Time registration and legal requirements: what employers need to know

Published 5 September 2026 · Consitus

Short answer

Since 1 July 2024, employers covered by the Danish Working Time Act have had to introduce an objective, reliable and accessible working time registration system that makes it possible to measure daily working time for each relevant employee. The employee must be able to access their own records, and the information must be retained for 5 years after the end of the period that forms the basis for calculating the average weekly working time.

The Act does not prescribe a particular technical solution. According to the explanatory notes to the bill, employers have freedom of method, so there is no separate requirement for a digital system. Equally, there is no exhaustive technical checklist to rely on — it is the overall solution and the daily practice that have to meet the requirements.

Why the rules exist

The registration requirement was not introduced for the sake of record-keeping. Its purpose is to make it possible to assess whether the rules on daily and weekly rest periods and the maximum average weekly working time are actually being observed. Without a record of daily working time, it is difficult in practice to tell whether those limits are respected.

That also explains why the requirement is about being able to measure working time. It is not a requirement for detailed task tracking or for documenting what the time was spent on, but for being able to determine daily working time for the employees who are covered.

What the company must concretely be able to do

Taken together, the rules mean a company must be able to do the following three things. They are stated cautiously, close to the wording of the Act:

• Measure daily working time. A working time registration system must be in place that makes it possible to measure daily working time for each relevant employee.
• Give the employee access. The employee must be able to access their own registered information.
• Retain records for 5 years. Retention runs from the end of the period that forms the basis for calculating the average weekly working time.

It is worth noting that the requirements are about making something possible. The rules describe an outcome — that working time can be measured, seen by the employee and retained — not a particular method.

Objective, reliable and accessible — without over-interpretation

Those three words are often used as a springboard for long lists of technical requirements. That is an interpretation the Act does not itself provide. The Act does not offer an exhaustive technical checklist, so specific features cannot be deduced from the wording.

In concrete terms, matters such as audit logs, locked periods, two-factor approval or a particular data model cannot be presented as certain legal requirements. Such features may well be sensible and make a registration more robust — but they are good practice and risk reduction, not documented provisions.

A more durable approach is to ask whether the registration would hold up in practice: does it reflect actual working time, can it be retrieved again, and can the employee see their own records? Those are the questions the requirements can be translated into without inventing content.

Freedom of method: a digital system is not a requirement in itself

According to the explanatory notes to the bill, employers have freedom of method in how registration is organised. The Act therefore does not in itself require a digital time registration system. In principle, a company may choose a simple solution if it can meet the requirements in practice.

Freedom of method does not mean the choice is irrelevant, though. The responsibility for working time actually being registered, for the information being reliable and accessible, and for it being retrievable for five years rests with the employer whatever the method. The difference between solutions therefore lies mainly in how big the risk is that things slip.

Spreadsheets, Excel and manual timesheets

One of the most common questions is whether a spreadsheet is enough. The answer is that spreadsheets and manual timesheets are neither automatically approved nor automatically rejected. It is the specific solution and the daily practice that together have to meet the requirements.

Typical strengths

• Can be set up immediately and requires no purchase.
• Many employees know the format, so the need for training may be limited.
• Works well in small, stable teams with few types of employment.

Typical risks

• Registration happens far from the work and is filled in afterwards from memory.
• Files are copied and renamed, so several versions exist and it is unclear which counts.
• The employee's access to their own records may end up depending on someone sending or sharing the file.
• Five-year retention can become a manual responsibility rather than a built-in property.
• Missing entries may only be noticed when the records later have to be retrieved.

These risks are not legal verdicts on spreadsheets. They are practical: they describe where things typically go wrong, and therefore what to watch if you keep the solution.

Briefly on exemptions

Certain employees may be exempt from the rules. This applies, among other cases, where the duration of working time is not measured or determined in advance because of the specific characteristics of the work, or where the employee can determine it themselves because they can make independent decisions or hold managerial functions.

The exemption cannot be used as a broad category. It presupposes, among other things, that the employment contract states that the employee is exempt, and collective agreements and rules for particular sectors may affect the picture. Individual roles should therefore be assessed separately rather than placed on a list in advance.

Practical checklist for employers

The points below are control questions you can go through internally. They are not a legal guarantee and do not replace a specific assessment:

• For a random week, can you determine daily working time for every covered employee?
• Does registration happen close to the work, or is it reconstructed afterwards?
• Can the employee see their own registered information without having to ask for it?
• Do you know where the information is stored and who is responsible for it?
• Can records be retrieved throughout the statutory retention period — including for employees who have left?
• Is it agreed what happens when an entry is missing or looks wrong?
• For each role, is it clarified and reflected in writing whether the exemption is used?
• Is the practice described so a new manager can follow it without asking?

How registration can be brought together in practice

If you choose a digital solution, the practical point is that registration should sit close to the work it concerns. At Consitus, time registration is an optional module in Consitus Intranet: employees register time manually or with a start/stop timer, an entry can be linked to a customer and a task and marked as billable, hours are submitted for approval, and access is governed by permissions so employees see their own overview.

We do not claim that a module in itself makes you compliant — that assessment depends on your practice, your groups of employees and any collective agreements. But one shared place to register makes it considerably easier to keep a practice running and to retrieve the records later.

The module builds on the custom-built intranet, where customers, tasks, users and permissions already exist. If you have other repetitive administrative steps around the process, you can also read about automation of workflows. The detailed product page for time registration is currently available in Danish only: tidsregistrering (Danish page).

Sources

The rules and interpretative material in this article are based on the following primary sources (in Danish):

• The Danish Working Time Act, Consolidated Act no. 982 of 12 August 2024 — the current consolidated Act.
• Bill L 68 with explanatory notes — including the freedom of method.
• The Danish Ministry of Employment on the new rules for registering working time.
• The Danish Working Environment Authority on working time and rest periods.

Further reading

If registration is to work in daily life and not only on paper, the next step is to look at how hours are registered, approved and read alongside customers and tasks.