Employee working time records — are they mandatory?

Proper accounting of an employee's working time is one of the employer's fundamental obligations. It is also a tool for managing human resources within the organisation, including calculating the wages due. It also helps in complying with Polish law regarding working hours. So, is keeping records of an employee's working time mandatory? Let's find out.

Is keeping working time records mandatory?

Let us answer the title question right at the outset. Keeping working time records is mandatory, and this is grounded in the provisions of the Labour Code. The employer is obliged to document the working time of every employee in order to correctly calculate their wages and other benefits.

Working time — definition

Working time is the time during which a given employee is at the employer's disposal at the workplace or at another location designated for performing job duties in accordance with the employment contract. Thus, working time is considered to be the period from the moment the employee reports to the designated place until the completion of their job duties on a given day. This definition indicates that the time an employee spends commuting to the workplace and from the workplace back home is not considered working time.

What are working time records and who do they concern?

The provisions of Polish law, including Article 149 § 1 of the Labour Code, oblige the employer to keep records of an employee's working time. At the same time, the records kept are available for the employee's inspection if they make such a request. This document forms the basis for determining the amount of remuneration for work in a given period, as well as additional work-related benefits. Keeping working time records applies to all employees regardless of the type of contract, the working time system, or the size of the position.

Simplified working time records — when can they be applied?

In certain situations, simplified working time records may be applied, in which no working hours card is kept. This concerns employees who:

• are subject to task-based working time in accordance with Article 140 of the Labour Code,

• receive a lump sum (flat-rate payment) for overtime hours or night work,

• manage the workplace on the employer's behalf.

What do working time records contain?

As a document, working time records must contain specific elements set out in the Regulation of the Minister of Labour and Social Policy on the detailed rules for granting annual leave, determining and paying remuneration for the period of leave, and the cash equivalent for leave, dated 8 January 1997. Under this regulation, working time records must contain information about:

• the time work started and ended, as well as the number of hours worked on a given day,

• the number of overtime hours,

• the number of hours worked at night or on statutory days off,

• the number of hours off work (e.g. leave) with an indication of their basis,

• the number of on-call hours as well as the time the on-call duty started and ended,

• the type and extent of exemptions from work,

• the type and extent of days of absence from work for other justified reasons,

• the extent of days of absence from work without a justified reason,

• the working time of a juvenile employee with respect to work that is permitted only for the purpose of completing vocational training and is normally prohibited for juveniles.

In what form should working time records be kept?

Nowadays, working time records can be kept in:

• paper form (e.g. record cards in ring binders),

• electronic form (e.g. RCP systems, Excel, HR applications).

The choice of the record-keeping method is up to the employer, although in recent years there has been growing interest in the electronic form. At the same time, both forms are legally equivalent. In each of them, it is the employer's obligation to ensure the protection of the data contained in the documentation, including personal data, and to safeguard it against access by unauthorised persons or destruction.

How long must working time records be kept?

Working time records should be kept by the employer throughout the entire period of the given employee's employment, as well as for a further 10 years, counting from the end of the calendar year in which the termination or expiry of the employment relationship occurred. Selected sectors have special guidelines in this regard, requiring working time records to be kept for a longer period. Failure to comply with this requirement exposes the employer to a fine ranging from PLN 1,000 to PLN 30,000.

Who oversees the keeping of employee documentation?

The working time card (the so-called working hours card) is a mandatory employee document that certifies the course of work of each person employed at a given company. On its basis, wages, overtime, leave, and absences are calculated. The body authorised to inspect this documentation is the National Labour Inspectorate, which may initiate an inspection on its own or on the basis of a received report of irregularities.

Employee working time records — are they mandatory? YES

Employee working time records are mandatory for every employer, and their absence may result in a fine being imposed on the employer. So make sure that you keep the necessary employee documentation reliably and in accordance with the actual state of affairs.

Sources:

• Jak ustalać i rozliczać czas pracy, https://www.biznes.gov.pl/pl/portal/00133 (accessed 11.02.2026)

• Ewidencja czasu pracy – jak ją prowadzić? Kogo obowiązuje?, https://www.ingksiegowosc.pl/news/sprawy-kadrowe/ewidencja-czasu-pracy-jak-ja-prowadzic (accessed 11.02.2026)