Since the Federal Labour Court’s (Bundesarbeitsgericht, BAG) ruling in September 2022, it has been clear: in Germany, there is a binding obligation to record working time, which also applies to medical practices. The court clarified that employers must systematically record the start, end, and duration of daily working time for all employees.
With the planned legal reform of the Working Time Act (Arbeitszeitgesetz, ArbZG), electronic time tracking is set to become the standard from around 2026 onwards. For many practices, this means that working hours must be documented transparently, traceably, and in a manner that can withstand scrutiny in court — regardless of practice size or specialty.
In everyday life, however, the obligation can actually be a blessing. Digital time tracking relieves teams, prevents mistakes, and adds structure to a hectic workday. Many physicians report that they have significantly less effort with payroll, rota planning, and holiday requests when they use simple, browser-based time tracking solutions such as Timebutler.
Note: This article provides general information about time tracking in German medical practices and should not be considered a substitute for individual legal advice.
TL;DR: Time Tracking for Medical Practices at a Glance
- Who this article is for: owners and managers of medical practices, MVZs, dental, and therapy practices in Germany who want to implement legally compliant and efficient time tracking for their teams.
- Legal situation: since the BAG ruling of 13 September 2022, employers must record the complete daily working time of their employees; the ongoing reform of the Working Time Act is expected to specify that this has to be done electronically from 2026 onwards.
- Systems you can use: browser-based time tracking, terminals, mobile apps, or tablets are considered future-proof. Manual time sheets are still possible today, but they are error-prone, hardly audit-proof, and will likely no longer be sufficient once electronic recording becomes mandatory.
- Key compliance topics: practices must ensure GDPR-compliant processing, clear roles and access rights, secure EU-based data hosting, and retention of working time records for at least two years in line with the Working Time Act.
- How to get started: review current processes, define clear internal rules, and choose a simple digital solution (for example, a browser-based tool like Timebutler). Start with a test phase and train the team so that everyone records their hours consistently.
Legal Basis: Why Time Tracking Is Already Mandatory in Medical Practices
The obligation to record working hours does not start with the future reform of the Working Time Act. It already exists today and is based on several legal pillars:
- EU Working Time Directive and ECJ Case Law: in 2019, the European Court of Justice (ECJ) ruled that member states must oblige employers to set up reliable systems to measure daily working time.
- German Occupational Safety Act (Arbeitsschutzgesetz, ArbSchG): The BAG derives the obligation to record working time from the employer’s duty to design work in a manner that protects employees’ health, including protection against excessive working hours.
- BAG Ruling of 13 September 2022 (1 ABR 22/21): The court clearly states that employers must record the start, end, and duration of employees’ daily working time.
For medical practice owners, this means:
- You must record working time. Not only overtime or Sunday work, but the entire daily working time of your employees.
- You may delegate the entry of working times (for example, to your employees), but responsibility remains with you as the employer.
From When Does the Time Tracking Obligation Apply in Medical Practices?
Short answer: from now on.
The BAG ruling from September 2022 has already taken effect. The planned amendment to the Working Time Act will not introduce the obligation itself. It will merely standardize it (for example, by requiring electronic recording and specifying deadlines for recording on the same day).
The obligation applies essentially to all outpatient healthcare facilities in Germany, including:
- General practitioner and specialist practices
- Medical care centres (MVZ)
- Group practices and practice networks
- Dental practices
- Physiotherapy, occupational therapy, and speech therapy practices
- Other healthcare providers with employees (for example, midwife centres or psychotherapy practices with staff)
Only self-employed physicians without any employees are currently exempt, because there is no employment relationship in which they act as employers.
Which Time Tracking Systems Are Allowed in Medical Practices?
Medical practice owners are relatively free to decide how they record working time – as long as the system is reliable, complete, and traceable.
1. Digital Time Tracking via Browser or Terminal
Digital solutions are currently the most common choice in practices, because they are:
- Tamper-Resistant and Legally Robust: changes and corrections can be logged, so that you have a complete audit trail for inspections or disputes.
- Efficient in Everyday Life: employees clock in and out directly at the reception PC, a tablet in the back office, or via a wall terminal.
- Easy to Roll Out: browser-based tools such as Timebutler work without installation. You simply log in and can start configuring your practice settings.
2. Mobile Time Tracking via Smartphone or Tablet
Mobile time tracking is especially useful wherever staff are not always on site. For example, in home visits, nursing home rounds, or outreach clinics.
- Working times can be recorded directly on the move via smartphone, tablet, or browser.
- Data is synchronised centrally, so the practice office always has an up-to-date overview of hours worked, absence, and overtime.
Timebutler, for example, can be used via smartphone or tablet without a dedicated app – employees simply access the browser.
3. Manual Timesheets and Excel Lists
Paper timesheets or Excel lists are still generally permissible today, but they are critical for several reasons:
- They are error-prone (forgotten entries, illegible handwriting, version chaos).
- They are not audit-proof, especially if changes are not traceable.
- They are not future-proof because current legislative drafts explicitly refer to electronic recording as the standard.
If you currently use manual timesheets, it is recommended that you switch to a digital time tracker as soon as feasible.
Related: Google spreadsheet vs. time tracking solution for businesses
What Must Time Tracking Software for Medical Practices Be Able to Do?
A legally robust and practical time tracking system for medical practices should cover far more than just the “start” and “end” of working time. In practice, the following functions are particularly important:
- Recording Start, End, and Duration of Daily Working Time: the system must allow precise daily recording, including date and employee assignment.
- Automatic Calculation of Breaks and Overtime: break rules as per the Working Time Act (for example, minimum breaks after six hours) should be stored so that breaks are calculated correctly, and overtime is clearly visible.
- Holiday, Sickness and Absence Management: holiday requests, sickness notifications, and other absences (training, parental leave, etc.) should be mapped in the same system to provide a complete picture of staff availability.
- Exports for Payroll and Tax Consultants: data should be exportable in formats that your payroll office or tax consultant can process with minimal manual work.
- GDPR-Compliant Data Storage in the EU: time tracking data are employee personal data and must therefore be stored in compliance with GDPR, ideally on servers located in the EU.
- Role-Based Rights Management: practice management, physicians, and employees should have different views and access rights (for example, employees see only their own times; management sees evaluations).
- Audit Security and Change History: it should be possible to see who changed which time entry and when – important for inspections and internal clarity.
- Multi-Location Capability: for MVZs or practices with multiple locations, the system should support several sites and staff groups.
Browser-based systems, such as Timebutler, work well for medical practices because they offer these functions without requiring local installation. They can also be used virtually on any device with internet access.
What are the Benefits of Time Tracking for Medical Practices?
The legal obligation is only one side of the coin. In everyday life, a modern time tracking solution offers very tangible advantages for medical practices.
1. Less Administrative Work in the Practice Office
- Fewer manual corrections and fewer individual questions about overtime and balances.
- No chasing missing timesheets at the end of the month – all entries are already in the system.
- Payroll runs more smoothly because data can be transferred directly to payroll accounting or your tax consultant.
2. More Transparency and Fairness in the Team
- Employees can view at any time how many hours they have worked, how much overtime they have accrued, and how much holiday time remains.
- Discussions about “who worked how much” become more objective as the data speaks for itself.
- Transparent rules about breaks, stand-by duties, and travel times promote trust and satisfaction.
3. Better Planning of Staffing and Rotas
- Practice management has a clearer view of absences, bottlenecks, and workload.
- Rotas can be better coordinated with school holidays, part-time models, and on-call services.
- Overload situations become visible earlier, so you can counteract them (for example, by reducing overtime or hiring additional staff).
4. Stronger Legal Position in Disputes and Inspections
- In disputes over overtime, breaks, or duty rosters, you can produce complete and traceable records.
- In inspections by supervisory authorities, you can quickly provide the documentation required under the Working Time Act and occupational safety law.
How Does Time Tracking Affect Data Protection, GDPR, and Security in Medical Practices?
Medical practices work with particularly sensitive data – even if time tracking itself primarily concerns employee data, it takes place in an environment with highly protected health data.
Legal Framework
Important legal bases include:
- GDPR (General Data Protection Regulation): especially the rules on lawfulness of processing, special categories of data, and security of processing.
- Federal Data Protection Act (BDSG) and the specific professional confidentiality obligations for physicians.
- Working Time Act (ArbZG): specifies, among other things, that working time records must be kept for at least two years.
In most practices, the legal basis for recording working time is the legal obligation under labour and occupational safety law.
Practical GDPR Requirements for Time Tracking Systems
When choosing and configuring your time tracking solution, you should pay particular attention to:
- Access Only for Authorised Persons: clear, role-based access concepts (for example, employees only see their own data; management sees the whole team).
- Encrypted Transmission and Storage: HTTPS, modern encryption standards, and secure server infrastructure are a must.
- Data Minimisation: only collect what you actually need: working times, breaks, absence categories; no unnecessary additional information.
- Retention and Deletion Concepts: define how long working time records are stored (at least two years; longer if other laws require this) and how they are deleted afterwards.
- Order Processing Agreement (AV-Vertrag): if you use a cloud solution like Timebutler, you should conclude a GDPR-compliant data processing agreement with the provider.
- Information for Employees: staff must be informed transparently about what is recorded, for what purpose, and how long data is stored.
Modern digital systems such as Timebutler are designed so that these requirements are largely fulfilled “out of the box”, which is a clear advantage over handwritten lists or simple Excel tables.
Practice Example: How to Introduce Time Tracking to Your Medical Practice
A paediatric practice with two female physicians and eight medical assistants had long struggled with:
- Different paper timesheets,
- Spontaneous rota changes, and
- Unclear overtime status.
In the rush of everyday practice, there was often no time to log times immediately. At the end of the month, the practice management team had to chase missing information, and payroll regularly became a source of stress.
Switching to a Browser-Based Tool
The practice decided to introduce a digital, browser-based time tracking system:
- The team clocked in and out directly at the reception computer or via a tablet in the back office.
- Sick days and holiday requests were recorded centrally in the same system.
- The practice management could see at a glance who was present, who was absent, and how overtime was developing.
Noticeable Improvements After a Few Weeks
After only a few weeks, the practice felt like it had clear benefits:
- Fewer errors and gaps in the records.
- No more chaos at the end of the month, as payroll could be prepared much faster.
- Fewer queries from employees because everyone could see their own balances.
Experiences from Timebutler customers show that it is precisely these everyday improvements that make the most significant difference in small practices.
Step-by-Step: How Medical Practices Can Prepare for Digital Time Tracking
To prepare your practice for digital time tracking in a structured way, do the following:
- Analyze Your Current Situation: look at how working times are currently recorded, where errors frequently occur, and which information you regularly need for payroll and rota planning.
- Define Clear Internal Rules: clarify together with your team how breaks, on-call duties, house visits, and travel times are to be recorded. Document these rules in writing and make them part of your practice guidelines.
- Choose a Digital Solution: select a GDPR-compliant system that fits your practice. It should be browser-based, cloud-hosted in the EU, easy to use, and with the required functions (holiday management, exports, mobile use). Timebutler is a good fit for many medical practices because it can be used in just a few minutes without installation.
- Start with a Test Phase: many providers, including Timebutler, offer a free test phase. Use this period to try out workflows with your team, adjust settings, and clarify questions before you make binding decisions.
- Train the Team and Appoint a Contact Person: explain to your employees why time tracking is necessary, how it works, and who they can contact if problems arise. This creates acceptance and ensures that times are recorded consistently.
- Review and Optimise Regularly: after the first few months, look at how well the system works: Are there still many manual corrections? Are overtime and absences transparent? Adjust rules and configurations where necessary.
Time Tracking is a Legal Obligation and a Real Opportunity for Modern Practice Management
Time tracking in medical practices is no longer an optional “nice to have” but a legal necessity. It is also a real opportunity to make your practice more efficient and future-proof.
Digital systems reduce administrative effort, strengthen transparency within the team, and ensure that your practice is well prepared for inspections and the planned legal changes from 2026 onwards. For many practices, browser-based tools such as Timebutler are a straightforward way to implement requirements quickly and simultaneously noticeably relieve the burden on everyday operations.
If you want to prepare your practice for digital time tracking without bureaucracy, you can test Timebutler free of charge. Simply register and try Timebutler with your team for six weeks without any contractual commitment or payment information required.
