Working time records must include specific fields: start and finish times, hours worked, overtime, night work, on-call duty and its location, and the type and duration of absences. It is best to keep electronic records with a PDF export option and a backup. The legal basis is the consolidated text of the Regulation on Employee Documentation, alongside guidelines from the National Labor Inspectorate (Państwowa Inspekcja Pracy, PIP).
In brief:
- Working time records must include start and finish times, overtime, night work, on-call duty, and absences, as required by the regulation and PIP guidelines.
- As an employer, you should keep electronic records with restricted access, a change history, and PDF export to preserve their integrity and meet GDPR requirements.
- Close the records each month before payday, do not edit saved data, and regularly compare the records with login systems to avoid discrepancies and errors.
- Confusing working time records with attendance lists is a common mistake. Keep these documents separate and do not display absence details publicly to protect your employees’ personal data.
- For larger teams, paper records become difficult to secure and fail to reflect actual working time accurately, so electronic systems or specialist services are a better choice.
Contents
- What working time records must include: legal requirements and fields
- Keeping records in a small business, step by step
- Electronic or paper records: requirements, GDPR, and good practice
- Document storage and retention periods
- Common mistakes and what PIP checks
- Akwadrat’s perspective: how we help organize working time records
- Akwadrat HR and payroll services: organized records without the work on your side
- Where to find regulations and document templates
- Sources
- Frequently asked questions
What working time records must include: legal requirements and fields
Many entrepreneurs think attendance lists and working time records are the same thing. That mistake can be costly during an inspection. PIP draws a clear distinction: working time records are mandatory and used to calculate pay correctly. An attendance list is an internal tool whose format is not regulated by law, as PIP explains.
Section 6 (§6) of the Regulation of the Minister of Family, Labor and Social Policy on Employee Documentation sets out the data your records must contain. The consolidated text lists specific details you must record for each employee:
- the number of hours worked, including start and finish times,
- the number of hours worked at night,
- the number of overtime hours,
- days off and the grounds on which they were granted,
- on-call hours and the location of the duty,
- the type and duration of time off and other absences from work.
You must also account for the working time standard under Article 149 of the Labor Code, which requires employers to keep records that allow them to calculate pay and other employment-related benefits. Without this data, you cannot correctly calculate overtime premiums or payments in lieu of unused leave.
Remember one rule: do not put the type of absence on an attendance list, as this breaches personal data protection rules, a point PIP highlights. Writing “annual leave” or “sick leave” on a list everyone can see exposes information about an employee’s health or personal circumstances to people who have no right to see it. A practical working time record should have separate columns for start time, finish time, standard hours, overtime, night work, on-call duty, and an absence code, kept in a system with restricted access.
Keeping records in a small business, step by step
Setting up proper records does not require expensive software. It requires consistency and a few decisions at the outset.
- Set the working time system and reference period for each employee group, since shift workers and office employees may have different reference periods.
- Choose a recording method: a paper form, a spreadsheet, or a system with login tracking, and document your decision in the workplace rules.
- Set a procedure for confirming attendance, such as a signature, PIN, or mobile app with geolocation for fieldwork.
- Collect requests for overtime, on-call duty, and absences as they arise, not at the end of the month.
- Close the records each month before payday and export the data to payroll.
- Archive the closed version with its date and the name of the person responsible for preparing it.
Take a small graphic design studio in Warsaw’s Targówek district with five full-time employees. The owner kept records in a spreadsheet without editing restrictions. An inspection found that the recorded finish times for two employees differed from the company network login records. The discrepancy was 15 minutes per day, which, across five employees and 21 working days in a month, resulted in a difference of about 26 hours per month in overtime calculations. A closed, password-protected file with a change history eliminates this problem.
Professional tip: Close each month’s records no later than the day before you prepare payroll, and do not edit closed entries. Instead, add a dated and signed correction.
Note: The most common mistake we see among Akwadrat clients is keeping records “in their heads” and filling them in just before payday. By then, nobody remembers who was on call and who worked ordinary overtime, so the calculations become guesswork.
Electronic or paper records: requirements, GDPR, and good practice
The law does not prescribe a particular format, but it does set conditions for electronic records. The document must retain its integrity, meaning it cannot be freely changed without leaving a trace. It must also be available for review during an inspection or a dispute with an employee.
In practice, good electronic records mean:
- access restricted to people handling HR and payroll, never all employees,
- a change history showing the date, time, and identity of the person making each correction,
- the ability to generate a readable PDF printout for a PIP inspection,
- regular backups stored outside the main system.
Working time records are the first document PIP checks during a working time inspection. If you cannot print the last three months of records for a specified employee within a few minutes, your system is not working as it should.
Remote work and shift work need separate attention. For remote work, your records must show the time actually spent performing duties, not just declared availability. We covered this in more detail in our article on employers’ obligations for remote work. For shift work, you need to record which shift the employee actually worked and at what times, because this affects the night work premium.
Paper working time records are still legal and may be sufficient for a microbusiness with one or two employees. Problems arise with larger teams: manually transferring data to payroll leads to errors, and paper is harder to protect against unauthorized access, which matters for GDPR compliance.
Document storage and retention periods
Working time records form part of employee documentation and follow the same retention rules as other HR documents. According to information published on Biznes, you must keep employee documentation throughout employment and for 10 years from the end of the calendar year in which the employment relationship ended.
In practice, this means the following rules for your business:
- count 10 years from 1 January of the year following the employee’s departure, not from the date the contract ended,
- some documentation from before the 2019 changes may require longer retention if it is relevant to determining pension entitlements; if in doubt, check the applicable law on gov.pl,
- once the retention period ends, destroy the documentation so that it cannot be reconstructed, unless the employee has already collected it.
For electronic archives, keep copies in two independent locations, such as your company server and cloud storage with encrypted access. For paper archives, sort documents by year and store them somewhere protected from moisture and unauthorized access. Document sorting and archiving services are available for clients who do not have time to organize these records themselves.
Common mistakes and what PIP checks
PIP inspections of working time records reveal recurring mistakes. Knowing what inspectors check lets you correct your documentation before an inspector has to.
- failing to record on-call hours and the location of the duty, despite the requirement in the consolidated text of the Regulation on Employee Documentation,
- confusing hours worked beyond a part-time employee’s contracted hours with overtime, leading to incorrect premium calculations,
- editing entries without leaving a change history, which undermines the credibility of the entire record in a dispute with an employee,
- discrepancies between working time records and attendance lists when a company keeps both but does not update them together,
- failing to record night work hours, even though they affect the premium payable.
If you find an error in your records, do not delete the entry. Add a correction with the date, an explanation, and the signature of the person making the change, keeping the original entry in the history.
Professional tip: Once a quarter, compare a sample of entries against network login records or shift schedules. This is the quickest way to catch discrepancies before an inspector does.
Akwadrat’s perspective: how we help organize working time records
Working with businesses in Targówek, Bródno, and Praga, we most often see one problem: records exist, but nobody is sure they would stand up to an inspection. Entrepreneurs spend hours manually transferring data to payroll, yet doubts about overtime and on-call duty remain.
Well-organized records are not paperwork for its own sake. They protect you if an employee claims unpaid overtime and during an inspection where every column matters. A consultation to check whether your records meet the regulation’s requirements takes less time than most people fear and shows you where the real risks lie.
— Agnieszka Kopyłowska
Akwadrat HR and payroll services: organized records without the work on your side
Keeping legally compliant working time records takes time you would rather spend on clients than spreadsheet columns. At Akwadrat, we take on this responsibility as part of our HR and payroll services: we handle payroll, Social Insurance Institution (ZUS) declarations, and HR documentation, including working time records ready for export and inspection.
We also sort and archive documents so you do not have to search for a folder from three years ago during a PIP inspection. You can find the full scope and terms of our HR and payroll services on Akwadrat’s services page, and prices for full accounting (books of accounts) and other accounting services in the Akwadrat price list. If you want to check whether your current records would stand up to an inspection, contact us to arrange a free consultation before an inspector checks them for you.
Where to find regulations and document templates
Rather than basing your records on guesswork, use the sources that provide the legal basis. Below are the documents we used to prepare this guide.
- the consolidated text of the Regulation on Employee Documentation, which provides the full list of mandatory record fields in §6,
- PIP’s explanation of the difference between working time records and attendance lists, useful for deciding what you can put on a list visible to your team,
- PIP’s working time guide, covering overtime calculations and reference periods,
- Biznes, where you can check current retention periods.
To compare systems for working time records and HR calculations, you can also refer to .
Sources
- Notice of the Minister of Family, Labor and Social Policy on the consolidated text of the Regulation on Employee Documentation
- What is the difference between working time records and an attendance list? – PIP
- Biznes
- Working time – PIP
Frequently asked questions
How should I keep working time records?
Keep paper or electronic records showing each employee’s start and finish times, overtime, night work, on-call duty, and absences, covering the details required by the consolidated text of the Regulation on Employee Documentation. Close the records each month before preparing payroll and retain a history of all corrections.
Where can I find a working time record template?
There is no single official format for working time records, but templates must contain the fields specified in §6 of the Regulation on Employee Documentation. The consolidated text is available on the Sejm website. You can also find practical spreadsheet templates in the employee documentation section of biznes.gov.pl.
Are working time records mandatory?
Yes. Employers must keep working time records under Article 149 of the Labor Code, with further requirements set out in the Regulation on Employee Documentation. This applies to every employee hired under an employment contract, regardless of the size of the business.
Who keeps working time records?
The employer is responsible for keeping the records. In practice, the task is handled by the person or department responsible for HR, or by an accounting office providing the company’s HR and payroll services. At Akwadrat, we keep these records on our clients’ behalf as part of our HR and payroll services.
