Yes—EU law requires employers to use a system that can measure each worker’s daily working time. The Court of Justice of the European Union (CJEU) set out that principle in its 14 May 2019 judgment in CCOO v Deutsche Bank SAE, Case C-55/18. The ruling does not require a particular time clock, app, or software. How the requirement works in practice depends on the relevant Member State’s rules.
Is time tracking mandatory in the EU?
At EU level, the CJEU held that Member States must require employers to establish an objective, reliable, and accessible system that enables the duration of time worked each day by each worker to be measured. The judgment interprets Articles 3, 5, and 6 of the Working Time Directive, read in light of Article 31(2) of the EU Charter of Fundamental Rights, alongside provisions of the Occupational Safety and Health Framework Directive.
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The Court’s reasoning is that rights to daily and weekly rest and limits on maximum weekly working time need to be effective in practice. Without a way to measure working time, it is difficult to check whether those protections are being observed or to provide authorities with reliable information for supervision. Read the CJEU judgment, especially paragraphs 57–65 and the operative part.
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Does EU law require a time clock?
No specific product or format is required by the CJEU ruling. It leaves Member States to set implementation details, including the form of the system, while taking account where appropriate of the characteristics of sectors and undertakings and the requirements of EU law. A physical clock, digital tool, or another method may be used if it meets the applicable rules and provides an objective, reliable, and accessible way to measure daily working time.
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![Pyramid Time Systems 2500 Auto-Aligning Time Clock Bundle [2500K1]](https://m.media-amazon.com/images/I/411v7QKnZiL._SL160_.jpg)
- AUTO-ALIGNING PUNCH CLOCK: Top-loading card feed automatically aligns each punch for clean, accurate time entries; no manual adjustments needed; reduces errors that slow down payroll
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- VERSATILE TIMEKEEPING FOR ANY WORKPLACE: Records arrival, break, lunch, and departure times across 3 in/out punch cycles per day; double-sided time cards cover up to 31 days; choose 12-hour or 24-hour military time format
- COMPACT DESIGN, FLEXIBLE PLACEMENT: Small footprint fits on a desk or mounts on a wall to suit offices, retail, warehouses, and other workplaces; backlit LCDs show time, date, and day at a glance; tamper-proof security lock guards against time theft
- COMPLETE BUNDLE, READY TO USE: Includes 100 pyramid time cards, 2 ink ribbon cartridges, 2 security keys, and a 10-slot time card rack; everything a small business needs to start accurate employee time tracking without additional purchases
The ruling does not endorse a vendor or say that any particular technology automatically complies. Employers choosing a method should assess it against the three qualities named by the Court and check that it fits their country’s requirements.
What does the CJEU C-55/18 ruling mean for employers?
The judgment establishes an EU-level principle, not a complete, uniform compliance manual for every workplace. National law is where employers must check the practical details that apply to them.
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- Coverage: Check which workers and activities are covered by the national rules.
- Records and access: Verify any local requirements on record retention and worker or authority access.
- Exceptions: Confirm whether a national exception applies to the role and circumstances at issue.
- Enforcement: Consult current national legislation and official labor-authority guidance for applicable enforcement rules and consequences.
The judgment refers to Article 17(1) of the Working Time Directive, which permits a derogation for certain activities where working time is not measured or predetermined, or can be determined by the workers themselves, subject to the Directive’s conditions and safety-and-health principles. This is not a blanket exemption for a job title or employer. Whether an exception is available depends on the relevant national law and the facts.
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The CJEU ruling interprets EU law; it does not settle every country-specific question about implementation. It does not itself provide a single EU-wide answer on retention periods, worker access procedures, exemptions, or penalties. Those details should be verified in the current legislation and official guidance of the Member State where the employer operates.
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- Comprehensive Kit - Includes HN3000 clock, 100 cards, two racks, two ribbons, and six keys.
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The judgment was delivered on 14 May 2019, following a preliminary reference in litigation involving a Spanish trade union and Deutsche Bank SAE. The CJEU’s official case summary identifies the decision date and the question referred to the Court.
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- Complete Bundle - Includes HN4500 AutoAlign clock, 200 cards, two racks, three ribbons, and 2 keys.
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- ACCURATE DIGITAL TIMEKEEPING: Eliminate manual errors in employee time tracking with this precise digital clock in machine for employees, easily monitoring arrival, break, lunch, and departure times.
- ADVANCED DATE STAMPING: Simplify document organization with built-in date stamp functionality, featuring preset messages and 3-way printing for efficient proof of receipt and processing.
- USER-FRIENDLY DESIGN: Strategically placed window in the cover allows for easy loading of time cards and documents, enhancing efficiency in daily operations.
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