which creates both underpayment risk for workers and incorrect social security declarations.
Combining tachograph data and time registration
The practical solution for Belgian transport companies is to run a time registration system alongside tachograph data, not instead of it. The tachograph remains the authoritative record of driving time and compliance with Regulation 561/2006. The time registration platform captures the full working day from first clock-in to last clock-out, including depot time, waiting time, and any non-tachograph activity.
Suivo’s vehicle tracking solution integrates tachograph data (remote download via the remote tacho download solution) with the workforce time registration platform. This means:
- Driving time from the tachograph is automatically matched to the worker’s time record.
- Non-driving working time is captured via the time tracking solution on the driver’s mobile device.
- The combined record gives a complete picture of each driver’s working day for NSSO, Directive 2002/15, and PC 140 compliance.
See how Van Moer Logistics approached this for their trailer fleet in the Van Moer case study.
A practical checklist for Belgian transport companies
- Identify your tachograph scope: which vehicles are covered by Regulation 561/2006 and which are exempt.
- For all drivers: implement a digital clock-in and clock-out system for the full working day, not just drive time.
- For tachograph-equipped vehicles: integrate remote tacho download with your workforce management platform so driving time and total working time are visible in one report.
- Check PC 140 agreements: confirm which CAOs apply to your workforce and configure your system to flag when weekly or reference-period limits are approached.
- Keep records for 5 years: Directive 2002/15 requires records to be retained; 5 years covers both the NSSO audit window and most labour inspectorate investigations.
Ready to close the gap between tachograph and total working time?
Suivo helps Belgian transport companies combine tachograph data and workforce time registration into a single, audit-ready record, covering both Regulation 561/2006 and Directive 2002/15 compliance. See Suivo products or explore pricing.
