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Get to know the new Time Registration law

The Working Time Act has been amended, meaning a set of new requirements for employees and employers in Danish workplaces. But what does the new time registration law say, and what requirements does it impose? Learn everything you need to know about the new legislation here.

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Why changes to the Working Time Act are needed

The law comes into effect on July 1, 2024.

On January 23, 2024, the Danish Parliament passed the Working Time Registration Act in response to a European Court of Justice directive requiring member states to enforce mandatory tracking of working hours to ensure adherence to regulations on daily work, rest periods, and breaks.

The rationale for mandatory registration is, in other words, to ensure employee protection against rule violations and, importantly, to focus on their safety and health.

Requirements imposed by the new Working Time Law

The new Working Time Act imposes requirements on employers to implement a registration system showing each employee’s daily working hours. The registration requirement aims to ensure compliance with these three points in particular:

Maximum working time

According to the Working Time Act, an employee may work a maximum of 48 hours per week on average over 4 months. This is intended to ensure sufficient rest and prevent overwork. 

Right to breaks

The Working Time Act has rules for breaks during the working day. There must be designated breaks during the working day, depending on the length of the working day, the industry, and the workplace.

Rest period

An employee’s working hours must be scheduled to allow the individual to have 11 consecutive hours of rest within 24 hours. The employee is entitled to 35 consecutive hours of rest once a week.

Implement a Time Registration System

Companies must implement a reliable, objective, and accessible system to track daily employee hours. The system can be digital or manual. Regular compliance checks are required; non-compliance risks fall to the employer.

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Employees must have access to registration

During employment, the law also requires that time registration be accessible to each employee.

At the same time, the employer must securely store the information for five years after the anticipated working period.

GDPR must be updated

The new rules on registration requirements must also be updated in GDPR processes.

Employers must ensure that working time rules align with GDPR processes and data protection rules. This implies that employees’ privacy information must be protected.

Deviation from weekly working time rules

The 48-hour rule, which states that an employee may not work more than 48 hours on average over a reference period of four months.

It can be exceeded for certain employees, allowing up to 60 hours per week over four months. This applies to those in critical societal roles or covered by collective or standby agreements. Employee consent is required for extended hours.

Company must have a time registration policy

All employers must ensure that there is a clear and consistent policy for time registration of working hours in the company.

The policy should include:

  • Definition of working time
  • What needs to be recorded (when and where)
  • Sanctions and control measures

Step by Step

To a successful implementation of time registration in everyday work

As an employer, you are obliged to implement a reliable system for registering working hours for all employees. But how do you do it best? Here are four steps to a succesful system implementation.

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System implementation

Decide on which system you want to implement in the company. Should it be as simple as possible, and should it be manual or digital? As an employer, you know best what suits your company. However, try to think long-term so that you don’t need to change the system again soon.

Create a policy at the same time, so it is clear what the company requires from employees regarding time registration.

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Clear information

When the company introduces a new administrative process, the information must be clear. Among other things, it should be clear what the requirements are for time registration.

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Training and education

Allocate sufficient time for training and education for employees when they need to be trained in using the new system.

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Follow-up on the system

Once the system has been used for a while, it makes sense to evaluate whether it meets the requirements, works efficiently, and functions in everyday life.

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More essential information

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What does the time registration obligation mean?

Many may be unsure of what working time entails. According to the Working Time Act, it is the period during which an employee is available and performs their tasks.

These include:

  • The total daily working time must be registered – there is therefore no requirement for a specific timeframe during the working day.
  • Employees only need to register deviations from their total agreed working time.
  • Time registration must have an efficient and reliable system. This means that it may be more difficult to remember the daily working hours and ensure reliability if registration only occurs once a month or less frequently.
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Who does the new law apply to – and who is exempt?

As a starting point, all employers and employees in Danish business are subject to the new requirements for time registration. However, there are still a few exceptions.

These include:

  • Self-employed individuals
  • Self-schedulers
  • Administrative directors

Note that employees of self-employed individuals must follow the time registration law, even if the self-employed individual does not need to follow the rules themselves.

Pros and Cons of Time Registration Requirement

The purpose of the new legislation is primarily to ensure the welfare of employees. However, there are both pros and cons to the new time registration law.

When Are You a Self-Scheduler?

There is no clear and definitive answer to when you are a self-scheduler – and it always requires a specific assessment in each case.

However, there are two common denominators for self-schedulers:

  • Employees who independently determine their working hours and make independent decisions.
  • Employees who work under special conditions that mean working hours cannot be predetermined, while they have a function as a leader or in another capacity to make independent decisions.
As an employee, you are subject to the time registration rules if it is not stated in your contract that you are a self-scheduler. To be exempt from the registration requirement, the employer must therefore create a new contract or addendum to the existing contract. As a rule of thumb, you can distinguish between self-schedulers based on the size of the company. However, this does not mean that there cannot be self-schedulers beyond this.
  • Self-schedulers in SMEs: Here, it is typically the upper management layer just below the director.
  • Self-schedulers in large companies: Here, it is more likely to be the top two management layers.