A time tracking template documents work start times, end times, and breaks – as an Excel spreadsheet, PDF timesheet, or Word document. Since the German Federal Labour Court (BAG) ruling on September 13, 2022, all employers in Germany are required to systematically record working hours. Templates must include at minimum the date, start and end times, and the duration of daily working hours.

Definition: What Is a Time Tracking Template?

A time tracking template is a standardized document for the systematic documentation of working hours. It serves as proof of hours worked and helps companies meet the legal requirements for time recording.

Unlike fully automated time tracking software, a template requires manual or semi-automatic entry of times – either by the employees themselves or by HR staff. Common formats include Excel spreadsheets with integrated formulas, fillable PDF forms, and Word documents.

The term "timesheet" is often used synonymously and traditionally refers more to the paper-based version of time tracking.

Legal Basis – Is Time Tracking Mandatory?

The BAG Ruling of September 13, 2022

With the decision of the German Federal Labour Court (Bundesarbeitsgericht, BAG) on September 13, 2022 (Case No. 1 ABR 22/21), it was conclusively established that employers in Germany are obligated to record the working hours of all employees. The BAG refers to Section 3(2) No. 1 of the German Occupational Health and Safety Act (Arbeitsschutzgesetz, ArbSchG), which, when interpreted in compliance with EU law, establishes an obligation to implement a time recording system.

This decision implements the "time clock ruling" of the European Court of Justice (ECJ) from May 14, 2019. The ECJ had already ruled at that time that member states must require employers to establish an "objective, reliable, and accessible system" for recording working hours.

Important: This obligation applies immediately and without a transition period. While specific legislation with detailed regulations is still pending, the recording obligation already exists now.

What Information Is Legally Required?

According to the BAG decision and the FAQ from the German Federal Ministry of Labour and Social Affairs (BMAS), the following information must be recorded:

• Start of daily working hours
• End of daily working hours
• Duration of actual working time

The specific form of recording is not prescribed – neither the BAG nor the Occupational Health and Safety Act mandatorily require electronic recording. This means Excel templates, PDF timesheets, or handwritten records are generally permissible.

Types of Templates at a Glance

Excel Templates – Advantages and Disadvantages

Excel templates for time tracking are particularly common among small and medium-sized businesses. They offer the advantage that working hours can be calculated automatically – formulas determine daily working time, sum up weekly hours, and display overtime.

Advantages:

• Available for free or at low cost
• Automatic calculations through formulas
• Flexibly adaptable to individual needs
• Well-suited for small teams

Disadvantages:

• Susceptible to manipulation (entries can be changed retroactively)
• Data protection issues (personal data in local files)
• Prone to errors with manual entry
• Becomes unwieldy with many employees

PDF Templates for Printing

PDF timesheets are the simplest form of time tracking. They are printed out, filled in by hand, and filed or scanned.

This method is suitable for businesses without digital infrastructure or as a transitional solution. The disadvantage: Handwritten recording is time-consuming, error-prone, and makes analysis more difficult.

Software vs. Template – When Is It Worth Switching?

Templates are a good starting point but quickly reach their limits. Switching to professional time tracking software is recommended when:

• The team grows (from approximately 20 employees)
• Shift work or flexible working hours predominate
• Audit-proof documentation is required
• Payroll processing needs to be automated
• Remote work and mobile working are increasing

Checklist: What Must a Template Include?

A legally compliant time tracking template should allow for the following information:

Mandatory information:

• Date and day of the week
• Work start time
• Work end time
• Duration of daily working hours

Recommended information:

• Break times (start, end, or duration)
• Employee name
• Personnel number or department
• Signature field for employee and supervisor
• Field for notes (e.g., home office, business travel)
• Weekly and monthly totals

Good to know: A signature is not legally required but increases the binding nature of the records.

Time Tracking When Working from Home

The obligation to record working hours also applies when working from home – the German Working Hours Act (Arbeitszeitgesetz) does not differentiate by work location. Employers must ensure that employees working remotely also document their hours.

In practice, this means: Recording can be delegated to employees. They enter their working hours independently into the template – ideally on a daily basis. However, the employer remains responsible for providing the system and monitoring compliance.

The rest period of at least 11 hours between two working days (Section 5 ArbZG) also applies when working from home. Time tracking helps to verify compliance with this requirement.

Special Regulations for Mini-Jobbers

For marginally employed workers (mini-jobbers), particularly strict documentation requirements apply under Section 17 of the German Minimum Wage Act (Mindestlohngesetz, MiLoG). Employers must:

• Record the start, end, and duration of daily working hours
• Complete the recording no later than the 7th calendar day after the work was performed
• Retain the records for at least 2 years

This obligation exists independently of the BAG ruling and has been in effect since the introduction of the Minimum Wage Act in 2015. Violations can be penalized with fines of up to 30,000 euros.

Retention Requirements and Data Protection

How Long Must Records Be Retained?

The statutory retention periods vary depending on the use case:

• Section 16(2) ArbZG: At least 2 years for overtime records
• Section 17 MiLoG: At least 2 years for mini-jobbers
• General recommendation: 3 years (due to the standard limitation period for wage claims)

Digital retention is permitted – what matters is that the documents are accessible and readable in the event of an audit.

Data Protection with Excel Templates

Working time data is personal data and is subject to the GDPR. When using Excel templates, the following should be observed:

• Files should be password-protected
• Access only for authorized persons (HR, supervisors)
• No storage on private devices or insecure cloud services
• Deletion after the retention period expires

For larger companies or sensitive industries, professional software solutions with integrated data protection features are the safer choice.

Frequently Asked Questions About Time Tracking Templates

Is time tracking mandatory in Germany?

Yes. Since the BAG decision of September 13, 2022, employers are obligated under Section 3(2) No. 1 ArbSchG to implement a time tracking system. The obligation applies immediately and without a transition period. There is currently no direct fine for missing time tracking – however, authorities can issue an order, non-compliance with which can be penalized with fines of up to 30,000 euros.

What information must a time tracking template contain?

Mandatory: Start, end, and duration of daily working hours. Additionally recommended are break times, name and personnel number, as well as a signature field. The specific format – whether Excel, PDF, or handwritten – is not prescribed.

Is an Excel template for time tracking legally compliant?

Generally, yes. The BAG does not require electronic recording, so Excel spreadsheets are also permissible. However, Excel files are susceptible to manipulation and problematic from a data protection perspective. For small businesses, they are suitable as a starting point; with growth, switching to professional software is recommended.

Who is responsible for time tracking?

The responsibility lies with the employer. However, the actual recording can be delegated to employees – they then enter their times themselves. The employer must still provide the system and monitor compliance. Flextime based on trust remains generally possible, but the documentation obligation still applies.

How long must time records be retained?

At least 2 years for overtime records (Section 16 ArbZG) and for mini-jobbers (Section 17 MiLoG). 3 years is recommended due to the general limitation period for wage claims. Digital retention is permissible.

Does the time tracking obligation also apply when working from home?

Yes. The Working Hours Act and the recording obligation apply regardless of the work location. When working from home, employees can record their times themselves, but the employer must provide a suitable system. The 11-hour rest period also applies when working from home.

Do mini-jobbers also have to track their working hours?

Yes, and particularly strictly. Under Section 17 MiLoG, employers must document the start, end, and duration of daily working hours for marginally employed workers – no later than the 7th day after the work was performed. The documents must be retained for 2 years.

What happens if the time tracking obligation is violated?

Currently, there is no direct fine for the absence of a time tracking system. However, the responsible occupational health and safety authority can issue an order to implement a system (Section 22(3) ArbSchG). If this order is disregarded, a fine of up to 30,000 euros may be imposed. Violations of the Working Hours Act itself (e.g., exceeding maximum working hours) are penalized separately.

Conclusion

A time tracking template is a practical tool for implementing the recording obligation that has been in effect since 2022. Whether Excel, PDF, or handwritten – what matters is that the start, end, and duration of daily working hours are documented. For small teams, templates are a good starting point; with a growing workforce or complex working models, switching to professional software is recommended.

When selecting a template, pay attention to complete mandatory information, data protection, and practical usability in daily operations. This way, you not only meet the legal requirements but also create transparency for your team.

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Sources

• Occupational Health and Safety Act (ArbSchG) Section 3. Federal Republic of Germany, 2024. https://www.gesetze-im-internet.de/arbschg/__3.html
• Working Hours Act (ArbZG) Section 16. Federal Republic of Germany, 2024. https://www.gesetze-im-internet.de/arbzg/__16.html
• BAG Decision on Time Tracking (1 ABR 22/21). Federal Labour Court, 2022. https://www.bundesarbeitsgericht.de/presse/einfuehrung-elektronischer-zeiterfassung-initiativrecht-des-betriebsrats/
• FAQ on Time Tracking. Federal Ministry of Labour and Social Affairs (BMAS), 2024. https://www.bmas.de/DE/Arbeit/Arbeitsrecht/Arbeitnehmerrechte/Arbeitszeitschutz/Fragen-und-Antworten/faq-arbeitszeiterfassung.html
• Time Tracking Obligation for Employers. IHK Berlin, 2024. https://www.ihk.de/berlin/service-und-beratung/recht-und-steuern/arbeitsrecht/arbeitszeiterfasung-5666426