New requirements for registration of working hours adopted by the Danish Parliament

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From July 1, 2024, all Danish employers must be able to document their employees' daily working hours using a time registration system. This is stated in the bill that was adopted by the Danish Parliament on January 23, 2024.

The registration is, among other things, intended to ensure that the current rest time rules are complied with, and that employees do not work more than 48 hours per week on average over a period of four months – known as the 48-hour rule. Be aware that if the rules of the Working Environment Act are not complied with by the employer, The Danish Working Environment Authority - Arbejdstilsynet - can impose fines and issue orders.

The law has two significant clarifications when compared to the original bill:

  • Employees are only obliged to register deviations from the agreed and/or scheduled working hours.
  • The bill only requires registration of the employees' total daily working hours without specifying the time period in which the work was performed. 

The clarifications mean that employers can ease the work for employees by filling in the total daily working hours in advance, so employees only need to approve the registration and adjust if there are deviations. 

You can read the bill – in Danish - here.

This is what the time registration system must be able to do 

How employers choose to document, systematize, and register employees' working hours is up to the individual. However, there are some requirements that must be complied with. First and foremost, the system must be objective, reliable, and accessible. In addition, the employee must have access to their own information in the work time registration system. All recorded information must be stored by the employer for five years.

Time registration and GDPR 

When employees register their daily working hours, the GDPR rules must be complied with. Therefore, it is important that the new work processes are implemented in the company's GDPR processes, so that the documentation complies with the applicable requirements. In addition, the company's existing GDPR inventory must be updated, and employees must be informed about this prior to the implementation of time registration.

If GDPR rules are not complied with, a company can be fined up to 4% of their global annual turnover.

Self-organizers can be exempted from the requirement 

As part of the bill, the so-called “self-organizers” can be exempted from the requirement for time registration. The work of a self-organizer cannot be measured and/or determined in advance, and they often have a significant degree of freedom and the opportunity to set their own working hours. If an employer has a self-organizer employed who does not have to register working hours, this must be stated in the employee's employment certificate.

How the law came to be

The new law on time registration was passed based on an EU ruling from 2019 in the so-called Deutsche Bank case. Part of the ruling required all member states to enforce all companies to implement a time registration system in which employees can register their daily working hours.

The implementation process should start now 

Development and implementation of a time registration system is extensive. Therefore, we recommend that the process is started as soon as possible, so that your company is ready to time register when the legal requirement comes into force on July 1, 2024.

At Grant Thornton, we can help identify a relevant time registration system, advise on its use, and the final implementation in your company.



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