Working time records in the EU, country by country
There is no single European figure. It runs from one year in France to ten in Poland, and in some countries the clock does not even start at the same point. If you have staff in more than one country, this matters.
The periods, country by country
| Country | Retention | Basis |
|---|---|---|
| Spain | 4 years of retention | RD-ley 8/2019, art. 34.9 ET |
| Germany | 2 years of retention | MiLoG, § 17.2 |
| France | 1 year of retention | Code du travail, art. D3171-16 |
| Italy | 5 years of retention | Libro Unico del Lavoro |
| Portugal | 5 years of retention | Código do Trabalho, art. 202 |
| Poland | 10 years of retention | Kodeks pracy |
| Austria | 1 year of retention | AZG, § 26 |
| Belgium | 5 years of retention | Individual account · general from 2027 |
| Denmark | 5 years of retention | Arbejdstidsloven |
| Croatia | 6 years of retention | Pravilnik NN 55/2024 |
| Finland | 2 years of retention | Työaikalaki, § 32 |
| Netherlands | 1 year of retention | Arbeidstijdenbesluit, art. 3.2:1 |
| Sweden | 3 years of retention | Arbetstidslagen |
| Ireland | 3 years of retention | Organisation of Working Time Act 1997, s. 25 |
| Slovenia | Permanent retention | ZEPDSV, 19. člen |
| Czechia | No statutory period | Zákoník práce, § 96 |
| Slovakia | No statutory period | Zákonník práce, § 99 |
| Hungary | No statutory period | Mt. 134. § |
| Luxembourg | No statutory period | Code du travail, art. L. 211-29 |
| Romania | No statutory period | Codul muncii, art. 119 |
| Estonia | No statutory period | Töölepingu seadus, § 28 |
| Latvia | No statutory period | Darba likums, 137. pants |
| Lithuania | No statutory period | Darbo kodeksas, 120 str. |
Four traps that are easy to miss
1. In France, the year is not what it looks like
The figure of three years for France gets repeated a lot. The period in art. D3171-16 for working time computation documents is one year. The three years belong to something else: the limitation period for wage claims and forfait-jours agreements. Keeping three years is prudent; saying the recording rule requires it is not accurate.
2. In Italy and Poland the clock starts later
In Italy the five years run from the last entry, and in Poland the ten from the end of the calendar year in which employment ended. In practice, the records of someone with long service must be kept considerably longer than the bare figure suggests.
3. Portugal requires breaks; Germany does not
Portugal’s art. 202 requires the record to include start and end times and breaks. In Germany, MiLoG does not require breaks to be recorded: the 30-minute break beyond six hours, and 45 beyond nine, comes from the ArbZG, a rest rule rather than a recording rule. The two get confused often.
4. Belgium does not require it yet (but not for long)
Today in Belgium time recording is mandatory only in specific cases, such as part-time work. The general obligation for all employers takes effect on 1 January 2027. If you operate there, now is the time to prepare calmly rather than rush in December.
Where an internal record is not enough
There are countries where keeping a good record of your own does not put you in the clear, because the obligation is to send the data to a state system. Worth knowing before you buy any tool at all:
- Greece. Law 4808/2021 introduces the digital work card: working time must be transmitted in real time to the state ΕΡΓΑΝΗ ΙΙ system. An internal record, however good, does not replace that transmission. Puntual is not sold in Greece, precisely for this reason.
- Italy. The Libro Unico del Lavoro is not just hours: it covers pay and social security, and it is normally kept by the consulente del lavoro. A clock-in app supplies the hours that feed the LUL, not the LUL itself.
- Spain. A draft decree anticipates that the labour inspectorate will be able to consult records remotely. It has not been published in the official gazette, so it is not enforceable today; but if you are choosing a tool now, better one already heading that way.
What this means in practice
The duty to retain sits with the employer, not with the software vendor. Whatever a tool promises: if it disappears tomorrow, you are the one answering to the inspectorate.