EU Time recording obligations: a comparison

Are employers in your country obliged to set up an objective, reliable and accessible system to enable them to measure the duration of time worked each day by each worker?



The Austrian Working Time Act requires employers to record employees’ working hours, including start and end time and rest periods. Part-time workers and employees with limited roles are included but managerial employees are excluded. Employees can agree to record their own working time but must be given proper instruction on doing so. Employees who work from home are only required to record the duration of their working day.

Birgit Vogt-Majarek, Schima, Mayer, Starlinger Rechtsanwälte GmbH


There is no general obligation to record the time worked by each worker in Belgium. At present, keeping track of working time is only required in a few cases. For example, workers with ‘floating’ work schedules or part-time workers who deviate from their work schedules.

Julie De Maere, Claeys & Engels


Employers are responsible for introducing a mechanism for measuring and reporting the duration of the working hours of their workers. However there are no further statutory requirements towards the criteria such systems need to meet. Most employers use up-to-date electronic systems, but some employers also use outdated hard copy or manual forms.

Violeta Kirova, Boyanov & Co


Under the Organisation of Working Time Law, employers are obliged to respect the statutory working and rest times. The Law does not regulate or impose a particular record to be kept by the employer. What needs to be recorded and kept as registry is a list of all employees who have opted out from the maximum 48-hour work per week rule.

Nadia Tryfonidou, George Z. Georgiou & Associates LLC


Generally not. It is, however, a requirement in certain sectors such as the oil and gas industry.

Yvonne Frederiksen, Norrbom Vinding


The employer is obliged to ensure the agreed working and rest time is respected and keep account of working time. The Employment Contracts Act does not regulate the form and manner in which accounts are to be kept by the employer.

Karina Paatsi, Cobalt


For employees with sufficient autonomy working on a flat rate for a number of days annually in compliance with collective bargaining agreements and contractual provisions, employers must monitor the number and date of days or half days worked. They must also ensure working time is reasonable, complies with minimum rest periods and respects work-life balance.

For employees whose working time is calculated hourly, there is no obligation to record working hours if established collectively. If hours are not collective, employees’ start and end time or total daily hours must be recorded. The total number of hours weekly must also be recorded.

Guillaume Bordier, Capstan Avocats


In Germany, there is no obligation to record the actual working hours of employees. Maximum permissible working time is governed by the Working Hours Act and employers are obliged to ensure that maximum permissible working time is observed. In addition, working time exceeding eight hours must always be recorded by the employer.

Alexander Ulrich, KLIEMT.HR


In the public sector, there is an obligation. In the private sector, although there is a legal obligation, the Ministerial Decision that will specify which kinds of organisations are obliged to set up this system is still pending. Many private sector employers have opted to have such a system (provide for in internal regulations, CBAs or policies).

Fani Batsila, Kremalis Law Firm


According to the Hungarian Labour Code the obligation to keep a record of all hours worked by the employees daily only applies to employees working under fixed working time schedules. For employees with flexible working time schedules, including executive employees, only absences and their category (e.g. holiday or sick leave) has to be recorded.

It is also possible to keep a simplified working time record by updating the previous working time schedule on a daily basis (if any changes occur) and verifying it at the end of the month.

Nora Ovary Papp, CLV Partners


Section 25 of the Irish Organisation of Working Time Act 1997 requires employers to keep records to show compliance with the Act. The Organisation of Working Time (Records) (Prescribed Form and Exemptions) Regulations, 2001 confirm what details should be included in the records, and also specify that if an employer does not have clocking in facilities to record days/hours worked, the records should be kept in a particular format, or in a form that is substantially similar.

Declan Groarke, Lewis Silkin Ireland


The employer does not have an obligation to record the working time of employees working under a fixed working time regime (i.e. the same number of hours per day and the same number of days per week).

Jovita Valatkaitė, COBALT


Employers must keep a special register to record the duration of time worked (beginning, end and duration of daily work), all extensions of the normal hours of work, hours worked on Sundays, statutory holidays or at night, and the remuneration paid for that work. There are some exceptions, including for top executives.

Ariane Claverie, Castegnaro


There is an obligation for employers to keep a ‘proper record’ of working hours. However, in practice, the actual working hours per day are not registered in various industries. Furthermore, this obligation does not apply to employees who earn at least three times the statutory minimum wage.

Marieke ten Broeke, Bronsgeest Deur


Employers must keep a working time record specifying time worked as well as hours when the work begins and finishes; however, no working hours register is needed for employees:

  • working in a task-specific working time system;
  • managing the working establishment;
  • who are paid a lump sum for overtime or for work at night.

Grzegorz Ruszczyk, Raczkowski Paruch


Employers are only obliged to keep records concerning on-call time, overtime and additional time. Exemptions to this regulation may only be made in collective bargaining agreements. Certain categories of employees can be exempted from the regulations, for example managing directors.

Sofia Lysen, Elmzell


The Working Time Regulations 1998 require employers to keep records which are ‘adequate’ to show whether the weekly working time and night work limits are being complied with, and retain these records for two years. However, the Regulations do not specifically require that all hours of work must be recorded, and this obligation does not cover daily or weekly rest. Where workers have opted out of the 48-hour week, employers must maintain up-to-date records specifying the number of hours worked by that worker during each reference period, although in practice many employers do not currently do so accurately.

Hazel Oliver, Lewis Silkin



Andrej Žmikić, Divjak, Topić & Bahtijarević Law Firm

Czech Republic

Nataša Randlova, Randl Partners


Mika Kärkkäinen, Dittmar & Indrenius


Valeria Morosini, Toffoletto De Luca Tamajo e Soci


Matthew Brincat, Ganado Advocates


Andrej Žmikić, Divjak, Topić & Bahtijarević Law Firm


Ines Reis, pbbr


Daniel Stancescu, Nestor Nestor Diculescu Kingston Petersen


Dušan Nitschneider, Nitschneider & Partners


Darja Miklavčič, Šelih & Partnerji


Gisella Rocio Alvarado, Sagardoy