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Time registration moving into Danish workplaces – what you need to know

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The Danish Parliament has adopted an amendment of the Danish act on working hours that requires you as an employer to make a system available for recording your employees' working hours. The reason for the amendment is an increased awareness of the importance of recording to working hours to ensure your employees' health and safety.

What does the recording of working hours imply?

Recording working hours is not quite the same as what many associate with time tracking.


Time tracking is a well-known phenomenon within union-covered and technical industries, IT, as well as service-oriented sectors such as law firms and consultancy houses. Employees in these sectors track the number of hours they have spent on a single assignment.


However, the new requirements differ from this practice by focusing on working hours rather than task-specific time consumption.


If one of your employees works from 8 AM to 4 PM, including a self-paid lunch break of 30 minutes, it is only necessary to record the total working hours of 7.5 hours – without specifying the exact times of work start and end.


In the mentioned example, it is important to note that any deviation from the agreed 7.5 hours, whether more or less, is considered a deviation, and the actual working hours for the day in question must therefore be recorded.

What do the new provisions imply?

Before we give you our best advice on what to be aware of regarding implementation, here is a brief overview of the new requirements:


You must implement an 'objective, reliable, and accessible working time registration system'.

This means that you need to allocate resources to establish a time registration system that can document each employee's daily working hours, thereby supporting the existing rules in the working time and work environment laws.


It is not a legal requirement for the system to be digital, but the transition is smoother when supported by a smart solution. Later in the article, we will delve deeper into why this is the case.


You need to pay attention to certain employees.

According to the new requirements, it is possible to exempt certain employees who can be termed 'self-organisers'. The term does not appear as a definition in the law, but it has already become a popular collective term for employees who can organise their total working time themselves.


Self-organisers can be exempt from the 48-hour rule, and as a result, self-managers do not need to register their time. It should also be noted that the rules do not apply to management and specific professions.

In broad terms, the new requirements stipulate that the following three rules must be adhered to:

  • Rest period: The 11-hour rule
  • Working hours: A maximum of 48 hours per week, averaged over 4 months
  • Day off: 1 weekly day off.

Five pieces of advice for implementing the new requirements

Both our People & Payroll Services, Legal Services and Finance IT Services have delved into the legislation and articulated some important issues to take into consideration regarding the new requirements:

  1. Initiate an assessment to define whether your employees are or are not self-organisers.  

This may be a difficult and time-consuming process depending on the data available today – so it would be better to start today than tomorrow. The People function should, together with the business, analyse which employees may be considered self-organisers under the new act..  

  1. Prepare addendums to existing employment contracts.  

Once you have identified the self-organisers, you are to prepare addendums to their employment contracts, stipulating that they are exempt from the protecting rules on rest hours, working hours, and days off. 

  1. Examine what to expect regarding sanctions and regulatory control. 

The rules are accompanied by an expanded sanctioning authority from the Danish Working Environment Authority. The Danish Working Environment Authority has the authority to prohibit or limit employees' possibility of working more than 48 hours a week for health or safety reasons.


The sanctions related to the implementation of a working time registration system that doesn’t meet the requirements of being "objective, reliable, and accessible" are set out in the Danish act on health and safety at work. Therefore, the Danish Working Environment Authority is the supervisory authority and has the power to issue, i.a., enforcement notices and fines.

  1. Update your employee handbook, onboarding programs, and GDPR documents.  

It’s important that you develop and communicate a clear and explicit policy for time registration and working hours. Though the new bill doesn’t require you to specify exact times for work performed, it may be useful. Detailed registration enables you to easily document compliance with the requirements of the Danish act on health and safety at work for 11 hours of daily rest and 24 consecutive hours of rest each week.


In addition, the new provisions must be implemented in your organisation's GDPR processes and any other documentation. This way, your employees will feel better prepared to handle this change.


  1. Put on your change management glasses.  

As the one responsible for the People area, you must be at least as focused on the change and communication task if the concept of time registration is new to the employees in your company. As mentioned above, the background for the new act is the desire to protect employees, and it is important to communicate this clearly to your colleagues.


Most Danish workplaces have a culture characterised by ‘freedom with responsibility’. We are used to self-determination and taking responsibility for our own tasks. Therefore, you shouldn’t underestimate the importance of developing an effective communication plan and ensuring that the management is actively involved in this project.


That is a change task. And preparing a communication and implementation plan, you have a better chance of avoiding unnecessary organisational resistance.

Why you should choose a digital solution

There is a high degree of methodological freedom in how your company can ensure the recording of working hours. However, the legislative change entails quite a comprehensive requirement for you as an employer, as you must use a system that is 'objective, reliable, and accessible', which is why we recommend that you choose a digital and integrated solution.

There are several operational and strategic reasons for this, as you as an employer will then be able to document the mandatory measures:

  • You can easily store the recorded data for five years after the end of the period that forms the basis for calculating the employee's average weekly working hours.
  • You ensure that the employee has access to their own data throughout the employment period.
  • You can reduce human errors and ensure accurate records of working hours, which is crucial for your company to comply with the new legislation.
  • You save time for both employees and the HR department, as it eliminates the need for manual calculation of working hours. Digital time registration systems can often be integrated with other HR and payroll systems, ensuring a streamlined process from time registration to payroll.
  • You get a clear overview of working hours and have the option to set reminders, ensuring that you can respond promptly if there is a need to scale up or down the work effort. This measure can be beneficial for protecting your employees' health, especially in relation to stress.

When choosing a system, remember to pay attention to ...


It is important that your employees have a clear overview of whether their rights are being safeguarded. Your company must continuously be able to check that employees are complying with the law, so action can be taken if this is not the case. This is particularly important if the authorities request documentation or if your employees complain about their rights.


Start by investigating whether your existing systems, such as your financial system (ERP system), already contain the functions you need, or if they can be expanded with new modules.

Work patterns

It is important to consider how your employees work, as this places demands on your choice of system. Are they often on the move, or do they sit at a computer all day? Do they usually work within the same time frame, or can their working hours vary?

If your employees are often on the move, it is easier for them to register their working hours via their mobile phone.

The law does not require working hours to be recorded at specific times or over a specific period. However, the recording of working hours must be reliable, which means that there should not be too long a gap between each registration.

Data storage

If you are considering using an 'easy' solution such as Excel or a similar quick solution, you should be aware that you need to store the data for five years. This means that if you later wish to implement a more comprehensive system, it may become more cumbersome to import master data (all registrations) into the new system. Therefore, it may be advantageous to start with the right system from the beginning.

Do you need help getting started?

Then do not hesitate to contact us. We are used to helping our clients with the implementation of changes and offer assistance with system implementations, legal challenges, interim project management, and consultancy.

Andreas Pedersen
Andreas Helverskov Pedersen
Camilla Bang Kristensen 121
Camilla Bang Kristensen
Senior Manager