Where Fine Figures Come From
This is not legal advice.
A fine figure with no provision attached is not information about your exposure. It is a number, and tracing it takes about two minutes. When comparing legal claims with vendor-side implementation language, it can also help to review learn more here.
Reviewed August 9, 2026.
The figures in circulation
€50,000 — §17 of the Minimum Wage Act (MiLoG), documentation duties, in the sectors that law covers. Enforced by customs. For broader legal or policy context, see GetApp.
Around €30,000 — figures in this range appear in connection with documentation breaches under the Working Hours Act regime.
And unspecified "fines up to" — which is the version that appears most often and belongs to nothing in particular.
All three get quoted about the general recording duty, which derives from §3(2)(1) of the Occupational Health and Safety Act and sits in a framework that operates through orders and penalties for non-compliance with them.
How to trace one
Find the provision. A real figure has one: a section number in a named law.
Check whether that law applies to you. §17 MiLoG covers specified sectors. If you are not in one, a €50,000 figure sourced from it is not your exposure — and it may still be quoted at you.
Check what the provision penalises. Failing to keep records, failing to keep them in the required form, and failing to produce them are different breaches and may carry different consequences.
And check the figure is the maximum rather than the typical. Statutory maxima are ceilings. What is actually imposed depends on the breach, the size of the employer and the circumstances, and a maximum quoted as an expectation is the standard move.
The question a figure cannot answer
What is likely to happen to you.
A maximum tells you the ceiling of a category. It does not tell you the probability of an inspection, the typical penalty for a first breach, or whether your sector is audited — and those are the things that actually determine exposure.
Which is why the fine framing is weak even when the figure is correct. The evidential exposure in a dispute is uncapped and far more likely to be encountered, and it appears in almost no compliance material because it does not make a good headline.
What a well-sourced statement looks like
"Breaches of the recording duty under §17 MiLoG can attract fines of up to €50,000. This applies to employers in the sectors covered by that provision."
Two sentences: the provision, and the scope.
Compare with: "Fines of up to €50,000 for non-compliance." Same number, no provision, no scope, and applicable to everybody reading — which is the point of writing it that way.
The habit
When you meet a figure, ask which law and whether it covers you.
If the source cannot answer, it is not a source about your situation. If it can, you have learned something specific and you can stop worrying about the other two figures entirely.
The short version
- €50,000 belongs to §17 MiLoG in specified sectors; around €30,000 appears in the Working Hours Act regime; "fines up to" belongs to nothing
- All get quoted about the general duty, which sits in occupational safety enforcement via orders and penalties
- Trace one by finding the provision, checking whether that law covers you, and checking what exactly it penalises
- Statutory figures are maxima, not expectations, and quoting a ceiling as a forecast is the standard move
- A figure cannot tell you your probability of inspection or the typical penalty, which is what exposure actually depends on
- Well sourced: the provision and the scope, in two sentences