Danish Working Time Act (time registration from 1 July 2024)
Since 1 July 2024 all Danish employers must record each employee's daily working time in an objective, reliable and accessible system. See the requirements and the 48-hour rule.
Who is covered?
All employers in Denmark have been required to record their employees' daily working time since 1 July 2024. The duty was introduced by an amendment to the Danish Working Time Act, following the CJEU's CCOO judgment (C-55/18), which requires member states to mandate systems for measuring working time.
The only exemption is for self-organisers ("selvtilrettelæggere") — employees whose working time is not measured or predetermined, or who set it themselves (typically certain managers). The exemption requires an individual assessment and must be stated in the employment contract.
What do the rules require?
What the law requires
- An objective, reliable and accessible time registration system measuring each employee's daily working time
- Recording the total daily working time is sufficient — no clock-in/clock-out times required — but deviations from an agreed norm must be visible
- Each employee must have access to their own records
- Records must be retained for 5 years after the end of the period used to calculate the average weekly working time
- The records must document compliance with the 48-hour rule: a maximum average of 48 working hours per week over any 4-month period
- Rest rules (11 hours' daily rest, weekly day off) continue to apply alongside
- The choice of system is free — from spreadsheets to dedicated software — as long as the criteria are met
Deadlines and sanctions
Deadlines and sanctions
- The requirement has applied since 1 July 2024 — there is no remaining transition period
- The Act sets no separate fine for missing registration, but without records the employer cannot meet the burden of proof in disputes about overtime and the 48-hour rule
- Breaches of the 48-hour rule can trigger compensation to the employee
- Missing time records can also count against the employer in inspections and labour disputes
How to comply with Verkta
Verkta provides an objective, reliable and accessible time registration system where employees log their daily hours on web or mobile in under a minute. Every employee can see their own records, and the system automatically warns you when someone approaches the 48-hour average over the 4-month reference period. Data is stored securely for 5 years and can be exported as documentation. See pricing and modules — time registration sits alongside your other compliance tasks in one platform.
Frequently asked questions
›Do we have to record exact start and end times?
No. The law only requires that the total daily working time can be measured. Many companies let employees confirm standard hours and only record deviations.
›Can we exempt all salaried staff as self-organisers?
No. The exemption requires an individual assessment of each employee — whole categories cannot be exempted en bloc. It must also be stated in the employment contract or an addendum.
›Is a spreadsheet enough?
Formally yes, if it is objective, reliable and accessible to the employee — but in practice reliability, access control and 5-year retention are hard to guarantee in spreadsheets. A dedicated system removes that risk.