Is Digital Time Tracking Mandatory?
What Really Applies from 2026?
Knowledge | Juni 28. 2026
There is still some uncertainty surrounding time tracking: Is it mandatory for businesses? How must working hours be recorded? Digitally or on paper?
With the planned reform of working time legislation, there is even occasional talk of the end of trust-based working hours. However, a closer look shows that this concern is unfounded. Significant changes will only affect businesses that still do not systematically record their employees’ working hours, as well as companies with 10 or more employees that have not yet switched to electronic time tracking.
For businesses already using the Celero One workforce management software, little or nothing will change. Even so, it is worth checking whether everything in your organisation already complies with the current and upcoming requirements, or whether any adjustments are still needed.
What are the current legal requirements for recording working hours?
Employers are already required to record their employees’ working hours. The European Court of Justice (ECJ) established this requirement in 2019. In 2022, the German Federal Labour Court confirmed that no new legislation was needed because the legal basis already exists under the German Occupational Health and Safety Act. Companies are therefore required to systematically record their employees’ daily working hours, including overtime, documenting the start time, end time and total duration.
However, digital time tracking is not yet mandatory. Businesses are still permitted to use paper timesheets and pen-and-paper records. Even so, many organisations have already adopted digital time tracking solutions because they make workforce scheduling simpler, more efficient and more reliable than paper-based processes – particularly when employees work from home or in the field.
What is expected to change with the Working Time Act from 2026?
The planned reform of working time legislation is expected to introduce a new Working Time Act during 2026. A draft bill was already published in 2024. Its primary objectives are to provide greater flexibility in maximum daily working hours by allowing a weekly working time model and to make digital time tracking mandatory.
Electronic time tracking will no longer simply be used to record hours worked. Instead, it will be required to document actual working hours precisely, including how those hours are distributed throughout the working week.
What does electronic time tracking mean in practice?
As is already the case today, all working hours must be recorded in full on the same working day and remain verifiable afterwards, regardless of whether the work is carried out on company premises, in the field or from home.
The key change introduced by the new Working Time Act will be that businesses must record these hours electronically, for example using on-premises or cloud-based software solutions, mobile apps, fixed terminals or browser-based applications.
According to the draft legislation, recorded working time must also be stored digitally for a minimum of two years.
Which working hours must be recorded?
All working time and on-call time must be recorded, including the start time, end time, total duration, breaks and overtime. These records are also required for businesses operating shift patterns.
The obligation to record working hours applies to full-time and part-time employees, marginal part-time employees (Minijobbers), employees working from home and those carrying out mobile work. The existing exemptions for senior executives, as defined under employment law, and managing directors will remain in place.
Working time must also be recorded to the exact minute. This means that using fixed time blocks, as is still common in some shift-based operations, recording in 15-minute intervals or rounding down working hours in favour of the employer will no longer be permitted.
Which businesses are required to introduce digital time tracking?
The planned Working Time Act will, in principle, apply to all businesses, from large listed corporations to SMEs. However, the requirements will not come into force for all organisations at the same time.
The draft legislation provides for transition periods for introducing digital time tracking, with the length of these periods depending on the size of the business. Smaller businesses will have more time to comply. According to the current draft bill, small businesses with fewer than 10 employees will still be permitted to record working hours using paper-based methods.
Will working from home and trust-based working hours still be possible?
Yes. Both trust-based working hours and working from home will remain possible. Employees will continue to record their own working hours, while employers will be responsible for checking those records for plausibility.
Is time tracking compatible with the GDPR?
Digital time tracking must also comply with the General Data Protection Regulation (GDPR). Any solution used must meet the legal requirements for data security. Only the data required for recording working hours may be collected and it may only be used for this purpose.
Employees have the right to access their personal data. Once the statutory retention period has expired, the data must be deleted, and the deletion must be documented, for example in the audit trail.
Does the works council have a say?
As the obligation to record working hours is a statutory requirement, the works council does not have a right of co-determination regarding the introduction of such systems.
However, it may have co-determination rights concerning the specific implementation of the solution, for example in relation to workforce scheduling. It is therefore advisable to involve the works council at an early stage.
Introducing digital time tracking in 5 steps
Many businesses already record their employees’ working hours digitally. For them, the expected legal requirement for digital time recording and storage will not involve any significant changes. Nevertheless, they should check whether their existing solution complies with the requirements of the Working Time Act.
Businesses that still need to implement a digital time tracking solution can follow these recommendations:
- Review your current situation: How are working hours currently recorded? By when must digital time tracking be implemented? Are there existing systems that can be built upon?
- Define your requirements: How and where should working hours be recorded? Do you operate from one or multiple locations? Do employees work remotely or in the field? Is an app-based solution required?
- Select a solution and plan the implementation: As this stage concerns the practical design and use of the solution, the works council should be involved no later than this point.
- Implement the solution: Allow sufficient time for implementation to ensure that any delays do not affect the planned launch.
- Communicate and provide training: Once everything is in place, employees should be familiarised with both the use and the benefits of digital time tracking.
Have questions? We're happy to help.
Simple and transparent: Time tracking in Celero One
Celero One is an intelligent operating system for frontline work, designed to meet the demanding requirements of field operations. This includes delivering consistently high-quality work across changing locations, internationally deployed teams and fast-moving operational environments. Paper timesheets and manual records are no longer fit for purpose. With Celero One, accurate digital time tracking in near real time has long been standard practice.
Working hours are always recorded manually by the employees carrying out the assignment. Time tracking is designed as a deliberate and active step within the Celero One Mobile app. To validate the working hours entered by employees, Celero One includes additional verification mechanisms. The recorded start time can be cross-checked using a location check-in, confirming when the employee arrived at the assignment location. Another way to verify manually entered working hours is by comparing the device timestamps of the first completed work step with those recorded when the visit documentation is completed as the final work step. Breaks can be entered manually at any time between the recorded start and end of the working day.
To ensure that recording working hours is never overlooked, it forms a mandatory part of the predefined workflow. Using the Process Manager in Celero One, this workflow can easily be configured individually for each area of responsibility. Every recorded working time entry is automatically linked to the corresponding assignment as part of the associated visit documentation. This simplifies both allocation and reporting. By linking time records with predefined processes and storing all working time data centrally, including a complete audit trail, Celero One provides a high level of protection against manipulation, as well as data security and transparency.
As required by the planned Working Time Act, Celero One records the start time, end time and total duration of every working period. All data is archived in compliance with the GDPR, including a complete change history. Via standard data interfaces, these records can also be transferred easily to other systems, for example to provide payroll systems with the required working time data.
Want to learn more about digital time tracking with Celero One?
FAQ – Frequently Asked Questions
Is recording working hours already mandatory?
Yes. In 2019, the European Court of Justice ruled that all businesses within the European Union are required to record and document their employees’ daily working hours accurately, reliably and transparently. In 2022, the German Federal Labour Court confirmed that this obligation already exists in Germany under the German Occupational Health and Safety Act.
Is digital time tracking mandatory?
Not yet. However, for most businesses it is expected to become mandatory once the new Working Time Act comes into force in 2026.
Does digital time tracking apply to all businesses and employees?
Yes. The only expected exceptions are small businesses with up to 10 employees, as well as senior executives and managing directors.
What requirements apply to digital time tracking?
Working hours must be recorded to the exact minute on the same working day, including the start time, end time and total duration, and must be stored for at least two years. According to the current draft legislation, breaks and overtime must also be recorded. The GDPR also applies.
Whether a software solution fully complies with the legal requirements can only be confirmed once the final wording of the Working Time Act has been adopted. Based on the current draft legislation, Celero One already meets these requirements.
Are there transitional periods?
The draft legislation provides for staggered transition periods based on the number of employees:
- 10 to 49 employees: Digital time tracking expected from 2032
- 50 to 249 employees: Digital time tracking expected from 2028
- 250 or more employees: Digital time tracking expected from 2027
What happens if a business does not comply with the working time recording requirements?
The law already provides for fines where businesses fail to comply with their obligation to record working hours. Members of the management board or executive management may also be held personally liable in certain circumstances.
Is trust-based working still possible if working time recording is mandatory?
Yes. The key requirement is that employees record their working hours promptly and accurately. Celero One provides a highly user-friendly solution through its integrated time tracking functionality. It also enables employers to verify the plausibility of the recorded working hours.
Does Celero One meet the legal requirements for working time recording?
Celero One complies with all current legal requirements and, as far as can reasonably be anticipated, also with the expected requirements of the future Working Time Act. Should further changes become necessary, they will be implemented and rolled out by Celero One in good time.