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Recording of working hours becomes mandatory – A first draft law is available

The two rulings on the obligation to record working hours by the ECJ and subsequently also the BAG have caused a stir. The Federal Ministry of Labor has now presented an initial draft bill, which will be negotiated and specified in the legislative process in the coming weeks.

The submitted draft law contains the following important key points:

• Employers will be obligated to record the start, end, and duration of daily working hours (almost) for all employees.

• The recording of working hours must be done electronically.

• The recording itself can be done by the employer, but it can also be delegated to the employees. However, the legal responsibility always remains with the employer.

• Flextime arrangements may still be possible, but the recording of working hours is still required.
  • Employers must ensure that violations of the provisions of the Working Hours Act are made known (duration and timing of working and rest periods). This could be done, for example, by reporting through an electronic time recording system.
    • There are diverse possibilities in SAP HCM time evaluation. In addition to automated checks for working hour violations, evaluations can also be implemented in the Manager Self-Service or email notifications for supervisors (see section below).
  • Although there is no obligation to control, there is an obligation to record working hours.
  • Upon request, the employer must inform the employee about the recorded working hours and provide a copy of the records upon request.

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Companies want to be prepared – what options are already available in SAP HCM?

Where time recording terminals are already in place, the recording of working hours will already be firmly established for a majority of the workforce today and can accordingly be easily extended to the remaining workforce.

However, what if time recording terminals do not exist so far?

In that case, electronic recording via Employee Self-Service (ESS) is a viable option. Many companies have already integrated Employee Self-Services into their HR IT landscape for some time. Consequently, this medium is also ideal for time recording, especially since it works well for employees in the field, on business trips, or on assembly assignments – preferably via smartphones. The ESS app naturally enables clocking in and out when working from home.

Implementation with SAP Fiori App “My Time Events”

To ensure seamless integration between time recording and SAP HCM time management, we recommend an ESS app that is directly integrated into time management. SAP offers the Fiori app “My Time Events” as standard (“My Time Bookings”). This app allows for ad-hoc recording of time events such as “clocking in” and “clocking out.” Furthermore, additional time events can be offered through customization:

In addition to quick entry, the user receives a calendar view providing an overview of past bookings. This allows for the subsequent recording or correction of time entries (performed in the ‘Detailed Entry’ tab):

Depending on customization, approval of time entries can be implemented by the direct supervisor. These time entries are stored in the ‘TEVEN’ table and can be processed by SAP HCM time evaluation as usual. The app also provides the user with features such as an overview of messages from time evaluation, a summary of relevant time balances, and the ability to download the time confirmation.

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For comparison: scdsoft Add-On Solution ‘Clock in/out’

Our scdsoft Add-On Solution ‘Clock in/out‘ is also a way to record working hours through Employee Self-Service, available for both SAP Fiori and Web Dynpro ABAP. Some functionalities, however, are implemented differently compared to the SAP standard app:

• Time stamping always occurs according to the SAP server time, ensuring no manipulation is possible. In ‘My Time Events,’ bookings are made according to the system time of the respective device.
• The time event can be assigned a freely chosen terminal ID and simulates an identical entry in the ‘TEVEN’ table as if it were made through a time recording terminal (no ESS identifier).
• Additionally, a defined origin code can be transmitted.

For the reasons mentioned above, many existing customers opt for a combination of scdsoft ‘Clock in/out’ for time event stamping and SAP ‘My Time Events’ for correcting or adding time events later.

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Analysis Options for Violations of Working Hours in SAP HCM

As mentioned in the key points of the legislative proposal, employers will be required to record working hours in the future and provide corresponding evidence. The obligation to record working hours implicitly means that employers must also track violations of working hours by their employees. This primarily concerns break times, overtime, and rest periods.

To fulfill this obligation as comfortably and automatically as possible, predefined evaluations within the SAP HCM system can be utilized. The possibilities for time evaluation in SAP HCM are diverse. If a violation of working hours is identified by the system, email notifications can be set up for the respective supervisor. Furthermore, these evaluations can be distributed to employees, supervisors, and, for example, members of the works council through a reporting app in the SAP Fiori Launchpad.

In the scdsoft Add-On Solution ‘Reporting Cockpit,’ defined notifications regarding working hour violations can be distributed to all involved parties. Additionally, the capture of a justification (by the employee or their supervisor) is possible. This justification can then be viewed by other bodies such as line managers or works councils:

In a further stage of development, these working hour violations, once justified by the employee and reviewed by the supervisor, can also be recorded in the IT2007 (attendance contingents) through a report, ensuring that overtime is compensated with appropriate allowances.

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Conclusion: Those who wish to take action today have several options

For those who want or need to implement time tracking for their workforce through a self-service scenario today, there are several options within the context of SAP HCM. The proposed legislation already includes the obligation for electronic time tracking, and this is unlikely to change during the legislative process. Even though transitional provisions and exceptions (flexible working hours) are expected in the law, employers are likely to be required to adopt some form of electronic time tracking.

NEW: scdsoft Daily Timesheet for convenient working time recording

The new legal requirements for recording working hours have further boosted the market for corresponding solutions. One of our latest developments is the scdsoft Daily Timesheet, an application that enables simple and efficient recording of daily working hours. This tool offers a solution for companies looking for a user-friendly and flexible way to track working hours. Find out more about the new add-on solution in our blog article.

If you have any questions or are interested in a live demonstration, please don’t hesitate to contact us!

Autor: Sean Schröpfer