EU framework

A tool configurable by country
in a tightening framework.

Since the CCOO ruling (C-55/18, 14 May 2019), every Member State must require an objective, reliable and accessible system measuring each worker’s daily working time. Transposition is progressing country by country: a tool configurable per country becomes an advantage for groups and employers of cross-border workers.

2019 to 2028

Since 2019, the framework tightens every year.

Since 2019, the framework tightens every year20192020202120222023202420252026202720282029todayCJEU C-55/18: measure daily time14.5.2019Germany: duty via BAG ruling13.9.2022Luxembourg: right-to-disconnect law30.6.2023Cross-border telework framework1.7.2023Luxembourg: 2019/1152 transposed29.7.2024CJEU Loredas: no exemption19.12.2024AI Act: bans (emotions at work)2.2.2025Luxembourg: Sunday work in retail1.1.2026Pay transparency: EU deadline7.6.2026Luxembourg: disconnection fines4.7.2026AI Omnibus in the Official Journal24.7.2026Germany: law targeted (draft)1.1.2027AI Act: high-risk employment applies2.12.2027Telework agreement: first period ends30.6.2028LuxembourgEuropean UnionOther countries
Six milestones fell in the last two years and three more arrive by 2028: rules must change through configuration, without redevelopment.
Directive 2003/88/EC

The limits to check across Europe.

Directive 2003/88/EC on working time
ArticleRuleCheck in the tool
Art. 311 consecutive hours of rest per 24 hAt every punch
Art. 4Break beyond 6 h of workConfigurable mandatory break
Art. 524 h weekly rest, plus the 11 daily hoursWeekly check
Art. 648 h on average per 7 days, overtime includedRolling average
Art. 74 weeks of paid leaveLeave counters
Art. 8Night: 8 h on average per 24 hNight work qualification
Art. 16Reference periods: 14 days (rest), 4 months (48 h)Configurable periods
Art. 17Derogations, notably autonomous senior managersDerogation profiles

Text: Directive 2003/88/EC.

CJEU case law

Eight rulings that shape the product.

RulingWhat it saysProduct translation
C-55/18 CCOO, 14.5.2019Objective, reliable and accessible system measuring daily timeTimestamping, no change without a trace, employee access to their data
C-531/23 Loredas, 19.12.2024No exemption for domestic workersNo group excluded by default
C-266/14 Tyco, 10.9.2015Without a fixed place, home to first client and last client to home = working timeMobile mode: time starts with the first journey
C-518/15 Matzak, 21.2.2018On-call at home with an 8-minute response = working timeOn-call duty qualified by its constraints
C-344/19, C-580/19, 9.3.2021On-call = work only if constraints are very significantOne on-call type per constraint level
C-107/19, 9.9.2021Break with intervention within 2 minutes: may be workPayable “on standby” breaks
C-585/19, 17.3.2021Several contracts with one employer: rest assessed overallChecks per person, not per contract
C-477/21 MÁV-START, 2.3.2023Daily rest is added to weekly restCombined check of both rest periods
Country overview (October 2026)

One group, several countries, one tool.

CountryGeneral obligationBasisKey point
LuxembourgYesArt. L.211-29Register available to the ITM
GermanyYes, through case lawBAG, 13.9.2022, 1 ABR 22/21Draft of 18.6.2026: electronic recording targeted for 1.1.2027, not adopted
SpainYesArt. 34.9 ET, RDL 8/2019Retention 4 years; digital register planned
AustriaYesAZG § 26Relief for autonomous or fixed hours
GreeceYes, by sectorDigital work cardExtended to 10 new sectors in 2026
NetherlandsYesArbeidstijdenwet, art. 4:3Register of working and rest times
PortugalYesCódigo do Trabalho, art. 202Retention 5 years
PolandYesKodeks pracy, art. 149Relief for managers
IrelandYesS.I. 473/2001OWT1 form or electronic clocking, 3 years
ItalyPartialLibro Unico del LavoroDaily hours in the payroll register
FranceNo, except individual schedulesC. trav. L.3171-2, D.3171-8Shared burden of proof (Cass. soc., 18 March 2020, no. 18-10.919)
BelgiumNo, specific part-time rulesProgramme law of 22.12.1989Law of 18 May 2026: 360 h a year of voluntary overtime

Bases without a link are cited second-hand: to be confirmed before contractual use.

Other EU texts

Other texts that affect time recording.

TextRequirementProduct translation
Directive 2019/1152Inform about standard hours and overtime; unpredictable schedules: reference hours and days, notice period, right to refuse. Transposed by the law from bill 8070 (Mémorial A no. 324 of 29.7.2024)Schedule published with notice period, change history
Directive 2014/67, Art. 9Posting: time records kept availableExport per employee and per assignment
Directive 2002/15, Regulation 165/2014Road transport: 48 h on average over 4 months, 60 h max, records kept 2 years; tachographsTachograph data import
GDPR, Art. 9, 22, 35 and 88Protected biometrics, no solely automated decision, DPIA, national employment rulesSee the GDPR and AI Act page
Directive 2023/970Pay transparency: transposition due by 7 June 2026Reliable hours for hourly pay calculations
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