Is time registration mandatory in Belgium from 2027? What the law says, and whether you need a prikklok

Last updated: 5 October 2026. We check the status of the law at the start of every month and update this page when it changes.

Short answer: not yet. As of 5 October 2026, Belgium has no general law that makes time registration (tijdsregistratie, enregistrement du temps de travail) mandatory. The government plans one from 1 January 2027, with a transition period to 31 March 2027, but the text is still a draft law. When it comes, it will not require a prikklok or pointeuse (time clock). It asks for a system that records working time objectively and reliably. Separately, Check in and out at work (CIAO) for construction and ready-mix delivery is already law and, according to the RSZ, starts on 1 April 2027.

Suivo’s time tracking software and Check in and out at work solution cover the day-to-day registration. This page explains what is law, what is planned, and how to prepare without guessing.

Where does the law stand today?

How we got here:

• May 2019: in case C-55/18, the Court of Justice of the EU ruled that Member States must require “an objective, reliable and accessible system enabling the duration of time worked each day by each worker to be measured”.
• End of November 2025: during the 2026 budget talks, the federal government decided to make working-time registration mandatory.
• February 2026: N-VA MPs tabled a Chamber resolution (DOC 56 1353) asking for a light version with maximum freedom for employers. It is still pending, not adopted.
• 26 March 2026: the Minister of Work asked the National Labour Council (NAR/CNT) for advice on the draft.
• 30 September 2026: the NAR published its advice no. 2.499. The council is split: the unions support the obligation but call the draft deficient, and the employers’ organisations reject a general obligation and ask the government to withdraw it.
• Next steps: a second reading in the Council of Ministers, the Council of State, a vote in Parliament and publication in the Belgisch Staatsblad. As of 5 October 2026 none of these has happened. Given the split advice, the text and the start date may still change.

The current Arbeidswet of 16 March 1971 (Labour Act) contains no general duty to register working time. Be careful with headlines that say time registration “is mandatory from 1 January 2027”. That is the plan, not the law.

Is time registration already mandatory for some employers?

Yes. There is no general duty yet, but several specific ones already apply:

• Part-time workers who work outside their published schedule: the hours must be recorded through a reliable time-tracking system or a register of deviations. See werk.belgie.be on part-time work.
• Flexitime schedules (glijdende uurroosters): the Labour Act requires a time registration system.
• Flexi-jobs: every hour a flexi worker works must be registered through an accepted system, such as a registered cash system in hospitality, electronic time tracking or a day Dimona with start and end times. Since 1 July 2026 flexi-jobs are open to almost every sector, so this duty now reaches far more employers. See the RSZ instructions.
• Construction, ready-mix delivery and meat: attendance on qualifying sites must be registered in Check in at Work (CIAW). For construction and ready-mix this moves to CIAO on 1 April 2027.
• Cleaning: since 1 September 2024, certain cleaning activities for third parties use Check in and out at work (CIAO): workers register their arrival, departure and breaks in real time.

What will the 2027 time registration law require?

What the draft provides, as described in the NAR advice of 30 September 2026 and reported by Securex and SD Worx:

• Where: a new article 38quinquies in the Labour Act.
• What: daily and weekly working time must be recorded objectively and reliably. It must be the working time actually performed, not hours copied from a roster.
• How: the draft does not prescribe a form. No time clock or badge is required, and recording only the deviations from a fixed schedule is allowed.
• Who: all employers, with no exemption for small companies mentioned.
• Planned exclusions: family workers, employees in management or trust positions, commercial representatives and travelling staff (reizend personeel). The King can add more groups. SD Worx and Securex also list home workers and teleworkers, and the union part of the NAR advice criticises that exclusion, but the NAR’s own summary of the draft does not name them. Field technicians who move between clients may count as travelling staff, so do not decide on scope until the final text is published.
• Retention: the data must be kept for five years.
• Start: planned for 1 January 2027, with a transition period to 31 March 2027.

What the draft does not say: which data must be recorded (such as start and end times), whether the employee can access the records, and what the sanction is. The unions ask for all three in their advice. So be wary of any article that quotes a fine for the 2027 rule: there is none in the draft.

What already changed in 2026?

Two labour-law changes from 2026 matter for how you register hours, even though neither creates the general obligation:

• Voluntary overtime (from 1 April 2026): up to 360 hours a year, 240 of them net (no premium, social contributions or tax), with written consent from the worker. In hospitality with a registered cash system: 450 hours, 360 net. You need a reliable count of those hours.
• Work regulations (from 1 June 2026): the arbeidsreglement may set a general framework for normal working time instead of listing every schedule. The part-time minimum also drops from one third to one tenth of a full-time job. See the FOD Werk overview.

Do you need a prikklok or pointeuse?

No. Neither the planned law nor CIAO asks for a wall-mounted time clock. A prikklok, tikklok, pointeuse or badgeuse is one way to register time, not a legal requirement. A system meets the intent of the rule when it is:

• Objective: the worker or a device records the time, not a planner after the fact.
• Reliable: records cannot be changed without a trace.
• Accessible: employees can see their own data, and you can show it to an inspector. The EU Court of Justice requires this; the Belgian draft does not mention it yet, but the unions ask for it.
• Practical where the work happens: in an office, on a site, in a van or at a depot.

For field teams that usually means a mix: an app for crews, a badge at a site terminal for workers without a work phone, and registration in the vehicle for drivers. Suivo supports all four: mobile app, badge, fixed check-in pole on site and automatic registration through the vehicle.

What does CIAO change on construction sites from 1 April 2027?

CIAO is not a plan. The Programme Law of 30 May 2026 extends IN and OUT registration to construction. According to the RSZ, it starts on 1 April 2027 for works in immovable property (except cleaning) and ready-mix concrete delivery, on sites worth EUR 500,000 excl. VAT or more. The law itself says 1 January 2027 at the latest; the RSZ has announced the later date to make the application fully functional. From that date, construction attendance can no longer be registered in Check in at Work.

• IN and OUT: every arrival and departure is recorded, with the number of the declaration of works.
• Real time: workers register at the moment itself. The employer can no longer register the crew in advance.
• Every person: each contractor and subcontractor must make sure everyone working for them can register.
• Device on site: the obligated contractors supply and maintain the registration device. The RSZ accepts its own app, or a badge or other application connected through the RSZ webservice.

Our CIAO guide covers the details.

Can one registration cover CIAO and working time?

Partly. No source says a CIAO record on its own satisfies the planned working-time obligation, so do not plan on that. The two records answer different questions:

• CIAO: who was on this site, and when did they arrive and leave?
• Working-time registration: how many hours did this employee work today, wherever they worked?

On a normal construction day the gaps are easy to see. Loading materials at the depot is not on the site record. A foreman who visits three sites has three presences, not one working day. Office and workshop staff, and sites under EUR 500,000, are not covered by CIAO at all.

What works is one registration feeding two records. The worker registers once. The system sends the IN or OUT to the RSZ for the site and adds the time to the employee’s working day for payroll and inspection. Suivo reports Check in at Work and Check in and out at work registrations to the RSZ, and the same registrations feed the working-time record.

What does it mean for your sector?

Our article on time registration rules per sector goes deeper per joint committee.

How do you prepare for 2027?

Use this checklist in your budget round:

• Map who falls under what. List sites of EUR 500,000 or more (CIAO), then all other staff (planned general rule). Mark groups the draft may exclude, but do not act on exclusions until the law is final.
• Check what you do today. Paper, Excel, an app? Can you show the hours actually worked, and can nobody change them without a trace?
• Choose a method per group, not one device for everyone. Crews, drivers, workshop and office staff work differently.
• Ask for one registration, two outputs: the RSZ for site attendance, and your payroll and inspection file for working time.
• Check the payroll link. Ask how hours reach your social secretariat. Suivo connects to SD Worx; for other providers, ask us.
• Include subcontractors on CIAO sites: everyone working for you must be able to register.
• Plan consultation time. In companies with on average 50 or more employees, CAO no. 39 can apply to new technology with important collective consequences. If it applies, inform and consult employee representatives at least three months before you start implementing the system.
• Update your work regulations (arbeidsreglement) with the chosen method.
• Start small. Pilot on one team or site, then expand when the final law is known.
• Recheck the law monthly. One publication in the Belgisch Staatsblad changes the status overnight.

Frequently asked questions

Is time registration mandatory in Belgium from 2027?

That is the plan, but it is not law yet. As of 5 October 2026 the general obligation is a draft law that is planned to apply from 1 January 2027, with a transition period to 31 March 2027. Specific duties already exist today, for example for part-timers who work outside their schedule, flexi-jobs and attendance on construction sites.

Is a prikklok mandatory in 2027?

No. No Belgian law requires a prikklok (time clock), and the planned rule does not either. The draft, as reported, asks for a system that measures working time objectively and reliably. It does not have to be a time clock and does not have to be electronic.

Is a pointeuse obligatoire in Belgium?

No. A pointeuse (time clock) is not required by law. The planned enregistrement du temps de travail asks for a reliable record of working time, which can be an app, a badge, a terminal or another method that meets the requirements.

Who will have to register working time?

The draft is reported to cover all employers, private and public, whatever their size or sector. It excludes some groups, such as family workers, management and trust positions, commercial representatives and travelling staff. That list may still change before Parliament votes.

Is Excel or a paper timesheet still allowed?

The draft does not require an electronic system, and existing methods that meet the requirements may continue. Recording only the deviations from a fixed schedule is allowed in the draft. What counts is that the record shows the time actually worked, objectively and reliably. Hours copied from a roster are not enough.

What is the difference between CIAO and the 2027 time registration law?

CIAO (Check in and out at work) is already law and records who arrives at and leaves a construction site, sent to the RSZ in real time. The planned time registration law records how many hours each employee works, for your own records and for inspection. They are two different obligations.

What is the fine for not registering working time?

For the planned 2027 rule there is none yet: the draft contains no sanction. Existing duties do have fines. For example, missing time registration for flexitime schedules is a level 2 offence under the Social Penal Code, with an administrative fine of EUR 250 to 2,500, multiplied by the number of workers.

What is a prikklok?

A prikklok (tikklok, pointeuse or badgeuse) is a time clock: a device where employees register the start and end of their working day, originally by punching a card. Today the same job is done with badges, site terminals, smartphone apps or a registration in the vehicle.

One registration for sites, crews and payroll

You do not need a prikklok. You need one clean record that works in the office, on a site, in a van and at the depot, and that reaches the RSZ and your payroll without retyping. Start with the sites and crews CIAO covers on 1 April 2027, and extend to the rest of your staff when the general law is final. We will tell you honestly which parts are ready today and which are not.

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