Is time registration mandatory in the Netherlands?
Yes: every Dutch employer must record working and rest times (Art. 4:3 Working Hours Act). What to record, how long to keep it, and the fines.
The short answer
Yes. Every employer in the Netherlands must record the working and rest times of its employees. This comes from Article 4:3 of the Dutch Working Hours Act (Arbeidstijdenwet) and applies to businesses of every size, including those with a single employee.
- What: for each employee, the actual start and end time of work, and their breaks.
- How long to keep it: at least 52 weeks.
- How: any format. Paper, a spreadsheet or software are all allowed, as long as the records are accurate and can be checked.
- Fine: for not keeping proper records, the base amount is €10,000, adjusted for the size of your business.
Seen news about “mandatory time registration from 2027”? That’s about Belgium, not the Netherlands. The Dutch obligation has been in force for years. We explain the difference below.
What does the law say?
The core is Article 4:3(1) of the Working Hours Act:
“Een werkgever […] voert een deugdelijke registratie terzake van de arbeids- en rusttijden welke het toezicht op de naleving van deze wet en de daarop berustende bepalingen mogelijk maakt.”
In English: an employer must keep proper records of working and rest times that allow the Netherlands Labour Authority (Nederlandse Arbeidsinspectie) to check compliance with the Act. That covers maximum working hours, rest periods, breaks and night shifts. The law doesn’t say how you record them.
What do you have to record?
The Act doesn’t list it, but the Labour Authority’s fining policy does. It must at least show which employee started work at what time, when they stopped, and the breaks in between, based on the hours actually worked and the rest actually taken.
In practice, for every employee and every shift:
- Start time, as it actually happened, not as scheduled.
- End time, likewise.
- Breaks. The total break time per shift is enough.
- Traceable to the person. An inspector must be able to see whose hours are whose.
Is a staff rota enough?
Only if you also record where reality differed from it. The Labour Authority is explicit: “Worden afwijkingen niet bijgehouden dan is de registratie niet deugdelijk” (“if deviations aren’t recorded, the records are not proper”). If someone stayed an hour longer or skipped a break, your records must show it. In hospitality and retail, where shifts often overrun, this is where most businesses go wrong.
How long must you keep the records?
At least 52 weeks from the date the records relate to (Article 3.2:1 Working Hours Decree).
You’ll often read “7 years” online. That is the Dutch tax retention period for business records such as payroll, which is a different rule. For the Working Hours Act, 52 weeks is the minimum. If you also use the hours for payroll, you’ll usually keep them longer anyway.
Does it apply to everyone?
Every employer, regardless of size. There’s no exemption for small businesses.
There is one exemption for high earners. Employees aged 18 or over who earn at least three times the statutory minimum wage (including holiday allowance) are excluded from the registration requirement (Article 2.1:1 Working Hours Decree). That exemption does not apply to night work or to work with serious safety or health risks. It rarely applies to staff in hospitality, retail, care, cleaning or logistics.
What about freelancers (zzp’ers)?
A self-employed person isn’t their own employer, so the Working Hours Act registration doesn’t apply. Tracking hours is still wise. To claim the self-employed deduction (zelfstandigenaftrek) you must meet the hours criterion of at least 1,225 hours a year spent on your business, and the tax authority expects you to back that up, for example with a calendar, timesheets and invoices.
Is paper or Excel allowed?
Yes. The Labour Authority states that the way an employer records the data is free (“vormvrij”), and explicitly mentions timesheets and punch cards. A spreadsheet is fine too.
The question isn’t whether it’s allowed, but whether it stays proper. Are the times right? Are deviations recorded? During an inspection, can you quickly show, per employee and going back 52 weeks, who worked when? With a handful of staff, paper works. With changing shifts, several locations or many part-timers, it gets error-prone.
What are the fines?
The Labour Authority can enforce under two laws.
Working Hours Act: no proper records
The base amount is €10,000 per offence, both for not keeping records and for not retaining them (fines under the Working Hours Act). It is adjusted for company size:
| Employees | Factor | Base amount |
|---|---|---|
| fewer than 10 | × 0.5 | €5,000 |
| 10 to 49 | × 0.75 | €7,500 |
| 50 to 99 | × 1 | €10,000 |
| 100 or more | × 1.5 | €15,000 |
Usually a warning comes first. If the inspector can’t check compliance over the whole period, a fine can follow immediately, increased by 50%.
Minimum Wage Act: no record of hours worked
Separately, you must be able to give the Labour Authority, on request, documents showing how many hours each employee worked (Article 18b Minimum Wage Act). This is how it checks that everyone receives at least the minimum wage per hour worked. If you can’t, the fine is €12,000 per employee concerned (Minimum Wage Act enforcement policy). For a team of ten, that adds up quickly.
”Mandatory time registration from 2027”: what’s that about?
Search for time registration and you’ll find plenty about an obligation starting 1 January 2027. That’s about Belgium, where the federal government is preparing a law requiring employers to record daily working time. At the time of writing it is still a draft, not an adopted law: the Belgian National Labour Council issued its advice on 30 September 2026, and employer organisations have called the timeline “absolutely unfeasible”.
For employers in the Netherlands, nothing changes in 2027. The Dutch obligation already exists.
The European background
Belgium, and Germany before it, are acting because of a 2019 ruling by the Court of Justice of the EU (case C-55/18). The Court held that member states must require employers to set up
“an objective, reliable and accessible system enabling the duration of time worked each day by each worker to be measured.”
Member states decide what that system looks like. Germany introduced the duty through a Federal Labour Court ruling (13 September 2022), and Belgium is legislating. The Netherlands already had a registration duty in Article 4:3 of the Working Hours Act, and there is no Dutch bill to change it.
Checklist for employers
- You record each employee’s actual start and end times and breaks, not just the rota.
- Deviations from the rota (overruns, swaps, cover) are recorded.
- You keep the records for at least 52 weeks.
- You can show the hours worked per employee (Minimum Wage Act).
- You know which employees, if any, fall under the high-earner exemption, and that it doesn’t apply to night work.
- You can produce the records quickly during an inspection.
Frequently asked questions
Is time registration mandatory for small businesses? Yes. The Working Hours Act has no size threshold. Even with one employee, you must record working and rest times. The fine is lower for small businesses.
Is a time clock required? No. Any format is allowed: paper, spreadsheet, app or time clock. It must be accurate and checkable.
How long do I have to keep time records? At least 52 weeks under the Working Hours Act. Your payroll records also fall under the 7-year tax retention period.
Do freelancers have to track their hours? Not under the Working Hours Act. But you need hour records to back up the 1,225-hour criterion for the self-employed deduction.
Will time registration become mandatory in 2027? In the Netherlands it already is. The 2027 news is about a Belgian bill.
This article is a general explanation of the rules as they stand on 7 October 2026, not legal advice. If you’re unsure about your own situation, contact the Netherlands Labour Authority or an employment lawyer. Quotes from Dutch legislation are given in the original Dutch; English renderings are our own.
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