Mandatory time tracking 2027 in food retail
In brief: Belgium plans to make time tracking mandatory from 1 January 2027. As of 12 November 2026, this is a draft bill: the government still has to adopt the text and submit it to Parliament. For supermarkets and hypermarkets, this obligation would represent a major challenge: dozens or even hundreds of staff members, variable shifts, multiple departments, flexi-job workers and students to manage. Shyfter already lets you record working time through its integrated time-tracking system: fixed time clock, digital badge and geolocation. Supermarkets that adopt the system now will have a head start.
What the Belgian draft bill on time tracking provides
On 14 May 2019 (CCOO ruling, case C-55/18), the Court of Justice of the European Union held that member states must require employers to set up an objective, reliable and accessible system for measuring the working time of each worker. Belgium has not yet adopted a general law to that effect. A draft bill, announced in the federal budget agreement, was submitted to the National Labour Council, which issued its opinion no. 2.499 on 30 September 2026 without a common position between unions and employers. The targeted entry into force is 1 January 2027, with time until the end of the first quarter of 2027 for employers that do not yet have a system.
Under the draft, every employer would need an objective and reliable system to record working time, and would keep this data for five years. Recording only the deviations from the planned schedule could be enough. Unions are asking for full recording that workers can access, so the final text may still change.
The draft does not impose any type of system, and a time clock is not mandatory. Physical time clock, mobile app, online software: the choice would remain free, as long as the system is objective and reliable.
The stated 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 draft covers both the private and the public sector, with no size threshold and a few exclusions (management and positions of trust, sales representatives, mobile staff, family workers). Supermarkets would be among the most affected. 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 time clock 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 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 prepares you for the 2027 obligation
Shyfter does not wait until 2027 to offer a complete recording system. The time-tracking module is available today and already records working time objectively and reliably, as the draft requires.
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.
Penalties: what we know today
The draft bill does not provide for a specific penalty for failing to record working time. Unions are asking for a dedicated criminal penalty, but nothing has been decided: be wary of content that already quotes a fine amount for 2027.
Reliable records are still valuable today. Without accurate data, it is hard for an employer to show the hours actually worked in a dispute about overtime or compensatory rest.
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, under the draft bill, which sets no size threshold. A neighbourhood supermarket with 10 staff would be covered just like a hypermarket with 200 people, subject to the text that is finally voted. The difference lies in the complexity of the system required.
Is Excel or a paper register sufficient to comply with the law?
The draft bill does not impose a digital system: it asks for an objective and reliable one. An Excel file can be changed without leaving a trace, and a paper register is easily lost, which makes both hard to defend during an inspection. A digital system that keeps a history of changes is easier to justify.
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.
