Germany’s Push to End Unpaid Overtime: Electronic Work Time Recording Becomes Mandatory from 2027

Germany clocked more than 638 million hours of unpaid overtime in 2024 — over half of all extra work performed in the country. Worth an estimated €6.27 billion, that figure is the prime driver behind a new government proposal that would force employers to electronically log every employee’s start, finish and daily duration of work.

The draft bill, drawn up by the Federal Ministry of Labour and Social Affairs, is meant to bolster health protection for staff and crack down on uncompensated extra hours. Employer associations have reacted sharply, with the head of the Federation of German Employers’ Associations (BDA) calling for the plan to be withdrawn, arguing it misses the mark on necessary reforms and contradicts the coalition agreement.

Phased roll?out by company size

Under the proposed law, recording must take place on the day the work is performed. The enforcement timeline is staggered according to headcount:

• General deadline: one year after the law takes effect (planned for early 2027).
• Companies with fewer than 250 employees: two years.
• Micro?enterprises with fewer than 50 employees: five years.
• Businesses with up to ten employees: fully exempt — they may continue using non?electronic methods.

All records must be kept for two years.

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The Labour Ministry stresses that so?called “trust?based working time” remains possible in principle, but the responsibility for correct documentation shifts to the employer.

Flexibilisation with strings attached

Collective bargaining partners will be able to agree on a weekly rather than a daily maximum working time, provided the EU ceiling of 48 hours per week is not exceeded. The balancing period can be shortened from the current six months to four months. Without a collective agreement, the existing cap of ten hours per day (including compensatory leave) stays.

The federal labour minister defended retaining the eight?hour day. Flexibilisation, she said, is permissible only under strict conditions. Individual days may be extended to up to 13 hours including breaks if a collective agreement allows.

The Education and Science Union (GEW) pointed to systematic overload, citing teachers in Lower Saxony as an example.

The recent German ruling on hygiene time highlights how hazardous substances require careful management. In the UK, compliance with the Health & Safety at Work Act 1974 demands proper documentation and risk assessments. A free toolkit offers nine essential tools, including a director’s liability guide, to help you stay on the right side of the law. Get the free Health & Safety at Work Act 1974 Toolkit

Parallel reforms in the pipeline

The time?tracking debate is accompanied by several other labour law changes:

• Sick?note rule: A coalition decision from early July 2026 will require employees to submit a medical certificate from the first day of illness. Telephone sick notes are to be abolished.
• Minimum wage: After rising to €13.90 at the start of 2026, the statutory minimum is scheduled to climb to €14.60 in January 2027. The mini?job earnings threshold will increase to €633.
• Fixed?term contracts: The maximum duration for contracts without a material reason is to be extended from two to four years, through to the end of 2030.
• Hygiene time: On 11 July 2026, the Federal Labour Court ruled that body?cleaning time can count as paid working time when employees are exposed to unusually heavy contamination from hazardous substances.

Next steps

The reform of the Working Time Act was initially put to one side during the coalition committee meeting in early July 2026. A final draft of the bill is expected to be submitted in autumn 2026.

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