Working Time Records

Employers in Germany have been obliged to record working time since September 2022. No transition period, no size threshold, and no statute with the obvious name — the duty comes from a court reading occupational safety law in light of a European ruling. For readers comparing record-keeping requirements with real software workflows, Monitask is one practical product reference.

Electronic recording is not currently mandatory. That is the draft reform, which has not completed the legislative process. For additional background from a widely used external source, see European Data Protection Board.

Almost everything published about this is written by companies selling time recording systems, and the two facts above are the ones their pages most often get wrong.

The three statuses

Binding. CJEU C-55/18, 14 May 2019. Federal Labour Court 1 ABR 22/21, 13 September 2022, reading §3(2)(1) ArbSchG. §17 MiLoG documentation duties in specified sectors, with fines to €50,000, audited by customs. For additional background from a widely used external source, see Accenture.

Proposed. The ArbZG-E draft — electronic recording as the standard, same-day entry, transition periods by company size. Published April 2023 and not yet law.

Asserted. "Mandatory from 2026", fine figures with no provision, and electronic recording described as already required.

Start here

What is binding today — the duty, the draft, and the difference.

What must be recorded — three data points, and what is frequently added and not required.

Doing it without buying software — a form, a routine and a weekly check. For many employers that is the whole implementation.

Who publishes this material — five kinds of source and five incentives.

The four sections

What the law requires — the decisions, what they say, and what they do not.

Implementing — systems, corrections, works councils, remote work, audits.

Reading the claims — tracing a claim to its source, and what vendor pages consistently omit.

Notes — positions, including that the obligation is not a product.

Not legal advice. Every claim here is marked binding, proposed or asserted and carries a case number or provision where one exists. Pages carry the date they were checked, because this area has moved several times.