Working time records in the UK: what employers actually have to keep

If you employ staff in the UK, you're legally required to keep working time records — but the exact form those records take is more flexible than many employers assume, and more misunderstood than you'd expect.

What the Working Time Regulations 1998 require

The Working Time Regulations 1998 require employers to keep "adequate records" showing whether the limits on weekly working time — an average of 48 hours per week, calculated over a reference period — and night work are being complied with. Records must be kept for at least two years from the date they were made.

Crucially, the regulations don't prescribe a specific format. A spreadsheet, a rota, a payroll system, or dedicated time-tracking software can all satisfy this requirement, as long as the records are genuinely adequate to demonstrate compliance.

The EU daily-recording ruling — and why it doesn't apply directly in the UK

You may have come across claims that "the law requires daily clock-in records" for every employee. This traces back to a 2019 ruling by the Court of Justice of the European Union, in a case brought against Deutsche Bank, which held that EU member states must require employers to set up a system enabling the duration of daily working time to be measured for each worker.

That ruling shaped daily-recording obligations across EU member states — Spain's Real Decreto-ley 8/2019 is a direct example. But the UK left the EU before this case law was transposed into domestic legislation, and no UK statute currently imposes a strict daily clock-in requirement equivalent to Spain's. UK employers should be cautious about treating "daily clocking is legally mandatory" as settled UK law — it isn't, at least not yet.

Why most employers track daily hours regardless

Even without a strict daily-clocking mandate, tracking exact start and finish times every day is simply the most reliable way to prove compliance with the 48-hour average limit, and it's the strongest evidence an employer can produce if a worker later disputes unpaid overtime or working-time breaches at an employment tribunal. Weekly or monthly estimates are harder to defend after the fact — daily records aren't a legal requirement, but they're the practical standard that protects both employer and employee.

Best practices for choosing a time-tracking system

1. Record exact clock-in and clock-out times daily, even though the law technically only requires "adequate" records — it's the strongest evidence in a dispute.
2. Keep records for at least two years, as required by the Working Time Regulations 1998.
3. Give every employee access to their own record at any time — it builds trust and avoids disputes before they start.
4. For staff without a personal computer or work phone — retail, warehouse, or site-based teams — a shared kiosk (a single screen the whole team clocks in on) solves this without needing an individual account per device.
5. Avoid biometric time-tracking unless you genuinely need it — it brings UK GDPR special-category data obligations that a PIN, card, or QR code sidesteps entirely.

RegistoDePonto records every clock-in and clock-out to the second, keeps each employee's full history accessible to them at any time, and lets an admin lock a completed week so it can no longer be edited after the fact.