Skip to content 2027 Mandatory working-time recording has been announced for all employers. Mandatory working-time recording announced. What the law says
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Legislation

What the law says about working time.

Recording working time has become a governance issue in Europe. Here are the key points, from the European framework to the situation in Belgium.The key points, from the European framework to the situation in Belgium.

These key points come from our white paper, September 2026 edition. They are general and subject to change. Have them checked against local law and your collective agreements, and confirmed with the competent authorities, before any roll-out.These key points come from our white paper, September 2026 edition. They are general and subject to change: have them checked against local law and confirmed with the competent authorities.

Download the white paper

The European framework

The European frameworkThree key texts

Article 31(2) of the Charter of Fundamental Rights gives every worker the right to limitation of maximum working hours, to daily and weekly rest periods and to an annual period of paid leave.Article 31(2) of the Charter gives every worker the right to limitation of working hours and to rest periods.

Directive 2003/88/EC sets minimum requirements: daily rest, weekly rest, breaks, a maximum average working week of 48 hours (including overtime) and annual leave.Directive 2003/88/EC sets minimum requirements: daily and weekly rest, breaks, 48 hours per week on average, annual leave.

In the CCOO ruling, the Court of Justice of the European Union held that Member States must require employers to set up a system enabling the duration of time worked each day by each worker to be measured. The system must be objective, reliable and accessible.In the CCOO ruling, the Court of Justice held that Member States must require an objective, reliable and accessible system for measuring working time.

CJEU, C-55/18, 14 May 2019

What the law requires

What EU law actually requiresFive requirements

  1. Objectivity

    The data does not rely on an unchecked after-the-fact estimate.

  2. Reliability

    The system limits untraceable deletions and changes. It keeps a record of corrections and who made them.The system limits untraceable deletions and changes.

  3. Accessibility

    The employee, their representatives and the competent authority can access the data in accordance with the applicable rules.The employee, their representatives and the competent authority can access the data.

  4. Effectiveness

    The data makes it possible to check rest periods and limits, not just to produce an attendance report.The data makes it possible to check rest periods and limits.

  5. Proportionality

    The system collects only what is necessary and does not put people under permanent surveillance.The system collects only what is necessary.

EU harmonisation focuses on outcomes. Day-to-day compliance remains largely a national matter.EU harmonisation focuses on outcomes. Day-to-day compliance remains a national matter.

In Belgium

In BelgiumWhat already applies

Belgium intends to implement this requirement through a general obligation covering all employers and workers.Belgium intends to implement this requirement through a general obligation covering all employers.

  • The Labour Act of 16 March 1971 sets the limits on working time, rest periods and overtime arrangements.The Labour Act of 16 March 1971 sets the limits on working time, rest periods and overtime.
  • The work rules (règlement de travail) set out the working hours and working-time frameworks that apply in the company.The work rules set out the working hours applicable in the company.
  • Recording working time or attendance is already mandatory in several situations: flexitime, certain part-time workers, flexi-jobs and certain forms of student work, construction sites and certain building works, certain sector-specific schemes.Recording is already mandatory in several situations: flexitime, part-time work, flexi-jobs, construction sites, sector-specific schemes.

2027

What has been announced for 2027What has been announced

In the November 2025 budget agreement, the federal government announced that from 2027 all employers would be required to have a simple and flexible working-time recording system.

The guiding principle is technology neutrality: no physical time clock is imposed. A paper register, HR software, badge system, web portal or mobile app may be suitable, provided the system is objective, reliable and accessible to workers, staff representatives and the social inspectorate.The guiding principle is technology neutrality: a paper register, HR software, badge system, web portal or mobile app may be suitable.

No law has been passed yet: the timetable and arrangements will depend on the final text.No law has been passed yet: the timetable will depend on the final text.

Other countries

What about other countries?A common baseline, local rules

Our white paper compares Belgium, Spain, Germany, France, Italy, Poland and the Netherlands. For an international group, the right model is a common European baseline supplemented by local rules.Our white paper compares Belgium, Spain, Germany, France, Italy, Poland and the Netherlands.

  • Belgium
  • Spain
  • Germany
  • France
  • Italy
  • Poland
  • Netherlands

GDPR

Personal data

  • Purpose and legal basisPurpose: keep time tracking, payroll, security and operational management purposes separate.
  • Minimisation: do not collect continuous location data if a timestamp is enough.: no continuous location data if a timestamp is enough.
  • Transparency: clear notice, retention period, recipients and rights.
  • Security: access rights, encryption, logging, backups.
  • Governance: a data protection impact assessment (DPIA) if the risk is high, and consulting the DPO where required.: impact assessment if the risk is high.

What GeoPrest provides

A timestamped record, at Start and Stop.

  • A timestamped record of the start and end of work, every time someone clocks in or out.The start and end of work, every time someone clocks in or out.
  • The position recorded at Start and Stop, never continuously.The position at Start and Stop, never continuously.
  • Viewing by employee and by date, plus Excel exports.Viewing by employee and by date, Excel exports.
  • Corrections made by a manager, from the web app.Corrections made by a manager.

The rest is up to you: correction rules, retention period, access rights, informing employees and consulting their representatives. The white paper offers an eight-step method and a control matrix.The rest is up to you: correction rules, retention, access rights, informing employees.

Download the white paper Talk to the team