Frequently asked questions about time registration 2027
What already applies, what has been announced, the penalties and how Klox helps you.
Note: As of 22/09/2026, the Belgian rules for general working-time registration have not been voted or published in the Belgian Official Gazette. The answers below separate what already applies from what has been announced. The sources are on our legislation page. This is general information, not legal advice.
The legal obligation
Does the time registration obligation apply to my business?
A general duty for every employer does not exist yet: it has been announced, but the legal text has not been published, and who it will cover and which exceptions there will be is not yet settled. Registration duties do already apply, for example for flexible schedules, deviations for part-time workers and flexi-jobs. Check whether one of these applies to you, and prepare for the general duty.
Exactly when does the law take effect?
The government wants to comply by 1 January 2027 at the latest and plans a transition period. In the Chamber committee the minister mentioned 1 January and 1 April as dates; the report gives the year 2026, which given the planning looks like a slip of the pen. As long as the law has not been voted and published in the Belgian Official Gazette, none of these dates is a confirmed legal start date. We update this page as soon as the text is available.
What is the European background to this law?
In the CCOO judgment (C-55/18, 14 May 2019), the Court of Justice of the EU held that Member States must require employers to have an objective, reliable and accessible system to measure each worker's daily working time. In Loredas (C-531/23, December 2024), the Court confirmed this for domestic workers. Belgium has announced it will implement this by 1 January 2027.
What are the three core requirements for the system?
The CCOO judgment requires an objective, reliable and accessible system, but prescribes no technology: the Member States determine the form. The Belgian technical requirements are not yet known. Klox interprets those three words by never overwriting original clock actions, keeping corrections separately and offering access and export. That is our product choice, not a legal requirement.
Do I need to update the work regulations?
The work regulations already state the working schedules and how work is measured and checked to determine pay. If you introduce a registration system, you therefore describe it there. Whether the new rules will require extra entries is not yet known. Our free generator creates a draft text and a staff message for you to have reviewed.
I work with flexi-job workers. Do I already have to register?
Yes. For flexi-jobbers a registration duty already applies, independently of the announced rules. The NSSO lists five options: a registered cash register system, the alternative attendance registration system linked to Dimona, an electronic time-tracking system, a daily Dimona with start and end times, or a digital tachograph. For an oral flexi contract you file a daily Dimona with start and end times.
I already do Dimona and Checkinatwork. Does 2027 come on top of that?
Those declarations remain; they serve a different purpose. Dimona reports that someone is employed by you, Checkinatwork and Check In and Out at Work record attendance on certain work sites and for certain cleaning activities. The announced rules are about recording the working time of every employee. Klox does not replace your Dimona declaration and is not a Dimona integration: it records the time worked and keeps it exportable.
Penalties and enforcement
What are the penalties for non-compliance?
The penalties for the announced duty are not yet known. Breaches of social legislation are currently punished under four penalty levels in the Social Criminal Code: level 1 is an administrative fine, levels 2 and 3 a criminal fine or another penalty or an administrative fine, level 4 can also be a prison sentence. For many breaches the fine is multiplied by the number of employees concerned. An existing example: having no time-tracking system with flexible schedules is a level 2 breach.
Who checks compliance?
The social inspection services, such as the Social Laws Inspection (Supervision of Social Laws) of the FPS Employment and the NSSO inspectorate. They can visit on site or request documents. In Klox you export, per employee and period, a file with registrations and corrections as PDF or CSV.
Does the obligation also apply to part-time employees?
For part-time workers, rules already apply: variable schedules are announced in advance and deviations from the schedule are recorded, in a deviation document or through a time-tracking system, and kept for five years. How the announced general duty will fit with this is not yet known.
Retention obligation and exportability
How long do I need to keep the records?
There is no general retention period; it depends on the arrangement. With flexible schedules you keep the data of the time-tracking system for five years after the end of the day they relate to (Labour Act, art. 20ter). For deviations of part-time workers it is also five years. The period of the announced rules is not yet known. Klox keeps registrations for five years by default, with export as PDF or CSV.
Does the employee have the right to access their data?
Yes. Under the GDPR every employee has the right to access their personal data and receive a copy. With flexible schedules, the employee must also be able to consult the time-tracking system. In Klox every employee sees their own hours and can export them.
What if there's an error in a record?
No published Belgian rule currently describes in general how a correction must be made. A system that keeps the original and keeps every correction visible does fit the CCOO requirement of reliable registration. In Klox a correction is a separate line with a mandatory reason, author and time; the original registration is always kept.
About Klox
When is Klox available?
Now. You can start on your own right away: create your organisation, invite your employees and try everything free for fourteen days, with no payment details. That way you are ready for the announced registration requirement.
Is my data safe and in the EU?
The data in Klox is stored on servers in the European Union, in a data centre in Germany. It is not stored outside the EU and not sold on to anyone. A data processing agreement (DPA) is included by default with every subscription, including the full list of processors.
What if I don't want to use a smartphone or computer?
Clocking in is always possible via a shared tablet or computer on the work floor: the employee signs in and clocks in via the browser, no smartphone needed. Or you choose the Klox Kiosk: employees tap their badge or pick their name and PIN. It is available to order, with delivery from 1/11/2026.
Is Klox also suitable for larger companies?
Yes. Klox works for any company size, from a handful to hundreds of employees. The software scales effortlessly and you simply pay per active employee, with no upper limit. Larger organisation with specific needs? Get in touch, we're happy to help.
Explanation of the law
What already applies, what has been announced and what is still open, with the primary sources.
Read the law pageUpdate your work regulations
Create a free draft clause on time registration and a staff message for your work regulations.
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