Working-time recording requirements in Denmark
Since 01.07.2024, employers in Denmark have generally been required to record employees' daily working time. The purpose is to make it possible to check the rules on daily rest, weekly rest and maximum average weekly working time.
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The requirement does not prescribe a particular app or recording method. The employer must introduce an objective, reliable and accessible system that makes it possible to measure the daily working time of each employee who is covered.
This guide provides general information, not legal advice. Collective agreements, sector-specific legislation and particular exemptions may change the requirements. Seek legal or professional advice if an employee's status or your recording method is uncertain.
What does the law require?
For a practical comparison of apps, shared kiosks and physical terminals, read our guide to digital time clocks and employee time tracking.
Section 4 b of the Danish Working Time Act contains the central requirements:
| Requirement | What does it mean for the employer? |
|---|---|
| System | Introduce an objective, reliable and accessible system. |
| Daily working time | The system must be able to measure each employee's daily working time. |
| Own access | Employees must be able to access their own recorded information. |
| Retention | Records must be kept for 5 years after the end of the reference period used to calculate average weekly working time. |
The Danish Working Environment Authority states that it may ask to see the records during an inspection, for example if it suspects a breach of the daily or weekly rest rules.
What must be recorded?
The Act requires the system to measure each employee's daily working time. It does not prescribe one technology or a single form for every business. The legislative notes describe a high degree of freedom as to method.
In practice, records must be accurate enough for the business to determine how much the employee actually worked that day and to check:
- daily rest between working periods
- weekly rest
- average weekly working time, including overtime
Scheduled shifts may not be enough if work starts early, ends late or changes during the day. The business must be able to document actual daily working time. Recording start, finish, breaks and later corrections is one practical approach, but the Act does not require a particular time-clock product.
Read the overview of Danish working-time rules when you also need to check 11 hours of daily rest, weekly rest and the 48-hour limit.
Access to the records
The employer must ensure that employees can access their own information in the recording system. This is a separate requirement in the Working Time Act and applies alongside employees' data-protection rights.
Access to one's own hours does not mean that every employee should see colleagues' records or edit approved data. The business must define appropriate permission levels and a clear way to report an error.
The Working Time Act does not prescribe a particular correction flow. The GDPR requires personal data to be accurate and kept up to date where necessary, and data subjects have a right to have inaccurate personal data rectified. The business should therefore document how it investigates and corrects errors without making the history unclear.
A practical correction process can record:
- which entry was inaccurate
- the correct working time
- why the correction was made
- who made it and when
The Act does not prescribe this exact sequence. It simply makes a correction easier for both employee and manager to understand.
For the later review and approval, follow the workflow from schedule to payroll data.
How long must working-time records be retained?
The Working Time Act requires records to be kept for 5 years after the end of the period used to calculate the employee's average weekly working time. The deadline is therefore not necessarily five years from the individual shift.
Working-time records are also personal data. The business needs a lawful basis, must inform employees about the processing and should restrict access and use to legitimate purposes. The GDPR principle of storage limitation does not cancel the statutory five-year retention period, but data should not be kept longer for other purposes without a valid basis.
Who may be exempt?
The requirement does not necessarily cover every employee in every situation. The Working Time Act contains a narrow exemption for workers whose working time, because of the special characteristics of the activity, is not measured or predetermined or can be determined by the workers themselves, where this is stated in the employment contract. Collective agreements and sector-specific rules may also affect scope.
A title such as manager or salaried employee is not enough by itself. Assess the employee's actual autonomy over all working time and document the basis.
How Monoplan can support the workflow
Monoplan's employee time tracking and digital time clock lets employees record start, finish and breaks on mobile or kiosk. Businesses can apply GPS or Wi-Fi rules, compare scheduled with actual time and let designated managers review, correct and approve variances before the payroll report.
Employees can see their own hours in Monoplan. The business must still ensure that its setup covers all relevant working periods, provides the required access and meets the retention requirement.
The employer remains responsible for:
- identifying who is covered by the recording requirement
- ensuring that every relevant working period is recorded accurately
- defining access, employee information and the correction process
- securing the statutory retention period, including when data is later moved or exported
- using the records to check the applicable working-time rules
Check the business's setup
- Map employees, collective agreements and any specific exemptions.
- Decide how actual daily working time and breaks are recorded.
- Ensure that each employee can access their own information.
- Document how errors are reported, investigated, corrected and recorded.
- Define access for managers, payroll staff and other relevant people.
- Document retention for five years after the relevant reference period ends.
- Use actual hours to check daily rest, weekly rest and average weekly working time.
- Review the process when the system, collective agreement or workflow changes.
Sources
The sources were checked on 19.09.2026:
- The Danish Working Time Act, Consolidated Act no. 982 of 12 August 2024, particularly section 4 b on the system, access and retention and section 1 on scope and exemptions.
- Bill L 68 and its explanatory notes, particularly section 3.2 and the notes on section 4 b concerning purpose, freedom as to method and access.
- Danish Working Environment Authority questions and answers on working time and rest, published 02.07.2024.
- The EU General Data Protection Regulation, particularly Article 5 on accuracy and storage limitation and Articles 15–16 on access and rectification.
Neither the Act nor the explanatory notes require a particular app, time clock or approval flow.
Read also
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What is a digital time clock? A guide to employee time tracking
App or kiosk: recording shift starts, finishes and breaks.
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