Compulsory Work Time Recording: The 2027 Shift back to Time Clocks

Belgium Mandates Working Time Recording, Navigating EU Compliance and Employer Flexibility

Brussels, Belgium – November 28, 2025 – Belgian employers are now legally obligated to implement systems for recording working time, a move stemming from a 2019 ruling by the Court of Justice of the European Union (CJEU) and formalized in Belgium’s government agreement earlier this year. The new regulations, designed to ensure compliance with the EU’s working Time Directive (2003/88), aim to provide an objective, reliable, and accessible record of hours worked for all employees.

the CJEU’s decision in the CCOO c. Deutsche Bank case established that Member States must guarantee a system for measuring working time. Belgium’s implementation seeks to balance this requirement with employer flexibility, particularly for businesses utilizing flexi-jobs and part-time arrangements.

Federal Minister of Employment, David Clarinval, emphasized the government’s intention to allow employers – in both the private and public sectors – considerable leeway in how thay track time. “The system must be objective, reliable and flexible, leaving employers… free to choose the way in which working time is monitored,” his office stated.

What Does This Mean for Employers?

Companies are not mandated to adopt specific technologies. existing systems, whether digital or paper-based, are permissible provided that they accurately determine standard hours, benefits, and overtime. This approach is intended to minimize administrative burdens, especially for small and Medium-sized Enterprises (SMEs).The KERN decision specifically highlights the need for a system that is “objective, reliable and flexible,” while granting employers “complete freedom as to how working time is tracked.”

A “Necessary Evil” for businesses

The Union of Middle Classes (UCM) acknowledges the new requirement as a “necessary evil,” focusing on providing support to employers to ensure a smooth and minimally disruptive transition. The move comes as Belgium also prepares for mandatory salary clarity regulations set to take effect in June, adding another layer of compliance for businesses to navigate.

While the mandate is driven by EU law, it signals a broader shift towards increased transparency and worker protection within the Belgian labor market. The focus now shifts to implementation and ensuring that the chosen methods effectively balance legal obligations with practical business needs.

What are the key drivers behind the UK government’s decision to re-emphasize rigorous work time recording in 2027?

Understanding the new Regulations

In 2027, businesses across the UK will see a meaningful change in how employee work hours are tracked. New legislation, driven by concerns over wage theft and accurate working time compliance, mandates a return to more rigorous work time recording practices. While many companies have embraced flexible working and digital solutions,the government is pushing for a standardized,verifiable system – largely centered around the re-introduction of time clocks. This isn’t simply a nostalgic step backward; it’s a response to increasing complexities in modern work arrangements and a desire for greater openness.

Why the Change? Addressing the Issues

For years, reliance on self-reporting and software-based time tracking has presented challenges. Issues like “time theft” (employees inaccurately reporting hours worked) and difficulties in proving compliance with the Working Time Regulations 1998 have prompted the government’s intervention. The new rules aim to:

* Ensure accurate payroll: Minimize errors and disputes related to wages.

* Protect employee rights: Guarantee employees are paid for all hours worked and receive appropriate rest breaks.

* Simplify compliance: Provide a clear, auditable record for employers to demonstrate adherence to legal requirements.

* Reduce ambiguity: Clarify working hours, particularly for those on flexible schedules or remote work arrangements.

What Does This Meen for Employers?

The legislation doesn’t strictly require physical time clocks, but the standard of proof demanded by the new rules makes them the most practical solution for many businesses. Acceptable methods of employee time tracking must be demonstrably tamper-proof and provide a permanent, verifiable record.

Acceptable Time Recording Methods

Here’s a breakdown of what’s likely to be considered compliant:

1. Traditional Time Clocks: Physical devices requiring employee identification (badge, fingerprint, etc.).
2. Biometric Time Clocks: Utilizing fingerprint, facial recognition, or other biometric data for accurate identification. These offer high security but raise data privacy considerations (see section below).
3. Digital Time Clocks (with robust security): Software-based systems integrated with secure hardware,preventing manipulation of time entries. These must go beyond simple app-based solutions.
4. Combined Systems: A hybrid approach utilizing both physical and digital elements for redundancy and versatility.

The Impact on Different Industries

The impact of the new regulations will vary depending on the industry.

* Manufacturing & Construction: These sectors, already accustomed to strict timekeeping, will likely see minimal disruption.

* Retail & Hospitality: Managing shift work and fluctuating schedules will require careful planning and possibly investment in new time and attendance systems.

* Office-Based Roles: The shift will be more significant, requiring a change in culture and potentially a move away from trust-based systems.

* Remote Work: Remote employee time tracking presents unique challenges. Solutions must be secure and prevent “buddy punching” (one employee clocking in for another).

Data Privacy and Employee Concerns

The use of biometric time clocks raises legitimate concerns about data privacy. Employers must comply with the General Data Protection Regulation (GDPR) and obtain explicit consent from employees before collecting and storing biometric data. Transparency is key. Employees have the right to:

* Know what data is being collected.

* Understand how the data will be used.

* access their data.

* Request deletion of their data.

Failure to comply with GDPR can result in significant fines. consider offering alternative time recording solutions for employees who object to biometric data collection.

Benefits of Accurate time Recording

Beyond compliance, implementing a robust timekeeping system offers several benefits:

* Improved Productivity: Accurate tracking can identify inefficiencies and areas for advancement.

* Reduced Labor Costs: Eliminate overpayment due to inaccurate time reporting.

* Better Workforce Management: Optimize staffing levels based on real-time data.

* Enhanced Employee Accountability: Promote a culture of responsibility and transparency.

* Streamlined Payroll Processing: Automate time data transfer to payroll systems.

Practical Tips for Implementation

Preparing for the 2027 shift requires proactive planning.Here are some steps to take:

1. Assess Your Current system: Identify gaps and areas for improvement.
2. Research Time Clock Options: Compare features, costs, and security measures.
3. Develop a Clear Policy: Outline time recording procedures and employee responsibilities.
4. Communicate with Employees: Explain the changes and address any concerns.
5. Provide Training: Ensure employees understand how to use the new system.
6. Consult with Legal Counsel: Ensure compliance with all relevant regulations, including GDPR.
7. Consider Integration: Look for systems that integrate with existing HR and payroll software. HRIS integration is crucial for efficiency.

Real-World Exmaple: The Automotive Industry

Several large automotive manufacturers in Germany faced similar pressures regarding accurate working time documentation in the early 2020s. They implemented sophisticated biometric time