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EU Member States
EU Member States
Denmark, Sweden, Germany, France, and all other EU members
EU Working Time Directive 2003/88/EC…
Active from: July 2024 (ECJ CCOO ruling enforced)
All EU employers must record daily working hours for every employee. Enforced following the 2019 European Court of Justice ruling (Deutsche Bank/CCOO case) requiring member states to implement objective, reliable and accessible time-recording systems.
48-hour average maximum weekly working time
calculated over a 17-week reference period
11 hours consecutive daily rest
between working days
24 hours consecutive weekly rest
plus the 11-hour daily rest
20-minute break after 6 hours
minimum rest break during working hours
4 weeks paid annual leave minimum
separate from any additional national entitlement
8-hour average maximum for night workers
per 24-hour period
Daily working hours must be recorded
objective, reliable and accessible records required
Records retained for minimum 2 years
varies by member state — check national law
Opt-out
Available in most member states — must be voluntary, written, and workers cannot…
Penalties
Fines up to €50,000 in some member states. Criminal sanctions in others. Enforce…
Official source
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EEA Countries (Norway, Iceland, Liechtenstein)
EEA Countries (Norway, Iceland, Liechtenstein)
Norway, Iceland, Liechtenstein — not EU members but bound by EEA Agreement
Working Environment Act (Arbeidsmiljølov…
Active from: July 2024 (Norway: expanded requirements under amended Working Environment Act)
EEA countries implement EU working time rules through the EEA Agreement, transposed into national Working Environment Acts. Norway's obligations are legally equivalent to EU member state requirements but enforced under Norwegian law by Arbeidstilsynet (the Labour Inspection Authority).
Working hours must be recorded in writing
real-time, preferably daily, showing actual hours and breaks
Records retained for minimum 2 years
after end of the relevant work period
40 hours maximum normal working week
or 36 hours for shift workers; 48-hour average with overtime
Daily and weekly rest periods
11 hours daily, 35 hours weekly rest minimum
Overtime tracked separately
only statutory overtime recorded as such — collective agreements may differ
Leadership and highly independent positions exempt
but employer must still document that working hours are defensible
Expanded employment contract requirements
from July 2024: breakdown of wage components, leave, shift arrangements
Increased NLIA fine cap from July 2024
up to 50G or 4% of annual revenue — significantly higher than before
Opt-out
Individual opt-out possible by written agreement. Collective agreements can set …
Penalties
Up to 50G (~NOK 6.2 million) or 4% of annual revenue from July 2024. NLIA now ha…
Official source
⚠️ Norway is NOT an EU member. References to 'EU directive' in Norwegian context should say 'Arbeidsmiljøloven' or 'EØS-kravene'. The obligation is real and equivalent — the legal basis is different.
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United Kingdom (post-Brexit)
United Kingdom (post-Brexit)
England, Scotland, Wales, Northern Ireland
Working Time Regulations 1998 (retained …
Active from: Ongoing — January 2024 amendments; April 2026 new record-keeping obligations for holiday pay
The UK Working Time Regulations 1998 implemented the EU directive and were retained as domestic law post-Brexit. EU law no longer has automatic supremacy — ECJ rulings are persuasive but not binding. The UK diverged in 2024: employers must keep records sufficient to demonstrate compliance, but are no longer required to maintain full hour-by-hour logs for every worker.
48-hour average maximum weekly working time
calculated over a 17-week reference period
Records sufficient to demonstrate compliance
NOT required to log every worker's daily hours — diverged from EU post-Brexit
Opt-out records must be kept
written opt-out agreements for those exceeding 48 hours
Records retained for minimum 2 years
for opted-out workers
From April 2026: holiday leave and pay records
retained for 6 years under the Employment Rights Act
28 days paid annual leave
including bank holidays — exceeds EU minimum of 20 days
20-minute break after 6 hours
minimum rest break
Night workers: 8-hour average maximum
with right to free health assessments
Opt-out
UK employers can use a 48-hour opt-out — must be voluntary and in writing. Worke…
Penalties
Unlimited fines for failure to keep records. Employment tribunal claims from wor…
Official source
⚠️ Post-Brexit divergence: The UK no longer requires full daily hour-by-hour records for all workers. 'Adequate records to demonstrate compliance' is the standard. This is a meaningful practical difference from EU/EEA requirements.
Side-by-side: what you must record
| Requirement | EU Members | EEA (Norway) | UK |
|---|---|---|---|
| Daily hours per worker | ✓ Required | ✓ Required | ✗ Not required — compliance-based |
| Breaks and rest periods | ✓ Required | ✓ Required | ✓ Required |
| Written opt-out agreements | ✓ Where applicable | ✓ Where applicable | ✓ Required |
| Minimum retention period | 2 years (varies by state) | 2 years | 2 years (6 from Apr 2026 for leave) |
| Night worker records | ✓ Required | ✓ Required | ✓ Required |
| Annual leave records | ✓ Required | ✓ Required | ✓ From April 2026 (6 years) |
| Enforcement body | National labour inspectorates | Arbeidstilsynet (NO) | Fair Work Agency + HSE (from Apr 2026) |
| Max fine | Up to €50,000+ | 50G / 4% revenue | Unlimited + tribunal claims |
Who is exempt?
Managing executives
Workers who genuinely determine their own working hours are excluded from the 48-hour limit in all three frameworks. The exemption is narrow — job title alone is not sufficient.
Mobile transport workers
Road, rail, sea, and air transport workers are covered by separate sector-specific regulations in all jurisdictions.
Senior independent roles (EEA)
Norway explicitly exempts 'leading and particularly independent positions' from hour-by-hour recording — but the employer must still document that hours are defensible.
Voluntary workers (UK)
Voluntary workers are not covered by the UK Working Time Regulations.
What this means in practice
If you operate in EU member states
You need a system that records daily working hours for each employee, generates time reports, tracks rest periods and breaks, and retains the data for at least 2 years. Integration with your project management tool is the most efficient way to do this.
If you operate in Norway
You need a system that records working hours in writing, preferably daily, with separate tracking of overtime. The records must show actual hours and breaks. Records must be kept for 2 years.
If you operate in the UK
You need records sufficient to demonstrate compliance with the 48-hour average limit. You do not need daily logs for all workers — but for opted-out workers, you must keep records. From April 2026 you must also keep detailed holiday and leave records for 6 years.
If you operate across multiple jurisdictions
You need a single system that can meet the strictest standard across your footprint. In practice, this means daily hour-by-hour recording for all employees — which satisfies EU, EEA, and UK requirements simultaneously.
Time tracking built into your project management
Proglar integrates working time recording directly into project tasks — so compliance happens as a byproduct of normal project work, not as a separate administrative burden. One system. Every jurisdiction.
Frequently asked questions
Does the EU Working Time Directive apply in Norway?
Not directly — Norway is not an EU member. But as an EEA member, Norway is bound by the EEA Agreement, which requires implementation of equivalent rules through the Working Environment Act (Arbeidsmiljøloven). The practical obligations are very similar, but the legal basis is Norwegian law, enforced by Arbeidstilsynet — not EU institutions.
Does the EU Working Time Directive apply in the UK?
Not directly post-Brexit. The UK implemented the directive through the Working Time Regulations 1998, which remain in force as domestic law. EU law no longer has automatic supremacy, and the UK diverged in 2024 by relaxing the daily hour-by-hour recording requirement. The core protections — 48-hour limit, rest entitlements, annual leave — remain largely unchanged.
What is the difference between the EU and UK recording requirements?
The EU (following the 2019 ECJ CCOO ruling) requires employers to maintain objective, reliable and accessible records of daily working hours for each worker. The UK post-Brexit standard is records 'sufficient to demonstrate compliance' — which does not require a daily log for every worker. In practice, employers operating in both jurisdictions should apply the stricter EU standard.
What are the penalties for non-compliance?
Fines vary significantly by country. In Germany, fines can reach €15,000 per violation. In some EU member states, criminal sanctions apply for repeated or wilful breaches. In Norway, fines of up to 50G (approximately NOK 6.2 million) or 4% of annual revenue apply from July 2024. In the UK, the Fair Work Agency (from April 2026) can require repayment of unpaid leave and impose enforcement notices — with tribunal claims available to workers.
Can senior managers opt out?
The 48-hour limit does not apply to workers who genuinely and freely determine their own working hours — including managing executives. The exemption is narrow. Job title and seniority are not sufficient; the worker must genuinely control their hours. Norway additionally exempts 'particularly independent' roles from the recording obligation, but the employer must still document that hours are defensible.