Belgium · Hospitality · Regulation

Mandatory working-time registration from 1 January 2027: what it means for your horeca business

Belgium is making working-time registration compulsory for every employer. From 1 January 2027 you must record — objectively and reliably — when each member of staff starts, pauses and stops working. Here is what changes, what is still open, and how to get ready without adding paperwork to your week.

Last updated 10 June 2026 — we will keep this page current as the implementing legislation lands.

What changes on 1 January 2027

Every employer in Belgium — private and public, regardless of size — must have a system that records each worker’s daily working time.
It covers all workers: permanent staff, flexi-jobs, student workers and extras.
The record must be objective, reliable and accessible — the three criteria set by European case law.
The choice of system is free: a classic punch clock, a badge or code on the till, or an app on a smartphone or computer.

Why this is happening now

In 2019 the EU Court of Justice ruled (the CCOO case) that member states must require employers to measure daily working time — without records, limits on working hours and rest periods cannot be enforced.

Most EU countries already implemented this. Belgium had not — until now: the federal government has set 1 January 2027 as the deadline for all employers.

For horeca the step is smaller than it looks: you already know the Dimona declaration for every shift. What is new is recording the full daily working time, not just reporting the start.

What counts as a compliant system

Objective: it records actual start and end times, not just what was scheduled.
Reliable: entries cannot be quietly edited without leaving a trace — think audit trail.
Accessible: staff and the labour inspectorate can consult the records.
The government is aiming for flexible application: punch clocks, digital systems, mobile apps — as long as the system meets the criteria.

The fine print is not final yet

The framework and the deadline are set, but the detailed rules — sanctions, data formats, possible exceptions — are still being written into legislation during 2026. Be wary of vendors claiming to be ‘2027-certified’ today (ourselves included): nobody can certify against rules that have not been published. What you can do is choose a system that clearly meets the three established criteria.

How to prepare — a five-step checklist

Map what you do today — Dimona, paper schedules, the till, Excel — where do real start and end times actually live right now?
Pick your registration method — Punch clock, badge, or an app on the phone your staff already carry. In horeca the smartphone wins: no extra hardware at the bar.
Start well before the deadline — Run the system for a full season in 2026, so the quirks surface while registration is still optional.
Train the team once — Clocking in must take seconds, or it will not happen on a packed Friday night.
Check that you can export — The inspectorate and your payroll office both want clean exports — test that now.

Where PlanWiser fits

PlanWiser already builds weekly schedules for bars and restaurants; time registration lives in the same flow your team uses to check their shifts.

QR clock-in from each staff member’s own phone — scan the rotating code at the venue, no extra hardware.
Location-verified, tamper-evident punches with a full audit trail.
Audit-ready exports for payroll and inspection.
Schedule and reality side by side: planned shift versus registered time.
Runs as a web app (PWA) — nothing to install from an app store.

Frequently asked questions

Does this apply to a small café with only a few staff?: Yes. The obligation applies to every employer, regardless of size or sector — and to every type of worker, including flexi-jobs, student workers and extras.
Is a paper register or Excel enough?: The law requires an objective, reliable and accessible record. Paper or a hand-edited spreadsheet is hard to defend on the ‘reliable’ criterion: there is no trace of changes. The final rules are still to be published, but digital systems with an audit trail are clearly a better fit.
We already do Dimona — is that not enough?: No. Dimona declares the shift to the NSSO; the new obligation is about recording actual daily working time: start, end and breaks.
What if we are not ready by 1 January 2027?: Sanctions will only be fixed in the implementing legislation expected during 2026. Waiting for them is not a strategy: choose and pilot your system in 2026, and the deadline becomes a formality.
Can staff clock in with their own phones?: Yes — the government has signalled flexibility on the tools, mobile apps included. PlanWiser does this with QR clock-in plus location verification.
Does PlanWiser make me compliant?: No tool can guarantee compliance before the final rules are published. PlanWiser is built to meet the three established criteria — objective registration, tamper-evident data with an audit trail, and accessible exports.

Sources

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This page is general information, not legal advice. The implementing legislation is expected during 2026; details may change. Last reviewed 10 June 2026.