Is digital time recording mandatory? Where Europe stands in 2026
Not in the UK or Ireland: both accept paper, spreadsheets or an app, as long as the record is accurate. EU law requires an objective, reliable and accessible system for daily working time, and some countries – Spain most visibly – are preparing digital-only rules. Here is where things stand in late October 2026.
Updated:
The short answer by country
| Country / level | Recording daily working time | Digital-only? |
|---|---|---|
| EU (CJEU, C-55/18) | Member states must require a system that measures each worker's daily working time | No – the form is left to each country |
| United Kingdom (GB) | Records adequate to show compliance with limits; daily hours not required if compliance can be shown otherwise (since 2024) | No |
| Ireland | Hours worked, leave and breaks recorded; kept 3 years | No – clock-in systems and paper Form OWT1 both accepted |
| Spain | Daily start and end already mandatory (art. 34.9 Workers' Statute) | Planned – a Royal Decree requiring digital records was still unpublished at the time of writing |
| Germany | Federal Labour Court (2022) held employers must already record working time | Not yet in law – the government has announced plans for electronic recording with transition periods |
This page is general information, not legal advice. If you employ people in several countries, each country's rules apply to the people working there.
What the EU actually requires
The starting point is the judgment of the Court of Justice of the EU of 14 May 2019 in case C-55/18, CCOO v Deutsche Bank. The Court held that, without a system measuring daily working time, neither workers nor authorities can check whether the limits of the Working Time Directive (2003/88/EC) – the 48-hour average week, 11 hours of daily rest, weekly rest – are respected.
Member States must require employers to set up an objective, reliable and accessible system enabling the duration of time worked each day by each worker to be measured.
CJEU press release No 61/19, case C-55/18
The Court left the form of the system to each member state, which can take account of the sector and the size of the business. So the ruling does not, on its own, require a digital system – but "objective" and "reliable" are hard to meet with times written from memory at month end, and several countries have taken the next step towards electronic, tamper-evident records.
Spain: the pending digital time recording decree
Spain has required a daily record of start and end times since 2019. In 2025 the Ministry of Labour proposed a Royal Decree that would make the record digital only, personal (each worker clocks in themselves), tamper-evident with a full trail of corrections, and remotely accessible to the Labour Inspectorate. The Council of State issued a non-binding unfavourable opinion in March 2026, and approval has been postponed several times.
At the time of writing (late October 2026) the decree had not been published in the BOE, Spain's official gazette, and the final text and transition period were unknown. Until it is published, paper and spreadsheets remain legal in Spain. If you employ staff there, our Spanish guide follows the details: registro horario digital.
Germany, Italy and other EU countries
In Germany, the Federal Labour Court ruled on 13 September 2022 (1 ABR 22/21) that employers are already obliged to record working time, based on health and safety law read in the light of the CCOO ruling. The government has announced it will set out the details in legislation, including electronic recording with transitional arrangements for small businesses; check the current status before relying on any date.
In Italy, employers record daily hours in the Libro Unico del Lavoro, in any format, with strict rules on remote monitoring and biometrics – see our Italian guide on rilevazione presenze. Other member states have implemented the ruling in different ways and at different speeds.
United Kingdom and Ireland
UK: since 1 January 2024, regulation 9(3) of the Working Time Regulations 1998 states that employers need not record each worker's daily hours if they can demonstrate compliance with the limits another way, and records may be kept in any format the employer reasonably thinks fit. There is no plan for mandatory digital records. However, holiday records (6 years, from April 2026) and minimum wage records (6 years) make an accurate record of hours worked very useful.
Ireland: the Organisation of Working Time Act 1997 and the 2001 Records Regulations require records of hours worked, leave and breaks, kept for 3 years, electronically or on Form OWT1. Missing records shift the burden of proof to the employer. Full details in our guide to working time records in the UK and Ireland.
What to do now, whatever your country
Waiting for each new law is risky: transition periods can be short. These steps work under today's rules and under the digital rules being discussed:
- Record real start and end times every day, at the moment they happen – not totals typed in later.
- Let each worker clock in personally, from their phone, a kiosk tablet or a terminal.
- Keep a trail of corrections: who changed what, when and why, without deleting the original.
- Record breaks and separate overtime, night and Sunday hours.
- Make the record easy to hand over: an export per employee and period in PDF or CSV.
- Avoid storing biometric data unless you have a strong legal basis and a data protection impact assessment.
- Inform employees in writing – and, where required, consult their representatives – before you introduce the system.
How QRtimetrack fits the direction of travel
No one can honestly promise compliance with a law that has not been published. What we can say is what QRtimetrack does today against the requirements being discussed:
| Requirement under discussion | What QRtimetrack does |
|---|---|
| Digital record | Every punch is digital: from the employee's phone (QR, GPS, optional selfie), an entrance tablet (PIN, printed badge or personal rotating code) or an office computer. |
| Personal, real-time clock-in | One phone per employee; a new phone needs manager approval. Time comes from the server; a changed phone clock is flagged. Offline punches keep their real time. |
| Tamper-evident corrections | Every correction is logged with a reason. Rejected punches don't count but are not deleted. |
| Breaks and overtime | Breaks recorded by the employee; overtime confirmed with a QR scan and photo; overtime and weekend hours calculated. |
| Access for workers | Employees see their punches and confirm or dispute their monthly hours from the phone. |
| Access for inspectors | Instant Excel, CSV or PDF exports with start, end, breaks and totals per day. |
| Data protection | EU hosting (Frankfurt). Face ID and fingerprint are checked on the phone – no biometric data reaches us. Selfies deleted after 30 days. DPIA template included. |
Prefer a fixed point at the entrance? Our special offer includes a Samsung Galaxy Tab A9+ tablet, 3 months of QRtimetrack free for your team and a step-by-step guide – you set it up yourself in about 10 minutes – for €299 outside Romania, with limited stock of 100 systems. Or start with the time tracking app on employees' phones.
Frequently asked questions
Is digital time recording mandatory in the EU?
Not at EU level. The CJEU's 2019 CCOO ruling requires member states to make employers use an objective, reliable and accessible system to measure daily working time, but leaves the form to each country. Some countries are moving to digital-only rules; check the country where your staff work.
Do UK employers need an electronic time clock?
No. The Working Time Regulations let you keep records in any format you reasonably think fit, and since 2024 you need not record daily hours if you can show compliance another way. Many employers still use a digital system because it makes holiday, minimum wage and overtime records easier to prove.
Can Irish employers still use paper timesheets?
Yes. The 2001 Records Regulations accept electronic clock-in systems and the paper Form OWT1. Records must show hours worked, leave and breaks (unless exempt), be kept for 3 years and be available to WRC inspectors.
When will Spain's digital time recording decree apply?
There is no date. At the time of writing, the Royal Decree had not been approved or published in the BOE, and the transition period was still under discussion. Until publication, the current rule – a daily record of start and end times in any reliable format – applies.
Is a spreadsheet an "objective and reliable" system?
It can be, if it's filled in daily with real times and changes are traceable. The weakness is that anyone can edit a cell without a trace, which is exactly what the proposed digital rules (for example in Spain) aim to exclude.
Sources
- CJEU press release No 61/19 – Case C-55/18, CCOO v Deutsche Bank (14 May 2019)
- Judgment of the Court, Case C-55/18 (EUR-Lex)
- Directive 2003/88/EC – Working Time Directive (EUR-Lex)
- Working Time Regulations 1998, regulation 9 – legislation.gov.uk
- Citizens Information – Keeping records of working time and breaks (Ireland)
- BOE – Spanish Workers' Statute, consolidated text (art. 34.9)