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Introduction to the New Working Time Registration Law

By EasyHours | April 3, 2025

An easy-to-understand guide to the new legal requirements for working time registration for companies

Working Time Registration

Tags: working time registration, legal requirements, EU regulations, working hours, rest periods, time tracking, legislation

On July 1, 2024, a new law came into effect requiring all employers to register their employees' working hours. This law is the result of the EU's Working Time Directive and a decisive ruling from the European Court of Justice, aimed at protecting employees and ensuring compliance with rules on working hours and rest periods.

In this post, we cover everything you as an employer need to know about the new law - from the background and purpose to the practical requirements and implementation. We also provide concrete advice on how you can easily comply with the law without unnecessary administrative hassle.

Whether you run a small business or a larger organization, this guide will help you understand your obligations and get started with working time registration.

Table of Contents

Introduction to the New Working Time Registration Law

From July 1, 2024, it became mandatory for all employers to record employees' working hours. This new legal requirement for time tracking stems from EU regulations and aims to ensure compliance with the EU's working time rules. In this blog post, we provide an easy-to-understand introduction to the new requirements for working time registration. See also our complete guide to legal requirements for time tracking. We explain the background (the EU court ruling and the Working Time Directive), review who the law applies to, what employers specifically need to do, and what the consequences may be for non-compliance. The post is written in clear and friendly language, so you as a business leader without a legal background can easily understand what needs to be done—and how to get started.

Background: EU Ruling and Working Time Directive

The background for the new law is an important EU ruling and the EU's Working Time Directive. In May 2019, the European Court of Justice ruled that all member states must ensure that employers implement a system to record employees' daily working hours. This decision came because the EU's Working Time Directive sets clear EU working time rules on maximum working hours and rest periods – but without recording, it was difficult to enforce these rules. To protect employees from overwork and ensure their well-being, member states were therefore required to introduce a general requirement for time registration.

What do the EU's working time rules entail? The Working Time Directive includes, among other things, these central rules:

  • You may work a maximum of 48 hours per week on average over 4 months (the so-called 48-hour rule).
  • You are entitled to at least 11 consecutive hours of rest per day.
  • You are entitled to at least one day off per week (24 hours).

Additionally, the EU rules require breaks (e.g., appropriate break if working more than 6 consecutive hours). All this is to ensure that employees are not overburdened. With the new law, authorities can now require documentation that these rules are being followed – and this is where the requirement for working time registration comes into play. The registration requirement is intended to provide documentation for any breaches of the rules on working time and rest periods, so that problems can be detected and prevented early.

Who does the law apply to?

In short, the law applies to all employers – regardless of industry, size, or whether you normally record time or not. From July 1, 2024, all employees (wage earners) must have their working hours recorded. This means that even small and medium-sized enterprises must now introduce some form of time registration if they do not already have it.

Are there any exceptions? Yes, there is a single narrow exception: the so-called "self-schedulers." These are employees in higher positions who set their own working hours and have a very high degree of autonomy in their jobs. Typically, this will be top management or specialists whose working hours cannot be measured or predetermined. Only if an employee meets the conditions to be a self-scheduler can they be exempted from the time tracking requirement. In that case, it must be explicitly stated in the employment contract that the employee is a self-scheduler. For most companies, this will only include very few (if any) employees—for the vast majority of employees, there is no exception, and working hours must be registered as a rule. Read more about time tracking for salaried employees and other employee groups.

What must employers do to comply with the law?

What does the requirement entail in practice? As an employer, you are responsible for implementing a system that records each employee's total daily working hours in an objective, reliable, and accessible manner. Let's break it down into concrete points:

  • Choose a time tracking system: There is freedom of method. You can use anything from a simple timesheet or Excel sheet to a digital time tracking app—as long as the system meets the legal requirements of being objective, reliable, and accessible. Objective means that the registration must be neutral and accurate; reliable means that data cannot easily be changed or lost; accessible means that both employer and employee must be able to easily access the records. In other words: choose a system that suits you, but make sure it records the hours accurately and that you can document it if required.

  • Record daily working hours: The law requires that each employee's working hours be recorded every day – meaning the number of hours worked per day. It is not necessary to note the exact start and end times unless you wish to do so. You just need to ensure that the total working hours for the day are recorded. If your employees have fixed working hours or a shift schedule, it may be beneficial to record deviations instead of entering the same information every day. For example, if an employee normally works 7.5 hours but works 8.5 hours one day, you can simply record the extra hour for that day. This flexible method is allowed and can minimize administrative hassle, as long as the final result – the correct daily total hours – is recorded.

  • Involve employees: As a rule of thumb, it is practical for employees to report their own hours in the chosen system (e.g., via an app or by filling out a timesheet). You should inform all employees about how and when they should record their working hours. It might be a good idea to create a short guide or policy for time registration in the company, describing: what needs to be recorded (e.g., regular working hours, overtime, breaks), when it should be recorded (preferably continuously or daily), and what the consequence is if it is forgotten. Such a time registration policy is not directly required by law, but it helps ensure a common understanding and consistency. (Tip: See our internal guide How to Get Started Easily for step-by-step advice on implementing time registration in your company.)

  • Follow up and verify: Since it is ultimately the employer's responsibility to ensure that working hours are recorded correctly, you should internally follow up to ensure that the system is actually being used. Make sure to remind employees who do not report their hours, and regularly check that the recorded information seems accurate and roughly aligns with the working time agreements. If something looks incorrect (e.g., an employee consistently forgets to register or has an improbably low number of hours recorded), you should have a discussion about it. Consider having a process for approving recorded hours so that both the employee and the manager agree on the time registration.

  • Store data for 5 years: The law requires you to keep the records for at least 5 years. This is related to the need to document compliance with the 48-hour rule over a longer period. Therefore, ensure that your time registration system can securely store data for at least five years, and that you have control over security and privacy (GDPR) regarding this data. Employees should also have access to their own recorded data as long as they are employed – this provides transparency and allows them to monitor their hours and, for example, notice if something is not recorded correctly.

  • Exceptions are handled correctly: If you determine that one or more employees in the company meet the criteria for self-managers (see the section Who does the law apply to? above), you must ensure that this is documented in the employment contract. This will typically require an addendum to the contract that precisely states that the individual is exempt from working time registration and from rules such as rest periods. It is important to use this exception only where it is justified – it is a very narrow exception, and it must be explainable and defensible if you choose to categorize a person as a self-manager.

(Do you have more questions? See our FAQ on working time registration where we answer typical questions about the new rules.)

Consequences of Non-Compliance

One might ask: What happens if we don't implement time registration or forget to use the system? The answer is that it can have serious consequences for your company. Although the law itself does not specify a fixed fine for "lack of time registration," you still risk sanctions because lack of registration is often associated with violations of working time regulations. Here are some potential consequences:

  • Orders or fines from regulatory authorities: The regulatory authorities that supervise work environment and working hours can react if you do not comply with the rules. They can issue an order (i.e., require you to correct it immediately) or, in the worst case, a fine for violation. The authorities can also require you to implement measures in the future to prevent violations of, for example, the 48-hour rule.

  • Compensation to employees: If it turns out that an employee has worked beyond the allowed limits (e.g., exceeded the 48-hour rule or not received 11 hours of rest) and you as an employer have not done anything to prevent it, the employee may be entitled to compensation for the breach of the rules. Lack of registration makes it harder for you to document that you have complied with the rules – and thus easier for an employee to succeed in claiming that a violation occurred. In other words, without proper time registrations, you have a weaker defense if someone complains about overtime or lack of rest.

  • Other legal consequences: Trade unions can get involved on behalf of employees if the rules are not followed. In serious or repeated cases, it can damage the company's reputation and internal working relationships. Furthermore, compliance with working time regulations is part of occupational health and safety legislation – systematic violations can ultimately lead to larger orders to change work processes or reduce working hours for your employees. In short: it can become costly and troublesome not to comply with the requirement.

Bottom line: Take the requirement for time tracking seriously. It's not just about complying with a law, but also about taking care of your employees and your business. Fortunately, compliance doesn't have to be difficult or time-consuming – there are good solutions that can make it easy.

Comply with the law in the easiest way

Implementing mandatory time tracking can seem overwhelming, especially for a small or medium-sized business. But you're not alone, and it doesn't have to be complicated at all. In fact, there are user-friendly digital tools that can handle most of the work for you. EasyHours is an example of a solution developed specifically to help companies with easy time tracking and ensure EU compliance. With EasyHours, you can quickly get started with recording working hours for all employees – the system is simple to use for both management and staff, and it naturally meets all legal requirements for objectivity, reliability, and accessibility.

Make it easy to comply with the new law – visit EasyHours.eu today. At EasyHours.eu, you can learn more and get started with a solution that saves you unnecessary hassle and ensures that mandatory time tracking becomes an integrated, simple part of everyday life. By choosing a smart solution like EasyHours, you show both your employees and the authorities that you take working time regulations seriously and care about employee well-being. So take action now: Get your time tracking in order – and let EasyHours help you on your way!