Belgium: working-time registration becomes mandatory. Are you ready?

What the law says

The programme law of 30 May 2026 (Belgian Official Gazette, 1 June 2026) replaces “Check in at Work” with “Check in and out at Work”. The ONSS has postponed its entry into force from 1 January to 1 April 2027.

Point

What changes on 1 April 2027

Activities covered

Construction works and delivery of ready-mixed concrete

Threshold

Sites with a total value of €500,000 excl. VAT or more

Who registers

Each worker, employee or self-employed, themselves

When

In real time, on arrival and at the end of the work, breaks included

How

Badge provided by the contractor, or QR code

No longer allowed

Advance or remote registration by the employer

The cleaning sector has applied in-and-out registration since 1 September 2024, with fines of up to €8,000 per worker. The meat sector is also covered by Checkinatwork.

One point protects the employer: if a compliant system is in place, the employer is not liable for workers who forget or refuse to register. The choice of system therefore becomes the employer’s best defence.

What about other sectors?

The general obligation for all companies has not yet been voted. The government announced it in late November 2025, and a draft bill was submitted to the National Labour Council in March 2026. It targets 1 January 2027, with a transition period until 1 April 2027.

It stems from a 2019 ruling of the Court of Justice of the European Union: every Member State must require employers to have a system that measures daily working time. The expected criteria are known:

• Objective: it records the time actually worked, with no unilateral manipulation.
• Reliable: data cannot be changed without a valid reason.
• Accessible: labour inspectors and the worker can consult it.

At this stage, the draft does not impose any method: time clock, badge, software or app. Beware of messages that already present it as law. What is certain today is the construction rule; for everything else, the safest move is a system that meets all three criteria, whatever the final text says.

What this means for employers

Whatever the sector, the system chosen will have to be objective, reliable and accessible. On construction sites, the law accepts badges and QR codes, but employers do not have to provide a smartphone. Everywhere, a fixed terminal at the workplace lets everyone clock in, phone or no phone, and provides the strongest proof of presence.

In practice, employers need:

1. A clocking point at every workplace (office, workshop, warehouse, shop or construction site), usable by everyone, with or without a phone.
2. A time-stamped record of entry and exit that nobody can alter afterwards.
3. Data flowing to payroll and to declarations, with no re-keying.
4. A history that inspectors and workers can consult at any time.