From July 1st, all Danish employers are required to introduce a working hours registration system that makes it possible to measure the daily working hours of each individual employee.

The requirement implements a 2019 judgement of the EU Court, with Denmark’s version built on an agreement reached on June 30th last year between the Confederation of Danish Employers, the Danish Trade Union Confederation, and Denmark’s white collar union, the Danish Confederation of Professional Associations.

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In what form must working hours be registered? 

As of July 1st, essentially all employees of Danish companies must register their working hours. Employers are obliged to provide a system fit for purpose – either electronic or manual, although the former is more likely.

Employees must be able to access their own records and look up the information relating to them.

“There are no specific requirements for the form of the system that is used. But it must be ‘objective, reliable and accessible’,” the deputy director of the Confederation of Danish Industry, Christoffer Thomas Skov, said in a statement.

Electronic systems can range from registration of when an employee logs in and out of their work computer, or when they enter a workplace using a key card. Digital companies have also begun offering apps for the purpose.

Manual registration does not necessarily mean written down on paper – the staff member can also send an email, for example, stating the hours they worked that day. They can also enter the hours into a registration system.

Do I have to register at the exact moment of starting or finishing work?

The law does not require this, but it’s generally recommended. There are also no specified periods in which registrations must be kept updated before the next period begins.

“But it must be reliable, so we recommend not leaving it too long between registrations,” Skov said.

Which companies does the law apply to?

All companies are affected by the law, no matter how big or small.

However, the company must have employees, meaning sole traders and self-employed people without and staff are not encompassed.

Which employees must register their hours?

If you’re an employee, you can assume you are encompassed by the law. There are no exemptions for, for example, part-time staff, seasonal workers or temps.

The law applies regardless of how many hours you work.

Employees empowered to set their own schedule — so called self-organisers or selvtilrettelægger — are exempt from the law, but the law states that such people should be able to reorganise their own working time “in its entirety” and that this power should be enshrined in their contracts. As such, this is only expected to apply to CEOs or other very senior executives. 

Do I need to register the time of day I arrive and leave, or just the hours?

This may be determined by the system used at your workplace.

Although the Employment Ministry, when processing the law in parliament, said it would only make the hours themselves compulsory for registration (and not arrival/leaving times), the notes attached to the law as it passed parliament say times of day should, in fact, be registered.

Trade unions and legal experts have subsequently recommended this as correct practice.

What is defined as ‘working time’?

Under the new law, workers will need to register deviations from agreed or scheduled working hours and will also have to register interruptions to the working day if they need to, for example, pop out to the dentist or stay late to finish a presentation. 

More intricate details include whether things like breaks or travel time during business travel, for example, should be registered as part of the working day. This is less clear-cut and you may need to consult your work place – which should set clear guidelines – or collective bargaining agreement (via your trade union).

A rule of thumb is that, if you are clocked in to work, you must be available to your employer to do work if called to (for example, by cutting short a break).

What if my job is exempt from normal rules on working hours?

Some professions – for example, emergency services or armed forces – have exemptions from normal rules related to working hours, for example the provision of at least one day off per week or 11 hours of rest per day.

Labour rules also restrict regular working weeks to 48 hours.

If you work in a profession which has some exemptions to these rules, they will continue to apply and will be unaffected by the rules on registration of working times.

Note: this article is a general guide and for specific advice on your personal situation, you should speak to your employer and/or trade union.