Working Time Records

What Auditors Ask For

This is not legal advice, and the specifics depend on which authority is asking and why. For an additional implementation-oriented example, see the product site.

An inspection is more procedural than employers expect. The requests are predictable, and being able to answer the first three quickly is most of what determines how the rest goes. For additional workplace and technology context, see German Federal Labour Court.

Reviewed August 9, 2026.

The six requests

One. Show me the system. Whatever it is — a folder, a spreadsheet, a product. The first question is whether one exists at all, and it is answered in thirty seconds or it is not.

Two. Records for these employees, for this period. Usually a sample rather than everything. Gaps are what gets noticed, and a gap in a sample implies a gap elsewhere.

Three. Start, end and breaks. The three data points, present and legible.

Four. Show me a correction. Who changed it, when, why, and what it was before. This is the request that distinguishes a maintained record from a produced one.

Five. Who is not in the system, and why. Classification questions surface here, and "we consider them senior" is an answer that invites the next question.

Six. How long do you keep these, and what happens then. Retention, stated and applied.

The two answers that extend an inspection

"We are just implementing that."

Which means no records for the preceding period, and the preceding period is now the subject.

"Let me reconstruct that for you."

Reconstruction is not a record, and offering it signals that the file has gaps. An acknowledged gap is a better position than a reconstructed month, and it is a much better position than a reconstructed month that gets noticed.

What makes it go quickly

A named person who knows where things are. Somebody who can produce a period without hunting.

A one-page description of the system — what is recorded, by whom, corrections, retention, who is covered. It answers four of the six requests before they are asked, and it is the policy you should have anyway.

Records in order. For paper, physically. For a system, exportable by employee and period without help from a supplier.

And export that works. If producing six months for one employee requires a support ticket, that is a problem discovered at the worst moment.

Sector-specific inspections

Different in emphasis.

Customs auditing §17 MiLoG in the sectors it covers is looking at a specific documentation duty with its own requirements and its own fine level. It is more frequent and more procedural than general working time supervision.

Where both apply, the §17 requirements are the stricter test, and satisfying them generally satisfies the general duty as well.

The preparation worth doing

Once, and it takes an afternoon.

Produce a full month for three employees, as if asked. Time yourself.

Find a correction and check it shows who, when, why and the previous value.

Write the one-page description.

And identify anybody not in the system, with the reason written down and, where it is a classification judgement, with advice behind it.

If all four are fine, an inspection is a routine morning.

The short version