Hairdressing and beauty businesses: subject to record-keeping since 2026

What changed on 30 December 2025

The Act on the Modernisation and Digitalisation of Combating Undeclared Work extended the list in section 2a(1) of the Act to Combat Undeclared Work. The hairdressing and beauty trade has been listed there as no. 11 ever since, alongside construction, catering, haulage, the fairground trade, forestry, building cleaning, exhibition construction, the meat industry, the prostitution trade and the security trade.

Taken by itself, that list only governs the duty to carry identification. Its effect on working time arises elsewhere: section 17(1) of the Minimum Wage Act refers to exactly these economic sectors and attaches the record-keeping duty to them.

It becomes relevant in practice from 1 January 2026, because records are kept for whole calendar months.

The wording, both provisions

Section 2a(1) SchwarzArbG, introductory sentence: "When providing services or works, persons working in the following economic sectors or branches are obliged to carry their identity card, passport, passport substitute or identity substitute and to present it to the customs authorities on request". No. 11 reads: "in the hairdressing and beauty trade".

Section 17(1) sentence 1 MiLoG: "An employer who employs employees under section 8(1) of Book Four of the Social Code or in the economic sectors or branches named in section 2a of the Act to Combat Undeclared Work is obliged to record the start, the end and the duration of those employees' daily working time by the end of the seventh calendar day following the day of work at the latest, and to keep these records for at least two years starting from the point relevant for the record."

The reference in sentence 1 is the decisive point: it names no earnings limit but an economic sector. Anyone employing people in one of those sectors records for everyone.

Who the duty applies to

To all employees of the business, regardless of their earnings. That is the difference from the general rule: outside the sectors in section 2a SchwarzArbG, section 17 MiLoG only covers marginally employed people under section 8(1) SGB IV.

Not covered are the owner themselves and family members working without an employment contract. Anyone working independently as a chair renter is not an employee; whether the self-employment holds up is a separate question and depends on the actual circumstances, not on the title of the contract.

What happens in an inspection

The customs authority's undeclared work enforcement unit is responsible. It inspects without notice, and it checks not only the records but also whether the people present have their identification with them; that is the second duty from section 2a SchwarzArbG.

Anyone who fails to keep the records, or keeps them incorrectly, incompletely or late, commits a regulatory offence. The range of fines in section 21 MiLoG goes up to 30,000 euros. Anyone not paying the minimum wage risks up to 500,000 euros, and without records the opposite is hard to demonstrate.

What a salon should do now

Start. The duty has existed since 30 December 2025; it does not hang on a transition period and not on the amendment to the Working Hours Act, which is to be considered separately.

Legally, a paper form is enough for the records. The effort lies not in the recording but in adding it up at the end of the month and finding it again two years later. Anyone working with an appointment book anyway will find it easier with a solution that records the start and the end when clocking and keeps the seven-day deadline by itself.