Time registration in the Netherlands: what the Working Hours Act asks of you.

In the Netherlands, time registration is not a new obligation. The Working Hours Act requires every employer to keep track of their employees' working and rest times, so the Netherlands Labour Authority can check whether the company follows the rules.

For companies with several sites, shift work or people on the road, this is not a formality. If you work with spreadsheets, rosters nobody updates or standalone time clocks today, your registration quickly falls short during an inspection. This post covers what the law asks, how the inspection works and how to set up time registration in Odoo.

What does the Working Hours Act require?

Article 4:3 of the Working Hours Act requires the employer to keep a proper record of working and rest times. That record must allow the Labour Authority to check whether you comply with the law, such as the maximum working hours and the minimum rest periods.

The law does not prescribe a format. A time clock, a timesheet or a digital system can all work, as long as the record is complete and verifiable. The Labour Authority expects at least the following data:

• Per employee: the data traces back to one employee, for example through a name or employee number.

• Start and end: the actual start and end time of the work.

• Breaks: the total break time per shift.

• Type of work: for example regular hours, on-call duty or standby duty.

• Retention period: you keep the record for at least 52 weeks.

How does the Labour Authority inspect?

During an inspection, the inspector first asks for the registered start and end times. If those are missing, the inspection looks for other sources, such as rosters, time cards, payslips, access logs or employee statements.

If a full check is still possible and it is a first offence, you receive a warning. If a check is not possible or the offence is repeated, the inspection draws up a fine report.

Where does the registration obligation come from?

The rule fits within the European Working Time Directive (2003/88/EC). In the CCOO ruling of 14 May 2019, the Court of Justice of the European Union held that member states must require employers to measure daily working time with an objective, reliable and accessible system. In the Loredas ruling of 19 December 2024, the Court confirmed that this obligation applies to all employees.

The Netherlands already had a registration obligation through the Working Hours Act. The Court's case law confirms what that law asks for: a system that reliably records working time per employee.

• 14 May 2019: CCOO ruling. Member states must require a time registration system.

• 19 December 2024: Loredas ruling. The obligation applies to all employees.

Does the obligation apply to everyone?

The Working Hours Decree makes an exception for employees who earn at least three times the statutory minimum wage. For them, most rules on working and rest times do not apply, and neither does the registration obligation.

That exception is under pressure. In a ruling of 16 November 2021, the Amsterdam Court of Appeal questioned whether it is compatible with European law. According to the court, you must check per employee whether that person truly decides on their own working hours. If you register everyone's time, you do not need to make that assessment person by person.

Objective, reliable and accessible: what does that mean in practice?

It comes down to three questions you can ask about your current registration.

Objective.

The registration shows the hours someone actually worked, not the theoretical roster. You record start, end and breaks when they happen, not afterwards on a Friday.

Reliable.

A correction is possible, but it leaves a trail: who changed what, when and why. A spreadsheet that anyone can edit struggles to meet that standard.

Accessible.

Employees consult their own data. During an inspection, you pull the records per person and per period, without days of searching.

How time registration works in Odoo.

Odoo Attendances records check-ins and check-outs per employee, linked to their working schedule in Odoo Employees. Everything lands in one database, so planning, time off and payroll work with the same data.

Check in where the work happens.

On a kiosk at the entrance with a badge or PIN, in the browser or through the Odoo app on a smartphone. For every entry, Odoo stores the time and, if you enable it, the IP address and GPS location. Location data falls under the GDPR: document why you collect it and inform your employees.

Overtime with an approval.

Odoo calculates extra hours against the working schedule. You set a tolerance in minutes and choose whether a manager approves overtime. You can use approved extra hours for a time off request.

Errors show up immediately.

A missed check-out stands out in the overview, filtered by department, manager or date. With automatic check-out, Odoo closes an open entry after a buffer you choose.

One source for payroll.

If you use Odoo Payroll, the recorded attendances can form the basis for the payroll calculation. If you work with an external payroll provider, the flow of that data is a fixed point in the analysis.

Where do you start?

1. Map who registers time today and how, per site, per shift and per contract type.

2. Choose the right check-in point per group: kiosk, browser or mobile.

3. Set the rules for corrections and for approving overtime.

4. Decide for which employees you rely on the exception, or register everyone.

5. Test with one department or site before you switch the whole company.

Why Dynapps?

Dynapps is an Odoo Gold Partner with 900+ customer references and 280+ Odoo experts across 13 offices. When we implement Odoo, we set up time registration as part of your HR and payroll processes, not as a standalone time clock. The data comes in once and you use it wherever you need it.

Frequently asked questions about time registration in the Netherlands.

Is time registration mandatory in the Netherlands?

Yes. Under Article 4:3 of the Working Hours Act, every employer keeps a record of their employees' working and rest times. An exception applies to employees who earn at least three times the statutory minimum wage, but the Amsterdam Court of Appeal questioned that exception in 2021.

Is a time clock required?

No. The law does not prescribe a format. A digital time clock, a kiosk with a badge, registration in the browser or a smartphone app can all work, as long as you record start, end and breaks per employee and the Labour Authority can check the data. A spreadsheet filled in afterwards struggles to meet that standard.

How long do you need to keep the records?

At least 52 weeks. If you delete the data earlier, the Labour Authority cannot check whether you follow the rules.

What happens if you do not register properly?

For a first offence where a check is still possible, you receive a warning. If the inspection cannot check or the offence is repeated, it draws up a fine report.

How does time registration work in Odoo?

With Odoo Attendances, employees check in and out on a kiosk with a badge or PIN, in the browser or in the Odoo app. Odoo records the time and compares the registered hours with the working schedule. Odoo calculates the extra hours and a manager approves them. Attendances shares one database with Employees, Planning and Payroll, so you reuse the data without entering it again.