Contents
What Excel can do
A spreadsheet costs nothing, anyone can use it, and it is set up in ten minutes. For sole traders, for very small teams and as an interim step until a system is introduced, it is an honest answer.
Legally it is not wrong either: the start, the end and the duration of daily working time can be recorded in it, and the Federal Labour Court order of 13/09/2022 requires no more.
The three weaknesses
First, immutability. A spreadsheet can be changed retroactively without anyone seeing it. In a dispute over overtime and in an audit under section 17 MiLoG that is a problem of proof, and for tax the GoBD expressly require changes to be logged.
Second, the effort. With ten people that is ten files a month that somebody has to collect, check, add up and pass to payroll. That time falls due again every month.
Third, the checks are missing. A spreadsheet calculates, it does not warn. Whether the eleven-hour rest period was observed, whether the break was long enough, whether somebody went over ten hours: all of it is in the figures, but nobody notices.
What the change can be pinned to
The tipping point is rarely the headcount alone. These questions come closer:
- Does somebody have to collect files? From around five people that costs more time than a licence.
- Do invoices come out of the times? Then the GoBD apply, and immutability becomes a requirement.
- Is there shift work? Then a rest period check is needed, which a spreadsheet does not provide.
- Does the business fall under section 2a SchwarzArbG? Then the seven-day deadline applies, and that is hard to demonstrate with scraps of paper.
- Do people work mobile? Then there is no access to the file exactly where the work happens.
What a change costs, and what it saves
Time tracking software in the German market ranges from around 2 euros to 13 euros per person per month, often with base fees, add-ons or minimum terms. For ten people that is roughly 50 to 150 euros a month.
Against that stands the time that currently goes into collecting, checking and recalculating. Anyone allowing two hours a month for that and costing it at the fully loaded cost of an administrator quickly arrives in the same range.
The second calculation is harder to quantify and usually more important: proceedings over overtime conducted without solid records, or a fine of up to 30,000 euros under section 21 MiLoG.
Until the change: setting the spreadsheet up properly
As long as the spreadsheet is still in use, it should at least know the break requirement and produce the weekly total. A ready-made template saves the building work and already contains the calculation logic.
One simple rule helps as well: the file is filed as a PDF each month and countersigned by both sides. That replaces no logging, but it turns a freely changeable file into a dated state of affairs.
This is not legal advice; for a specific case at your workplace you are better off asking someone qualified to give it.
Published by: AMNAU GmbH
Editorial responsibility: Ugur Aydogan, Product development.
Last reviewed: 2 September 2026