Time recording is now required by law in Denmark.
All Danish businesses must record their employees' daily working time. Zenegy makes it easy to meet the requirements – without needless complexity.
- Max. weekly working time, averaged over 4 months
- 48hours
- Continuous daily rest period
- 11hours
- Retention period for records
- 5years
- Employees whose working time must, as a rule, be recorded
- 100%
The 6 most important requirements you need to know.
The bill (L 68) was passed on 23 January 2024 and applies to all Danish businesses.
Daily working time. The total daily working time must be recorded. Not the start and end times – only the total.
An objective system. The system must be objective, reliable and accessible. You're free to choose the method.
Employee access. Throughout their employment, employees must have access to their own records.
5 years' retention. The records must be kept for 5 years after the end of the reference period.
Access for the authorities. It must be possible to make the data available to Arbejdstilsynet (the Danish Working Environment Authority) and relevant authorities.
Employment contract. Self-organisers must have the exemption stated in their employment contract.
The background to the legal requirement.
The EU Working Time Directive ensures that all employees are protected against overwork and have the right to a daily and weekly rest period. The requirement was brought to the fore by the Deutsche Bank case in 2019. The Danish implementation is a minimum implementation with freedom of method – so businesses choose for themselves how they record.
Completed: May 2019
The Deutsche Bank judgment
The EU Court of Justice requires member states to introduce time recording systems.
Completed: November 2023
Bill L 68 is introduced
Based on an agreement between DA, FH and AC on implementation in Danish law.
Completed: 23 January 2024
The law is passed
The Danish Parliament (Folketinget) passes the bill unchanged.
Now: 1 July 2024 – now
The law is in force
All Danish businesses must have a compliant time recording system.
Who is covered – and who can be exempted?
As a rule, the law applies to everyone. There are, however, defined exemptions.
Covered by the law
- All full-time and part-time employees
- Hourly paid employees, salaried employees and employees on collective agreements
- Employees with flexible working hours
- Employees who work from home
- On-call temps and temporary employees
Can be exempted
- Self-organisers – must be stated in the employment contract
- Mobile workers covered by separate legislation
- Employees covered by special legislation (e.g. the military)
- Self-employed people with a spouse who works in the business
- Functions critical to society, with a collective agreement
Your responsibility as an employer.
The law places the responsibility with the employer. Here are your specific obligations.
Set up a recording system.
Make sure daily working time can be recorded objectively and reliably.
Give employees access.
Employees must be able to access their own information throughout their employment.
Keep the data for 5 years.
The records must be kept for 5 years after the reference period.
Update employment contracts.
Self-organisers and the duty to record must be stated in contracts.
Not sure whether your business is compliant?
- Time recording system in place
- Employees can access their own data
- Retention policy (5 years) in place
- Self-organisers identified
- Employment contracts updated
- Reporting to the authorities possible
Two solutions. One that fits you.
Both meet the requirement to record working time in an objective, reliable and accessible system. Use them as a Zenegy customer or standalone. All prices exclude VAT.
Working time management
Payroll
A time registration module as an add-on to Zenegy Payroll, or standalone. For businesses that want to comply with the law with minimal complexity.
DKK 11per employee per month
Plus DKK 100 per month for the Zenegy Subscription
- Deviation registration or classic time registration
- Registration via app or browser
- Mark self-organisers
- Reports on the rest period rules, including the 48-hour rule
- Employee access to their own data
Time
Advanced time registration for businesses with complex needs – collective agreements, project management and a terminal.
fromDKK 75per time registrant per month
Price based on the business's size and needs.
- Terminal or mobile app
- Clock-in/clock-out, deviation or classic registration
- Hours and supplements handled by collective agreement
- Project management and resource allocation
- Reports on the 11-hour and 48-hour rules
Frequently asked questions.
Do we have to record start and end times?
No. The requirement only covers the total daily working time. You don't need to record when during the day the work was done – only the total time for the day.
Can we use Excel or a spreadsheet?
Yes, you're free to choose the method, as long as the system is objective, reliable and accessible. A digital system does, however, give far better assurance of compliance, automated reporting and 5 years' retention without risk of data loss.
Who are "self-organisers", and how do we exempt them?
A self-organiser is an employee who organises all of their own working time, or whose working time cannot be measured or determined in advance. The assessment is individual – you can't exempt whole groups. The exemption must be stated in the employment contract.
What about deviation registration?
Deviation registration is allowed. If an employee has fixed, agreed daily working hours (e.g. 7.4 hours), only deviations from the agreed time need to be registered.
Do breaks have to be recorded?
No. Only the daily working time during which the employee is at the employer's disposal must be recorded. Breaks during which the employee isn't at the employer's disposal don't count as working time.
How long do we have to keep the records?
5 years after the end of the period on which the calculation of the employee's average weekly working time is based. With Zenegy, retention is handled automatically.
What happens if we don't comply with the law?
Without records, it can be hard to prove that you comply with the rest period rules, such as the 11-hour rule. In a dispute, the employee can use the missing records as evidence, and you risk losing the case.
Is the law unique to Denmark?
No, the requirement comes from an EU judgment and applies to all member states. The Danish version is a minimum implementation with a great deal of freedom of method.