m
r
he requirement applies to all employers, both private and public, regardless of company size. The exemptions listed in the preliminary draft include management personnel and positions of trust, sales representatives, traveling workers, and family-owned businesses. Two caveats: the list is not final until the legislation is passed, and a category-based exemption cannot be determined internally—it is the actual role performed that counts, not the job title on the contract. An audit that reclassifies a “manager” as a regular employee leaves you without any records for the entire period.
No. A file that anyone can reopen and modify without leaving a trace meets neither the criteria of objectivity nor reliability. A signed sheet at the end of the month poses the same problem: the hours are reconstructed from memory, not recorded at the time they are worked. It is precisely this type of practice that European case law was targeting.
Objections / FAQ

