Frequently asked questions about time registration 2027
Everything you want to know about the law, the requirements, the penalties and how Klox helps you.
Note: At the time of writing, the definitive text of the law on mandatory work-time registration has not yet been voted on or published in the Belgian Official Gazette. The information below is based on the available preparatory work and the CCOO ruling of the European Court of Justice. Exact penalty amounts and technical requirements may differ from the final text.
The legal obligation
Does the time registration obligation apply to my business?
In principle, the obligation applies to all Belgian employers and employees. There may be exceptions for certain categories (self-employed persons, certain collective labour agreements, ...), but the definitive list has not yet been published in the Belgian Official Gazette. We recommend being cautious and preparing for the general obligation.
Exactly when does the law take effect?
The announced target date is 1 January 2027. At the time of writing, the final legal text with all technical requirements and exceptions has not yet been voted on or published in the Belgian Official Gazette. We follow the legislation closely and will adapt Klox as soon as the final text is known.
What is the European background to this law?
The announced Belgian regulation follows from the European obligation after the CCOO judgment of the Court of Justice of the EU (C-55/18, May 2019). The Court ruled that employers must implement objective, reliable and accessible work-time registration systems. That judgment obliges all EU member states to legislate. Belgium is giving effect to it from 2027.
What are the three core requirements for the system?
Based on the CCOO ruling and the Belgian preparatory work, three core requirements apply: the system must be (1) objective (automatic, non-manipulable recording), (2) reliable (data cannot be changed afterwards without traceability), and (3) accessible (available to the employee and the inspection). Klox is built on these three requirements.
Do I need to update the work regulations?
Yes. You are required to state the chosen registration method in the work regulations. Klox offers a free generator that drafts the mandatory clause and an employee communication based on your details.
Penalties and enforcement
What are the penalties for non-compliance?
The exact penalty amounts have not yet been definitively set in published regulations. Breaches of Belgian labour law are punished according to the sanction levels of the Social Criminal Code: levels 1 and 2 are administrative fines, levels 3 and 4 can also be criminal, and fines are often multiplied per employee involved. We advise you to follow the official publications in the Belgian Official Gazette for the precise amounts once the law is published. We follow them closely and will keep you informed.
Who checks compliance?
The social inspectorate (the Federal Public Service Employment, Labour and Social Dialogue, and the NSSO Inspectorate) is responsible for enforcement. They may carry out an on-site visit or request a file. Klox generates the required inspection file in 1 click.
Does the obligation also apply to part-time employees?
Based on the information available, the obligation applies to all employees, regardless of their working arrangement. However, the final wording of the law may contain nuances. We will adapt Klox as soon as the law is published.
Retention obligation and exportability
How long do I need to keep the records?
The retention obligation is at least 5 years. All records must remain available to the employee, the employer and the social inspectorate during that period. They must also be exportable in a readable format. Klox automatically retains all data for 5 years and offers export as PDF and CSV.
Does the employee have the right to access their data?
Yes. Employees have the right to view and export their own records. Klox offers an employee portal where each employee can view and download their own data.
What if there's an error in a record?
Corrections are legally permitted, but must be traceable. The original record may never be overwritten. In Klox, corrections are entered via a separate form with a mandatory reason, author and timestamp. The original data is always retained.
About Klox
When is Klox available?
Now. You can start for free right away: set up your organisation, invite your employees and try everything out, well ahead of 1 January 2027. Still unsure? Request a demo and we'll show you everything.
Is my data safe and stored in Belgium?
All personal data is stored and processed on servers within the European Union. 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. The Klox Kiosk with NFC badges is in development and not yet available to order; let us know if you need it and we will keep you posted.
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
A thorough, factual explanation of the legal obligation, its European basis, and what a system needs to be able to do.
Read the law pageUpdate your work regulations
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