2027 is approaching. And with the new year in sight, there are also some changes on the legislative front. For employers, there are this time two amendments that truly matter: mandatory working time registration and the mandatory mobility budget.
Both measures stem from the federal coalition agreement. The exact legislative texts are not yet available, but the outlines are fixed. And waiting is not a strategy. Those who start working on it now have time to make adjustments calmly.
What exactly is changing, and where is it best to start?
Mandatory working time registration
From 1 January 2027, every employer must record employees' working time in an objective and reliable manner. The European Hor of Justice ruled that rules on maximum hours and rest periods are only enforceable if the hours worked are also effectively recorded. Belgium is currently one of the last European countries without a general obligation, and that is now changing.
What does working time registration entail?
The essence is simple: as an employer, you must be able to demonstrate when and how much each employee actually works. Not the work schedule on paper, but a record of actual working hours. In practical terms, this means you must keep track of when an employee starts and stops working. That data must also be objective and reliable.
Today, this obligation already exists in specific situations, for example with flexible working schedules or for part-time workers with variable hours. From 2027, it will in principle apply to everyone, and that is the major change. Whereas time registration today is often still separate from day-to-day operations, it will become a structural part of how you work as an organisation.
The obligation arises because, without registration, it is difficult to verify whether the rules on maximum hours, overtime, and rest periods are being complied with. In disputes about overtime or during an inspection, the burden of proof lies with you as the employer.
Who does this apply to?
The obligation applies in principle to every employer, regardless of sector or company size. There is, however, a group of employees for whom exceptions apply. The reasoning behind this: some roles do not lend themselves well to conventional time registration. For example, when the employee determines for themselves how long they work, or when the nature of the work involves no fixed hours or fixed workplace.
This is the case for:
- Persons working in a family business where only blood relatives, relatives by marriage or foster children work under the authority of a father, mother or guardian.
- Employees in a managerial role or a position of trust.
- Commercial representatives.
- Home workers and teleworkers.
- Mobile staff: employees who mainly carry out work outside the employer's fixed place of business (think of technicians and home-care nurses).
For certain sectors, such as transport, specific registration rules already exist today. These simply remain in force, alongside the new general obligation.
What does objective and reliable mean in practice?
Your time registration system must be objective and reliable. That does not mean the clocking-in machine becomes mandatory again. Digital software, a badge system, an app or a system in which you only record deviations from the schedule: all of these are acceptable. Provided it correctly records the actual hours worked. A system that automatically fills in hours based on the planned schedule is not sufficient. Recorded data must also be retained for five years and kept accessible to employees and inspection services.
What can you do now?
Do you currently work with Excel, a badge system or specific software? Test it now against the core criteria: is objective, reliable and accessible. Also map out how work is actually carried out within your organisation. Think about deviations from the formal schedule, working from home or flexible hours. That way you choose a system that suits your organisation rather than having to make adjustments after the fact.
Mandatory mobility budget from 2027
Since 2019, you as an employer have already been able to voluntarily offer a mobility budget to employees with a company car. From 2027, this will become an obligation for a portion of employers. The measure forms part of the federal coalition agreement and is intended to encourage sustainable mobility.
What is a mobility budget?
A mobility budget is an amount that an employee receives in exchange for their company car. Instead of driving a car, the employee chooses for themselves how that amount is spent. They choose from three pillars that they can freely combine: a more environmentally friendly company car, sustainable transport solutions such as a bicycle or housing costs closer to the workplace, and any remaining balance that is paid out.
The amount itself is calculated on the basis of the total cost of ownership: all costs that the employer currently effectively bears for that company car — so not only the lease price, but also items such as fuel, insurance and taxes.
How the three pillars work exactly and what has already changed in the system over the past few years, you can read here.
Who does this apply to?
The basic rule is straightforward: every employer who has been making one or more company cars available for at least 36 months must offer the mobility budget from 2027. From 2027, those 36 months no longer need to be consecutive.
Two exceptions to that rule apply, based on the size of your company. Do you have an average of fewer than 15 employees? Then the system remains entirely voluntary for you. Do you have between 15 and 50 employees? Then you are exempt until the end of 2027, and only need to offer the mobility budget from 1 January 2028. Employers with 50 or more employees are not covered by any exception and must therefore be compliant from 1 January 2027.
What changes concretely for you as an employer?
Today you decide for yourself whether, and to whom, you offer a mobility budget. Going forward, every employee who is entitled to a company car must be given the opportunity to exchange it for the budget. If you refuse a request, you must motivate that refusal in writing and on objective grounds. Importantly, the employee decides for themselves whether to make the switch.
What can you do now?
The rules are not yet fully established. On 9 January 2026, the Council of Ministers approved a preliminary draft law, but the social partners requested a few further adjustments. Nevertheless, now is the time to get started. Map out what your current fleet actually costs and whether you fall under the obligation based on your number of employees. That analysis will later serve as the starting point for the mobility budget.
Our tip? Start today with a brief stocktake: how do you currently record working time, and will you be required to offer the mobility budget? Companies that know this now will be better placed later.
