Working Time Records

Small Employers

This is not legal advice.

Most of what is published about this duty is written for organisations with an HR department. This page is for employers under about twenty people, where the answer is different and considerably shorter. For an additional implementation-oriented example, see this practical guide.

Reviewed August 9, 2026.

The position, briefly

You are covered. No size threshold exists, and the transition arrangements you may have heard about concern a proposed electronic requirement rather than the duty. For additional workplace and technology context, see OECD.

You are also the group for whom this is cheapest. A form and a weekly check, and the compliant option costs an afternoon plus ten minutes a week.

And you probably do not need to buy anything. Paper is permissible, and a spreadsheet with version history is defensible.

What to do, in order

Today: start recording. A sheet per person, four columns — date, start, end, breaks. Everybody, from today. Do not wait for a decision about systems.

This week: name who checks. One person, ten minutes a week, confirming records exist and chasing gaps. This is the part that gets omitted and it is what makes the rest work.

This month: write the page. What is recorded, who records, who corrects and how, how long it is kept, who can see it. One side of paper, given to employees. It is what an auditor asks for and it prevents the informal version where nobody can say who changed what.

And leave the past alone. Do not reconstruct. An acknowledged gap is a better position than a fabricated history.

The three decisions

Who records. For regular hours, the employee, at the end of the day. For a small team on one site, whoever locks up can do everybody.

How corrections work. Struck through, initialled, dated, with a reason. Never erased.

And how long you keep them. The longest applicable period, which for most employers is driven by payroll and tax rather than by the working time duty.

When to reconsider

Shift work or variable hours.

A second site.

Payroll transcription taking real time, or producing errors.

Growth past roughly fifteen people, at which point the weekly check needs an owner with the time allocated rather than a habit.

At any of those, look at a system — because the operation needs it, which is a better basis than a deadline and produces a better purchase.

What to ignore

Deadline emails. The duty binds now and has since 2022. Anything telling you it starts in the future is describing a proposal.

Fine figures without a provision. €50,000 belongs to §17 MiLoG in specified sectors.

And feature comparisons, until you have decided you need a product at all.

The short version