Contents
Which trade has to record what
Since the Federal Labour Court's order of 13 September 2022, the recording duty applies to every employer, and no form is prescribed today. It gets stricter for trades on the list in section 2a SchwarzArbG: there, section 17 MiLoG requires the start, end and duration of daily working time to be recorded by the end of the seventh calendar day. The list names construction and the hairdressing and beauty trade, but not, for example, bakeries or joinery workshops. Butchers' trades are expressly excluded there.
Whether a trade business counts as construction depends on whether it provides construction work. Electrical, plumbing, painting, roofing and scaffolding businesses often do; an electrician who only repairs appliances in the workshop rather not. Under section 1 MiLoDokV, the duty under section 17 MiLoG does not apply to employees above 4,461 euros gross a month, or above 2,974 euros if that pay was demonstrably paid for the last twelve full months, nor to spouses, registered partners, children and parents of the owner who work in the business.
Record-keeping duty by trade
| Trade | What has to be recorded | Provision |
|---|---|---|
| Construction and finishing, where construction work is provided, often electrical, plumbing, painting, roofing, scaffolding | start, end, duration for all employees by the 7th calendar day, kept for 2 years, ID carried | Section 17 MiLoG, section 2a(1) no. 1 SchwarzArbG |
| Hairdressing and beauty | as above | Section 17 MiLoG, section 2a(1) no. 11 SchwarzArbG |
| Bakery, joinery, butcher and others | all working time, no prescribed form; beyond 8 hours per working day kept for 2 years | Federal Labour Court 1 ABR 22/21, section 16(2) ArbZG |
| Mini-jobbers in every trade | start, end, duration by the 7th calendar day, kept for 2 years | Section 17(1) MiLoG |
Exemptions under section 1 MiLoDokV for high monthly pay and close family members working in the business. If an industry minimum wage applies to a trade, section 19 AEntG is added.
Construction and finishing, where construction work is provided, often electrical, plumbing, painting, roofing, scaffolding
- What has to be recorded
- start, end, duration for all employees by the 7th calendar day, kept for 2 years, ID carried
- Provision
- Section 17 MiLoG, section 2a(1) no. 1 SchwarzArbG
Hairdressing and beauty
- What has to be recorded
- as above
- Provision
- Section 17 MiLoG, section 2a(1) no. 11 SchwarzArbG
Bakery, joinery, butcher and others
- What has to be recorded
- all working time, no prescribed form; beyond 8 hours per working day kept for 2 years
- Provision
- Federal Labour Court 1 ABR 22/21, section 16(2) ArbZG
Mini-jobbers in every trade
- What has to be recorded
- start, end, duration by the 7th calendar day, kept for 2 years
- Provision
- Section 17(1) MiLoG
Exemptions under section 1 MiLoDokV for high monthly pay and close family members working in the business. If an industry minimum wage applies to a trade, section 19 AEntG is added.
When the drive to the customer is working time
If the day starts at the workshop because material, tools or colleagues are collected, the drive from there to the customer and between two customers is working time. The start is then the time at the yard, not at the customer.
If someone sets off straight from home, it depends. Anyone driving to different customers every day without a fixed or habitual place of work, for example in customer service, is working from departure according to the Court of Justice of the EU (judgment of 10 September 2015, C-266/14). Anyone driving to the same building site for weeks, by contrast, has a habitual place of work there, and the drive is usually the commute. How the drive is paid can be regulated separately by the employment or collective agreement.
Apprentices under 18
Many apprentices in the skilled trades are minors, and the Youth Employment Protection Act applies to them instead of the limits for adults: at most eight hours a day and 40 a week (section 8 JArbSchG), work only between 6 am and 8 pm (section 14(1)) and twelve hours off between two working days (section 13). The vocational school day counts towards working time under section 9 JArbSchG.
On Saturdays, young people may not work in principle (section 16(1) JArbSchG). The exceptions in subsection 2 include bakeries and confectioneries, hairdressing and car repair workshops, but not building sites. A Saturday on site is therefore off limits for a 17-year-old apprentice. Where Saturday work is allowed, there is a day off in the same week for it. In bakeries, young people over 16 may work from 5 am, over 17 from 4 am (section 14(2) and (3)).
How often customs checks in the skilled trades
The Financial Monitoring Unit for Illicit Employment lists several trades as branches of their own in its statistics, separate from main and secondary construction with its 5,514 employer checks. In 2025 it checked 1,641 hairdressing and beauty salons, 468 electrical businesses, 264 painting and varnishing businesses, 174 roofing businesses and 96 scaffolding businesses. In addition, there were 15,787, 4,663, 2,055, 1,727 and 1,353 person checks.
In a check, the records have to be available in German, on request also at the place of work (section 17(2) MiLoG). The timesheet that only reaches the office from the company van at the end of the month does not meet the seven-day deadline if it was blank until then.
- Hairdressing and beauty salons1,641 checks
- Electrical trade468 checks
- Painting and varnishing trade264 checks
- Roofing trade174 checks
- Scaffolding trade96 checks
Figures as a table
| Group | checks |
|---|---|
| Hairdressing and beauty salons | 1,641 |
| Electrical trade | 468 |
| Painting and varnishing trade | 264 |
| Roofing trade | 174 |
| Scaffolding trade | 96 |
Source: German Customs, checks carried out in 2025, as of 03.01.2026
Booking times to the job
In MetronHR, journeymen and apprentices book start, end and break via the app, also without a network: the app stores the booking and transmits it as soon as there is reception again. Every time can be booked to client, project and service, to the minute and without rounding, so the hours per job are there for job costing. Anyone without a work phone clocks in at the terminal in the workshop with an NFC card.
In the Professional plan, the roster also checks the rules for young people: the time window, the five-day week, Saturday and Sunday. On top come the rest period and daily maximum for everyone. At the end of the month, the hours are in the monthly Excel overview and in the payroll file for DATEV.
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 November 2026