Mandatory time tracking 2027 in food retail

What Belgian law says about mandatory time tracking

In 2023, the Court of Justice of the European Union confirmed that each member state must impose an objective, reliable and accessible system for recording the working time of each worker. Belgium has transposed this obligation into its national legislation, with a progressive rollout culminating in 2027.

In practice, every employer will need to have a system capable of recording the start and end times of each shift, breaks, and the total hours worked per day and per week. The system must be accessible to the worker (who can consult their own data) and to the social inspectorate (which can verify it during a check).

The law does not prescribe a specific type of system. Physical badge reader, mobile app, online software: the choice is free, as long as the system is reliable, tamper-proof and auditable.

The legislator's objective is twofold: to protect workers against unpaid hours and to give the social inspectorate an effective monitoring tool. For supermarkets, this obligation formalises a practice that should already be in place, but which many still manage with paper attendance sheets or rough Excel files.

What this means for supermarkets

The time-tracking obligation affects all sectors, but supermarkets are among the most impacted. The complexity of their operations makes compliance more demanding than in a typical office.

Large and varied workforces

An average supermarket employs 40 to 80 people, across full-time, part-time, flexi-job, student and casual profiles. Each profile has its own working time rules. The recording system must handle this diversity without error.

Multiple departments

Checkout, butchery, bakery, fishmonger, fresh aisle, stock, shelf stacking, reception: a supermarket functions like several businesses under one roof. Recording should ideally allow time to be tracked by department, not just by employee.

Extended opening hours

Supermarkets open early and close late, often six to seven days a week. Shifts vary from one week to the next. The system must operate from 6 a.m. to 9 p.m. without interruption, including at weekends.

Workers moving between departments

A team member may start the day on shelf stacking, move to checkout at 10 a.m. and finish in the fresh aisle. The system must be able to record these department changes if the employer wants a detailed analysis of time allocation by department.

Multiple employment statuses

In a single supermarket, open-ended contracts, fixed-term contracts, flexi-job workers, students, agency workers and sometimes posted workers all coexist. The recording system must handle all these statuses, each with its own rules for calculating hours, breaks and premiums. A single system that integrates all these profiles considerably simplifies compliance.

Implementation challenges

Setting up a time-recording system in a supermarket is not simply a matter of installing a badge reader at the entrance. Several practical questions arise.

Which hardware to choose

The options are numerous: fixed tablet at the entrance, terminals by department, NFC badge, QR code, personal smartphone. The choice depends on the size of the store, the number of staff and the budget. A single tablet at the entrance creates queues at shift changeovers. Multiple terminals increase cost but reduce friction.

How to handle missed clock-ins

Any time-tracking system must provide a mechanism for missed clock-ins. A team member who forgets to clock in on arrival must be able to correct the situation, with manager validation. The system must record these corrections to guarantee traceability.

How to integrate flexi-job and student workers

Casual workers are not always familiar with the store's time-tracking system. The process must be simple: temporary badge, unique QR code, or clock-in via the personal mobile app. The important thing is that every shift is recorded, regardless of the worker's status.

How to connect time tracking to payroll

Time-tracking data must feed payroll calculation: regular hours, overtime, Sunday premiums, night premiums. If the time-tracking system is not connected to the payroll provider, the employer ends up entering the data manually, which cancels out the benefit of automation.

How to ensure adoption by teams

The main pitfall of any new time-tracking system is staff resistance. Cashiers, butchers and shelf-stackers are used to their routines. Introducing a badge or an app must be accompanied by support: a short training session (15 minutes is enough), instructions posted next to the terminals and a designated reference person available during the first few weeks. An intuitive system such as a mobile app considerably reduces the adaptation period.

What budget to plan for

The budget depends on the solution chosen. A clock-in tablet costs between 200 and 500 euros per terminal. A cloud software solution like Shyfter runs on a monthly per-user subscription. Training costs are minimal if the tool is intuitive. By contrast, the cost of non-compliance (fines, salary arrears, NSSO adjustments) far exceeds the investment in a compliant system.

How Shyfter already meets the 2027 obligation

Shyfter does not wait until 2027 to offer a complete recording system. The time-tracking module is available today and meets all the conditions of the future obligation.

Three clock-in modes

Shyfter offers three clock-in modes suited to the needs of supermarkets:

• Fixed tablet with NFC badge or PIN code: ideal for the store entrance or fixed workstations
• Mobile app with geolocation: perfect for staff moving between departments or outlets
• QR code by department: a cost-effective option for decentralised clock-in without additional hardware

Reliable and tamper-proof recording

Each clock-in is timestamped, geolocated and stored securely. Data cannot be modified without leaving an audit trail. That is exactly what the 2027 law will require: an objective, reliable and accessible system.

Worker access to their own data

Each team member can view their own time-tracking data via the Shyfter mobile app. Hours worked, breaks, overtime: everything is visible in real time. The 2027 law requires this transparency, and Shyfter already provides it.

Integrated scheduling and time tracking

Shyfter's real advantage is the integration between scheduling and time tracking. Planned hours are compared with actual hours in real time. Deviations appear automatically: late arrivals, early departures, unplanned overtime. The manager has a complete view without having to cross-reference two different systems.

Automatic export to payroll provider

Time-tracking data exports in one click to your payroll provider: SD Worx, Securex, Acerta, Liantis and more than 50 other connectors via Shyfter integrations. Hours, premiums and supplements are pre-calculated in the export. No double entry.

Preparation roadmap for supermarkets

Compliance does not happen overnight. Here are the recommended steps for supermarkets that want to get ahead of the 2027 obligation.

2025: audit and system selection

Take stock of your current situation. How do you record hours today? What are the gaps? How many staff members are affected? Evaluate available solutions and choose a system that integrates with your existing scheduling software.

2025–2026: deployment and training

Install the time-tracking system and train your teams. Start with a pilot department, then roll out progressively across the whole store. Allow a one-month run-in period during which both systems (old and new) coexist.

2026: optimisation and integration

Connect the time-tracking system to your payroll provider and scheduling tool. Verify that data flows correctly: regular hours, overtime, premiums, absences. Fix any processes that are not working.

2027: full compliance

By the time the obligation comes into force, your system is bedded in, your teams are trained and your data is reliable. You are ready for a potential social inspectorate check.

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Penalties for non-compliance

The exact details of the penalties will be set out in the implementing regulations. However, the general principles of the Belgian Social Penal Code will apply. The absence of a recording system or a non-compliant system (modifiable, incomplete, inaccessible) will expose the employer to level 2 or level 3 penalties: administrative fines of 400 to 4,000 euros, multiplied by the number of workers affected.

For a supermarket with 50 staff members and no time-tracking system, the theoretical bill could be considerable. Beyond the fines, the social inspectorate will be able to use the absence of reliable data against the employer in any dispute relating to hours worked, overtime or compensatory rest. The burden of proof will be reversed: without records, the worker's version will prevail.

Relationship with Dimona declarations

Time tracking does not replace the Dimona declaration. Both obligations coexist. Dimona declares the employment relationship to the NSSO. Time tracking documents the hours actually worked. An integrated system like Shyfter manages both: the Dimona is sent automatically when the shift is confirmed, and time tracking records actual hours on the day of the shift.

FAQ

Does the 2027 mandatory time-tracking obligation also apply to small supermarkets?

Yes. The law applies to all employers, regardless of their size. A neighbourhood supermarket with 10 staff has the same obligations as a hypermarket with 200 people. The difference lies in the complexity of the system required, but the obligation is identical.

Is Excel or a paper register sufficient to comply with the law?

In theory, the law does not impose a digital system. But in practice, an Excel file or a paper register does not meet the reliability and tamper-proof criteria the law requires. An Excel file can be modified without leaving a trace. A paper register can be lost or falsified. The social inspectorate favours digital systems with an audit trail.

What is the cost of compliance for a supermarket?

The cost depends on the solution chosen and the size of the store. A solution like Shyfter, which combines scheduling, time tracking and Dimona in a single platform, costs considerably less than purchasing separate systems. The clock-in tablet is often the only hardware investment required. The return on investment is rapid thanks to the reduction in payroll errors and administrative time.