Paper timesheets in a folder, spreadsheets on a shared drive, notes in a calendar: that is what time records look like at a lot of companies with German employees today. From January 1, 2027, that stops being good enough. § 8 BVV (§ just stands for “section”) requires electronic, machine-readable payroll documents and time records are explicitly on that list. The basics of the regulation are in our § 8 BVV guide; this post is about your time tracking specifically: which records are affected, what “machine-readable” actually means and how to switch in time.
Why time records count as payroll documents
At first glance, “payroll documents” sounds like wage statements, not time tracking. The connection is closer than it looks though: whenever working time decides the amount or contribution-free status of pay, the time record becomes a payroll document. That mainly covers:
- Mini-jobs and short-term employment: you already have to document the start, end and duration of daily working time under § 17 MiLoG, Germany’s Minimum Wage Act. Auditors want to see these records.
- Tax- and contribution-free bonus payments: Sunday, holiday and night-shift bonuses (SFN-type payments) only stay contribution-free if you can prove the hours actually worked. Flat payments without proof become contribution-liable fast during an audit.
- Minimum-wage-risk sectors under § 2a SchwarzArbG: construction, hospitality, building cleaning, logistics and other sectors with a statutory recording duty.
- Working-time accounts: flexitime, overtime and long-term accounts, whose balances come directly from recorded hours.
In short: if your payroll runs on working time and it almost always does, the underlying records need to be digital from 2027.
What “electronic and machine-readable” actually means
BVV asks for more than “digital in some form”. Three tiers to place your setup on:
| How your records exist today | Fit for BVV from 2027? |
|---|---|
| Paper timesheets in a folder | No |
| Scanned timesheets as a photo or PDF with no data structure | Not sufficient, not machine-readable |
| Digital time tracking with structured data (date, start, end, breaks, balances) and export | Yes |
Then there is the tamper-evidence requirement: later corrections have to be logged and traceable. A spreadsheet fails at exactly this point, because anyone can change any cell with no trace left behind. To an auditor, that is not proof, it is a claim.
One detail that matters for the audit itself: the electronically-supported audit (euBP) transmits data from your payroll software automatically. Time records usually do not live in the payroll software, so the auditor requests them separately. That is exactly when you need structured exports from your time tracking, per person and period, covering the full retention window, including for employees who left long ago.
Double pressure: § 8 BVV meets the working-time recording duty
The BVV deadline is not the only development here. Since a 2022 ruling by Germany’s Federal Labor Court (BAG), employers are already required to record the start, end and duration of every employee’s working time and the planned reform of the Working Time Act explicitly calls for electronic recording. The short version: switching to digital time tracking now handles both requirements with one system.
How to make your time tracking BVV-ready
Step 1: Check where you stand. Where do time records get created today and in what form? Paper and one-off tools (spreadsheets, calendars, notes) go on the replacement list.
Step 2: Capture digitally instead of filing digitally. The cleanest path is to never let working time exist on paper in the first place: employees clock in digitally, corrections run through a logged workflow, balances calculate automatically.
Step 3: Confirm export and retention work. Test whether you can produce a complete, structured record with a correction history for any person over any period.
Step 4: Cover the edge cases. Mini-job holders, field staff, remote workers: each group needs a workable way to record time through an app, browser or terminal, so no shadow paper trail builds up next to the system.
How Timebutler handles this
With Timebutler’s time tracking, your time records come out BVV-ready from the start. Employees log their hours through browser or terminal, start, end and breaks get stored in a structured format, corrections stay traceable and you export the data in a few clicks whenever you need it, per person, per period, audit-ready. Overtime and flexitime balances get tracked automatically too. Your employees clock in, Timebutler documents.
The bottom line
From 2027, time records need to be digital, structured and tamper-evident. Paper timesheets and spreadsheet lists do not clear that bar. The upside: switching to digital time tracking handles the BVV requirement almost as a side effect, while also getting you ready for Germany’s incoming working-time recording law. Timebutler takes the documentation work off your hands, because your records get created automatically wherever employees clock in.
FAQ: Digital Time Records Under § 8 BVV
1 Are time records really payroll documents?
Yes. § 8(2) BVV covers records that feed into contribution calculations. Time records count especially for mini-jobs, SFN-type bonus payments (Sunday, holiday and night shifts) and working-time accounts.
2 Will my spreadsheet still work after 2027?
Practically no. A spreadsheet is not tamper-evident and does not count as structured, auditable data, because changes leave no trace.
3 Do I need to digitize old paper timesheets from previous years?
The duty covers ongoing record-keeping from 2027 onward. For older records, check with your tax advisor or payroll provider what needs to be digitally available by the next audit.
4 Does this apply to small businesses too?
Yes. Unlike the planned reform of Germany’s Working Time Act, § 8 BVV has no size-based exception from 2027.
5 What about trust-based working hours, with no fixed clock-in?
Even under a trust-based model, recorded hours, bonuses and account balances still need documentation once they affect pay. Trust does not replace the paper trail, or in this case, the digital one.
Note: This article provides general information and does not replace individual legal or tax advice. The applicable law in its current version is always decisive.
