From January 2027, keeping track of your employees’ working hours goes from best practice to legal obligation for every Belgian employer without exception. Whether you run a construction firm, a retail chain, a care home, or an accountancy office, you will need an objective, reliable system that records the start and end of every working day. Belgian employers already using Suivo’s workforce management platform are building exactly this kind of auditable system today, here is what the obligation means, where it comes from, who it affects, and how to be ready before the deadline.
Where the 2027 obligation comes from
The 2027 mandate has two roots.
The first is the CCOO ruling handed down by the Court of Justice of the European Union in May 2019, which established that EU member states must require employers to set up an objective, reliable, and accessible system to measure each worker’s daily working time. You can read the full ruling on EUR-Lex.
The second is the Belgian coalition agreement of the De Wever government (2024–2029), which committed to transposing the CCOO ruling into Belgian law with a January 2027 implementation date. The FPS Employment (Federale Overheidsdienst Werkgelegenheid) is the responsible body; official guidance is published at werk.belgie.be.
The core requirement is simple: a daily record of when each employee starts work and when they stop, captured in a way that cannot be altered after the fact and that is accessible to both the employee and the NSSO labour inspectorate on request.
Who is already compliant and who is not
Belgium has been building toward mandatory time registration sector by sector for over a decade.
| Sector | Current obligation | Status before 2027 |
| Construction (CIAW) | Electronic attendance on qualifying sites | Mandatory since 2014 |
| Cleaning (CIAO) | Check-in and out on sites above €30,000 | Mandatory since 1 September 2024 |
| Meat processing (CIAW) | Electronic attendance on sites above €5,000 | Mandatory since 2014 |
| Transport | EU tachograph (drive time only) | Partial, working time gap remains |
| Retail | None beyond general labour law | Not yet compliant |
| Healthcare / care | None beyond general labour law | Not yet compliant |
| Office / services | None beyond general labour law | Not yet compliant |
| Hospitality / horeca | None beyond general labour law | Not yet compliant |
Employers already using Suivo’s Check-in at Work solution for CIAW compliance in construction or cleaning are ahead of the curve, but even they may need to upgrade: CIAW records attendance, not total working hours. The 2027 mandate specifically requires a daily working-hours record, start time, end time, and break duration, not just attendance.
What the record must look like
The CCOO ruling sets three criteria that Belgian law will require:
Objective: The record must not depend on the worker or manager filling in what they think happened. It must capture the actual moment work starts and ends, a verified timestamp.
Reliable: The record must be tamper-resistant. A spreadsheet where anyone can change yesterday’s hours is not reliable in the legal sense. Suivo’s time tracking solution creates GPS-verified timestamps that cannot be backdated or edited locally.
Accessible: The record must be available to the worker on request and producible to a labour inspector during an audit without delay.
Paper timesheets filled in at the end of the week from memory fail all three criteria.
What changes for sectors not yet covered
For Belgian employers in retail, services, office environments, hospitality, and healthcare, the 2027 obligation introduces something genuinely new. These sectors have historically operated on informal arrangements where working hours are roughly understood but rarely documented with precision.
Under the 2027 mandate, every employee’s start and end time must be recorded every working day, breaks long enough to count as rest must be recorded separately, records must be kept for at least 3 to 5 years, and workers must be able to consult their own records. SIOD inspectors from the social inspectorate can audit any employer and request working-hours records going back three years.
Practical steps to take before the planned January 2027 start
Map your workforce by location type. Office staff, home workers, field teams, and on-site workers each need a different clock-in approach. Suivo’s scheduling solution supports all of them from a single platform.
Run a pilot on one team or site. A two-week parallel run, digital system alongside whatever you do today, shows you where the gaps are before you scale.
Update your work regulations. Belgian law requires the time registration method, the data collected, and the retention period to be described in your arbeidsreglement. This update must go through the works council or union delegation if applicable.
Connect to payroll. A native integration with SD Worx, Acerta, or Partena turns hours into payslips without a spreadsheet in between. See Suivo’s API integration options.
Why starting now is better than waiting
Construction companies like Hoogmartens and logistics operators like Van Moer have been running verified digital time registration for years. Every month you wait is a month of payroll data you cannot retrospectively verify and a month of operational inefficiency you continue to absorb. The 2027 mandate is the legal deadline. The operational benefit is available the day you go live.
Ready to prepare for 2027?
Suivo helps Belgian employers across all sectors set up verified, audit-ready time registration before the planned 1 January 2027 deadline.
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Make Every Hour Count
A practical guide to digital time registration for teams that work off-site, across sites or on the road.
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