Time registration is now the law in the EU

Why this law exists

In May 2019, the Court of Justice of the European Union decided case C-55/18, CCOO v Deutsche Bank. A Spanish trade union argued that without a record of hours actually worked, employees could not prove overtime and authorities could not check compliance. The court agreed. It ruled that EU member states must require employers to set up an objective, reliable and accessible system for measuring each worker's daily working time. You can read the judgment at curia.europa.eu.

This guide is general information, not legal advice.

The ruling interprets the EU working time directive (2003/88/EC), which gives workers a 48-hour average maximum working week plus daily and weekly rest. The court's logic is simple: those rights are unenforceable if nobody knows how many hours were actually worked. Working time registration is what turns the directive from a principle into something you can check.

What "objective, reliable and accessible" actually demands

The three words carry the whole obligation, so it is worth unpacking them.

• Objective. Records must reflect hours actually worked — not a standard schedule copied forward, and not a manager's estimate.
• Reliable. Records must be complete and trustworthy over time. If entries can quietly change or disappear, the system fails.
• Accessible. Employees and, where relevant, labour authorities must be able to see the records — including a worker's own hours.

The rules are technology-neutral. Paper or a spreadsheet can qualify in principle. In practice, spreadsheets strain against all three tests: cells can be edited without a trace, files get forgotten in week seven, and handing one employee their own records without exposing everyone else's is awkward. A shared sheet is a reasonable starting point, not a comfortable end state.

Denmark: the concrete example

Member states have implemented the ruling at different speeds. Denmark is one of the clearest examples. Its amended Working Time Act (arbejdstidsloven) took effect on 1 July 2024 and requires nearly all employers to have an objective, reliable and accessible time-registration system. Two details matter for planning:

The act's text is on retsinformation.dk, and official guidance is published at at.dk.

The self-organiser exemption

Denmark exempts selvtilrettelæggere — self-organisers. Broadly, these are employees who genuinely organise their own working time; the act defines the exact boundary, and it is narrower than many managers assume. The exemption must be stated in the employment contract. If you plan to rely on it, that contract clause is not optional paperwork — it is the exemption.

If you employ people outside Denmark, check how your own country has implemented the ruling. The obligation traces back to the same judgment and the same EU working time directive, but dates and details differ.

Time records are personal data

An hour log tied to a named employee is personal data under GDPR. That means storing records securely, keeping them only for the statutory period, and being able to hand an employee their own records on request. If your time registration lives in an emailed spreadsheet, each of those duties gets harder. Our guide to GDPR-compliant time tracking covers this side in detail.

What to do this quarter

A workable compliance plan fits in six steps.

1. Confirm your national rules. Find out whether the time registration law is already in force in your country, and from what date.
2. Sort your people. Decide who, if anyone, genuinely qualifies as a self-organiser — and put the exemption into those employment contracts.
3. Pick a system. Paper, spreadsheet or software — test your choice honestly against objective, reliable and accessible.
4. Set retention and access. In Denmark that means five years of records, and a way for each employee to see their own hours.
5. Tell the team. Explain that this is working time registration required by law, not surveillance. What is recorded, who sees it, and why.
6. Run it for a month, then review. Look for missing days and quiet workarounds, and fix the process before a labour authority asks.

Where Klokly fits

Klokly is a calm, no-nonsense time tracker: one timer, one click. It is built to satisfy the system requirements without adding surveillance on top.

• Hours are recorded as they happen, not reconstructed later — which is what objective asks for.
• Data is securely hosted in the EU (Ireland), with each company's data isolated at the database level.
• Employees can export all their own data from Settings, which covers the accessible requirement and GDPR access requests in one move.
• You can export printable timesheets and CSV files when an authority or an employee asks for records — see our printable timesheet template guide.
• There are no screenshots, no idle detection and no GPS. The time registration law does not require surveillance, and Klokly does not do it.

To be honest about limits: Klokly has no invoicing, no project budgeting and no native mobile apps (the web app works on mobile). It records time, and it does that plainly. Pricing starts at $2 per seat per month, with a 14-day free trial and no credit card required — you can start a free trial and test it against the checklist above.

One last reminder: rules differ by country and continue to evolve, and this article is general information rather than legal advice. For a binding answer about your situation, talk to local counsel or your labour authority.

Frequently asked questions

Do all EU employers have to register working time?

The 2019 CJEU ruling in case C-55/18 requires every EU member state to make employers measure each worker's daily working time with an objective, reliable and accessible system. Implementation dates and details vary by country, so check your national law.

Is a spreadsheet a legal time-registration system?

In principle, yes — the rules are technology-neutral, so paper or a spreadsheet can qualify. In practice a spreadsheet must still be objective, reliable and accessible, which is hard when entries can be edited without a trace and records are scattered across files.

What is a self-organiser under the Danish rules?

A self-organiser (selvtilrettelægger) is, broadly, an employee who genuinely organises their own working time. The exemption is narrow — check the act's exact definition — and it must be stated in the employment contract.

How long must time records be kept in Denmark?

Under Denmark's amended Working Time Act, in force since 1 July 2024, working time records must be kept for 5 years, and employees must be able to access their own records.

Does the law require monitoring or surveillance of employees?

No. The obligation is to record working hours so rest rules and the 48-hour average weekly limit can be enforced. Screenshots, GPS or idle tracking are not required, and time records are personal data under GDPR, so collecting more than needed works against you.