Electronic time recording: what is allowed and what fits
Recording has been required since 13 September 2022, but it does not have to be electronic. The Working Hours Act prescribes no form, and a list on paper meets the obligation. Electronic is chosen where collecting, calculating and checking would otherwise happen by hand.
- To the minute, without rounding
- App, browser and terminal in the same business
- Checked against maximum working time, rest periods and breaks as you enter
Last checked on 4 September 2026
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Month endSeptember · Krämer payroll officeDone- Made in GermanyDeveloped and hosted in Germany
- Certified data centreISO 27001, located in Germany
- Web, app and terminalBrowser, iPhone, Android, Mac, Windows
- GDPR compliantServers in Nuremberg and Falkenstein
First the obligation, then the form
The two questions often get mixed up, and out of that comes the widespread misconception that electronic recording is required from a certain date. It is not.
The obligation itself follows from § 3 (2) no. 1 of the Occupational Safety and Health Act, as interpreted by the Federal Labour Court on 13.09.2022 (1 ABR 22/21). It has no exception by business size and prescribes no form. The electronic form as the norm appears only in the ministry's draft bill of 18.06.2026, which has neither been adopted by cabinet nor debated in parliament.
Anyone recording electronically today is therefore doing so for practical reasons, not by order. That does not make the reasons any weaker.
The forms and what they mean day to day
All of them are permitted, as long as start, end and duration are recorded in full. The difference lies in the work afterwards and in what can be changed later without anyone noticing.
Six ways of recording, measured against three questions
| Form | Work per month | Changeable afterwards | Checks along |
|---|---|---|---|
| Slips and timesheets | collect, add up, type up | yes, unnoticed | no |
| An Excel file per person | collect, check, merge | yes, unnoticed | no |
| A punch clock with a paper card | read the cards and transfer them | only the transfer | no |
| Browser at the desk | none, the report is ready | nur dokumentiert | yes |
| App on the phone | keiner | nur dokumentiert | yes |
| Terminal with a card | none, the device hangs on the wall | nur dokumentiert | yes |
Slips and timesheets
- Work per month
- collect, add up, type up
- Changeable afterwards
- yes, unnoticed
- Checks along
- no
An Excel file per person
- Work per month
- collect, check, merge
- Changeable afterwards
- yes, unnoticed
- Checks along
- no
A punch clock with a paper card
- Work per month
- read the cards and transfer them
- Changeable afterwards
- only the transfer
- Checks along
- no
Browser at the desk
- Work per month
- none, the report is ready
- Changeable afterwards
- nur dokumentiert
- Checks along
- yes
App on the phone
- Work per month
- keiner
- Changeable afterwards
- nur dokumentiert
- Checks along
- yes
Terminal with a card
- Work per month
- none, the device hangs on the wall
- Changeable afterwards
- nur dokumentiert
- Checks along
- yes
What the choice actually depends on
Not on the technology, but on where the work happens. A business with a computer at every desk needs no device on the wall; a kitchen needs exactly that.
The three routes can be mixed, and they all write into the same time account. Checking that before deciding saves buying a second thing.
- Work at a computer: the browser, with no extra device.
- Changing locations: the app for iOS and Android, voluntarily on a private device too.
- A fixed site without computers: a terminal with a card, with no personal device.
- Mixed teams: all three side by side, with no surcharge per route.
What electronic makes better, and what it does not
What gets better is what is manual work today: the collecting, the adding up, the typing up for payroll, the tracking of remaining holiday. Plus the checking a spreadsheet does not do, because it calculates but does not warn.
What does not get better is the quality of the data itself. Anyone clocking carelessly has careless data, only faster. And whether an arrangement in the business is lawful is not a question software answers: in businesses with a works council that council must be involved under § 87 (1) no. 6 BetrVG, and before the system runs.
Related
Where to go from here, and what waits for you there.
Frequent questions
What we are asked most often about Recording electronically.
Question not answered here? Every step is explained in the help centre.
Send us a messageIs electronic time tracking required?
No. What is required is the recording, not its form. So far the Working Hours Act prescribes no form, and handwritten records are permitted. The electronic form as the norm exists only in the draft bill of 18.06.2026, which is not yet law.
What has to be recorded electronically?
The start, the end and the duration of the daily working time, plus the breaks, because they are deducted. A target time entered in advance is not a record: what is recorded is what was actually worked. It is kept for at least two years (§ 16 (2) ArbZG).
May the time be rounded?
MetronHR does not round, neither to quarter hours nor when clocking. What is recorded stands in the time account to the minute. Rounding that systematically works against employees is open to challenge in employment law, and the dispute costs more than the benefit.
Do we need a works agreement for it?
If there is a works council: yes. Introducing and configuring technical systems capable of monitoring conduct or performance is subject to co-determination under § 87 (1) no. 6 BetrVG. Without a works council that falls away; the duty to inform employees under Article 13 GDPR remains.
What does electronic time tracking cost?
In the German market software prices sit roughly between 2 € and 13 € per person a month, often with a base fee, module surcharges or a minimum term. MetronHR costs 5 € on the Team plan and 10 € on the Professional plan, per person a month, with no setup fee. Hardware arises only if a terminal is wanted.
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