Here’s what it’s all about:
- Mobile Time Tracking via App
- How mobile time tracking works
- What Makes for Reliable Time Tracking
- What Companies Need to Consider Regarding Data Protection
- How to Log Time Without an Internet Connection
- How to reduce administrative overhead
Mobile time tracking via an app allows employees to record their working hours directly on their smartphone or tablet. This is generally legally permissible provided that the tracking system is objective, reliable, and accessible. The start, end, and duration of the daily work shift must be recorded. Companies must also comply with data protection regulations, ensure the traceability of corrections, and, where applicable, respect employee participation rights. GPS is not generally required for time tracking.
👉 Mobile time tracking from ZMI: The ZMI – App
🧐 When does it make sense to use a mobile app for time tracking?
Mobile time tracking is particularly useful in situations where employees do not have a fixed workstation or regular access to a stationary time-tracking terminal. Instead of documenting work hours retroactively on timesheets, employees can log their hours directly at their work location using their smartphones.
For companies with decentralized teams, mobile time tracking offers a way to integrate different work locations into a single time-tracking system. This is not only about documenting legally required working hours but also about providing up-to-date information for workforce planning and payroll preparation.
Typical areas of application include:
Sales representatives and technical field service teams record their start and end times, as well as breaks, regardless of the company’s location.
Employees record their working hours directly on the construction site. With the appropriate system support, these hours can be assigned to individual construction projects.
Service technicians track their working hours while visiting different customers and can document job-related activities.
Employees track their work hours using a mobile device, without the need for additional hardware.
Employees remain connected to a central time tracking system regardless of where they work.
👉 It is crucial that mobile time tracking be integrated into the rest of the HR processes. If app-based time entries are processed separately from desktop-based time entries, this creates additional reconciliation steps and potential sources of error.
👩⚖️ Is time tracking via smartphone legally compliant?
Yes, tracking work hours via smartphone is generally permitted in Germany. The key factor is not the device used, but whether the system in question meets the legal requirements.
What do working time laws stipulate regarding mobile time tracking?
The obligation to systematically record working hours stems in particular from the decision of the Federal Labor Court dated September 13, 2022 (Case No. 1 ABR 22/21). The Federal Labor Court (BAG) ruled that employers are required under Section 3(2)(1) of the Occupational Safety and Health Act (ArbSchG) to implement and use a system for recording daily working hours (See: When Does Working Time Recording Become Mandatory Under the ECJ Ruling?). This is also based on the judgment of the European Court of Justice dated May 14, 2019 (C-55/18). According to this judgment, the system must be objective, reliable, and accessible.
In practice, this means:
✅ Document the start of the daily workday
✅ Record the end of the daily work shift
✅ Record the total duration, including overtime worked
✅ Account for breaks in a way that ensures the actual working hours remain traceable
✅ Store records reliably and keep them accessible
These requirements generally apply regardless of whether employees work in the office, from home, or in the field.
Will electronic time tracking be mandatory in 2026?
The general obligation to record working hours already exists. However, the Federal Labor Court’s (BAG) ruling does not establish a general requirement to record all working hours exclusively electronically.
The Federal Ministry of Labor and Social Affairs (BMAS) expressly clarifies that there is still no general legal requirement for electronic working time tracking. The federal government has announced plans to establish specific legal provisions for electronic working time tracking.
For companies, this means they should not wait for further legal regulations before introducing a reliable system for recording working hours. An app is one possible digital method of recording, but it is not the only legally permissible one.
👉 More information: When will working time tracking become mandatory as a result of the ECJ ruling?
How long must time sheets be retained?
Section 16(2) of the Working Hours Act (ArbZG) requires employers to record working hours that exceed the daily working hours on business days as defined in Section 3, sentence 1, of the ArbZG. The law stipulates that these records must be retained for at least two years.
This specific two-year period does not automatically constitute a blanket statutory retention period for all working time data. Depending on the industry, employment relationship, and intended use, additional documentation and retention requirements may apply.
When using mobile time tracking, companies should therefore establish a data deletion and retention policy that takes into account statutory record-keeping obligations and data protection requirements.
⚠️ Mobile Time Tracking and Data Protection: What Do Companies Need to Keep in Mind?
When performing time tracking via an app, personal employee data is processed. This includes, in particular, work time entries, timestamps, user IDs, and, where applicable, location information.
The processing must comply with the principles of the General Data Protection Regulation (GDPR). Of particular relevance are Article 5 of the GDPR on purpose limitation and data minimization, Article 6 of the GDPR on lawfulness, and Article 32 of the GDPR on the security of processing. With regard to employee data, Section 26 of the Federal Data Protection Act (BDSG) must also be reviewed, taking into account the requirements of EU law.
Are employers allowed to track GPS location using a time tracking app?
Occasional location tracking may be permissible under certain conditions, such as when companies must demonstrate, for a specifically defined business purpose, at which work site a time entry was made.
However, the mere recording of working hours generally does not require GPS data. The start and end of work can be documented even without location information.
Companies should therefore verify, before activating a GPS function, whether location processing is necessary, proportionate, and based on an appropriate legal basis. The mere technical availability of the function does not justify its use.
👉 Continuous location monitoring is particularly problematic. One-time location data recorded during a time entry differs significantly from continuous tracking of movements.
Is employee consent sufficient for the use of GPS?
Consent may constitute a legal basis, but it must be voluntary, informed, specific, and revocable. In an employment relationship, the voluntary nature of consent must be examined with particular care due to the existing relationship of dependency.
A company agreement may also provide a legal basis under data protection law for certain processing activities, subject to the conditions set forth in Art. 88 of the GDPR and § 26(4) of the BDSG. However, it does not justify disproportionate monitoring.
👉 In practice, it is recommended to clearly define which data is collected, who is authorized to access it, for what purposes it is used, and when it is deleted.
Does the works council need to be involved in the implementation of a time tracking app?
When introducing and using a time tracking app, the works council may have rights of co-determination. Section 87(1)(6) of the Works Constitution Act (BetrVG) is particularly relevant if the technical system is capable of monitoring employees’ behavior or performance.
In addition, Section 87(1)(2) and (7) of the BetrVG may be applicable. The Federal Labor Court (BAG) distinguishes between the statutory obligation to track working hours and the discretionary leeway in its implementation, which is subject to co-determination.
A works agreement can, for example, regulate the permitted methods of recording, mobile devices, location tracking features, access rights, and correction procedures.
👉 Read more in the following blog post: Works Council and Time Tracking: Co-determination, Works Council Agreement, and Practical Implementation
⚙️ What features should a mobile time tracking app offer?
A time tracking app should require as few steps as possible while still providing the necessary data for centralized time management.
Record Start Time, End Time, and Breaks
The basic function is to log work hours directly on a smartphone. This includes clocking in, clocking out, and logging breaks.
👉 It is important that the actual hours worked are recorded. Automatic break rules must not result in the hours worked being inaccurately shortened.
Offline time tracking with subsequent synchronization
A stable Internet connection is not available at every work site. On construction sites, in technical facilities, or when visiting different clients, mobile network coverage may be limited.
An offline feature allows you to first record entries locally and then transfer them to the central time-tracking system once the connection is restored.
👉 To ensure that the records remain traceable, the original time of entry, subsequent transfer, and any corrections should be clearly distinguishable.
Request Time Off and View Time Balances
Mobile time tracking can go beyond simply logging attendance. If vacation requests, flex time, business trips, and other absences are submitted directly through the app, employees don’t need a separate office workstation to do so.
👉 Displaying time accounts and current balances provides additional transparency regarding recorded working hours. This requires a consistent database between the app and the central time management system.
Assign Project Times and Order Times
For companies in the service, skilled trades, or technical field service sectors, assigning time to projects or orders may be relevant in addition to employee time tracking.
👉 In this context, a clear distinction must be made between employee time and project time. For example, an order-related entry is used for cost accounting or performance documentation and does not automatically replace the legally required recording of working hours.
Revisions and Approval Processes
Missing or incorrect entries should be able to be processed through a standardized correction process. Those responsible need appropriate review and approval options for this.
👉 It is important that employees be able to correct incorrect time records and that companies be able to track which changes were made.
Terminal, browser, or app: Which time tracking solution is best suited for which use case?
The appropriate data collection method depends on the work location, technical infrastructure, and organizational structure. In many medium-sized companies, a combination of different data collection methods is advisable.
Terminal, Web Client, or App: Which time tracking solution is best suited for which use case?
Time-Tracking Terminal: Production , Administration, Fixed Locations
Employee Portal (PC Workstation): Office , Home Office
Time tracking app: Field staff , construction sites, service
Time-tracking terminal: stationary terminal
Employee portal (PC workstation): PC , laptop, or tablet
Time tracking app: smartphone or tablet
Time-tracking terminal: location-based
Employee portal (PC workstation): accessible on mobile devicesvia a browser
Time tracking app: designedfor mobile use
Time-Tracking Terminal: Hardware , Power, System Integration
Employee Portal (PC Workstation): Browser and Network Access
Time tracking app: mobile app, compatible device
Time-tracking terminal: depends on the terminal
Employee portal (PC workstation): depends on the solution
Time tracking app: if the app supports this feature
Time-recording terminal: system-dependent
Employee portal (PC workstation): system-dependent
Time tracking app: if the app supports this feature
Time-Tracking Terminal: Recurring Entries at the Location
Employee portal (PC workstation): Employees with browser access
Time tracking app: varying work locations and assignments
A terminal is particularly well-suited for situations where many employees clock in at the same location. A browser-based employee portal is ideal when employees regularly work on a computer. The app extends the time-tracking options to include varying work locations.
👉 It is crucial that all data entry methods are linked to the same time tracking system. This ensures that work hours are processed consistently, even when employees switch between the office, working from home, and field work.
✋ How can you implement mobile time tracking in 5 steps?
A successful implementation requires that technical capabilities and operational processes be aligned. Companies should take actual working conditions into account, especially for employees who work at different locations.
1. Clarify requirements and areas of application
First, determine which employee groups need the app. Key considerations include the availability of mobile devices, internet coverage, and the need for project or task scheduling. Also, specify whether the app may be used on work or personal smartphones. Separate usage and security policies should be established for personal devices (“Bring Your Own Device”).
2. Involve Data Protection and the Works Council
Determine which personal data will be processed and what access rights are required. In particular, clarify whether location data is needed and whether the GPS function can remain disabled. If there is a works council, any issues subject to co-determination should be resolved before implementation.
👉 See: Works Council and Time Tracking: Co-determination, Works Agreement, and Practical Implementation
3. Select a pilot group and test the processes
Start with a manageable group of employees from different departments. Employees who are regularly on the go or work at locations with limited internet connectivity are particularly well-suited for this. Test typical time entries, breaks, offline situations, retroactive corrections, and the transfer of data to the central time management system.
4. Train employees and managers
Explain the basic time-entry procedures and how to properly document breaks. Employees should also know how to correct incorrect entries and what to do in the event of technical problems. For managers, processing requests and reviewing incomplete time entries are particularly important.
5. Roll out mobile data collection in phases
After the pilot phase, additional teams and locations can be integrated. Companies should ensure that all required entries are fully imported into the central time management system. Regular checks for incorrect entries, pending corrections, and synchronization issues help ensure stable operations.
🔍 Real-world example: Mobile time tracking at a technical service company
A medium-sized service company employs staff in administration, in a workshop, and in the technical field service. While administrative employees can track their working hours via a web browser, service technicians primarily work on-site at customer locations.
Until now, field staff have documented their daily working hours on timesheets. These documents are regularly submitted to the administrative department and then manually entered into the time-tracking system. This process requires resolving issues such as incomplete entries, retroactive corrections, and discrepancies in job assignments.
The company therefore decides to supplement its existing time tracking methods with a mobile time tracking app. Administrative staff continue to use an employee portal on their desktop computers, while the workshop is equipped with a stationary time tracking terminal featuring an RFID reader. Service technicians are provided with a mobile time-tracking option via their smartphones. All work time data is consolidated in the central time management system.
Track work hours directly on the job
Service technicians use the app to log the start of their shift, breaks, and the end of their shift. They can make these entries throughout the workday without having to return to the company’s location first.
For internal job billing, project and job times are also recorded. This allows the company to distinguish between an employee’s total working hours and the activities documented for individual customer jobs.
For assignments in areas of a building without sufficient cell service, entries are initially saved offline. Synchronization occurs as soon as the smartphone can reestablish an internet connection.
Establishing Organizational Procedures for Corrections and Data Protection
Prior to implementation, the company defines a process for omitted or incorrect entries. Employees can request corrections, while the responsible managers process these according to the established procedure.
The company does not use general GPS tracking because assigning working hours to projects and orders is sufficient for the intended purpose. Employees are informed about data processing, and authorized access is defined.
Centralized Processing Instead of Parallel Time Sheets
The Human Resources department receives the recorded work hours centrally. It no longer has to regularly transfer mobile work hours from handwritten lists. At the same time, the different work locations and operational requirements of the employee groups are taken into account.
👉 This example shows that mobile time tracking offers organizational advantages, especially when time entries, corrections, and job-related reports are integrated into a single system.
✅ Checklist: What should companies look for in a time tracking app?
1️⃣ The start, end, and duration of the daily workday can be recorded
2️⃣ Breaks can be recorded according to actual work interruptions
3️⃣ Offline entries are reliably synchronized
4️⃣ Subsequent changes are traceable
5️⃣ Responsibilities for entry corrections are defined
6️⃣ Personal data is limited to what is strictly necessary
7️⃣ The use of GPS has been reviewed from both a technical and data protection perspective
8️⃣ The data protection officer and, if applicable, the works council or staff council are involved
9️⃣ The app is connected to the central time tracking system
🔟 Employees are familiar with booking procedures and correction processes
🤓 Conclusion: Mobile time tracking combines flexibility with legally compliant documentation
Mobile time tracking via an app enables companies to reliably record work hours regardless of location. It offers a practical alternative to stationary time-tracking terminals, especially for employees working in the field, on construction sites, in customer service, or from home.
Key factors include complete and traceable time tracking, compliance with data protection requirements, and integration into existing processes. Features such as offline tracking, digital absence requests, and project-based time entries can further reduce administrative overhead.
With the ZMI – App in combination with ZMI – Time , for example, mobile time entries can be integrated into a centralized time management system. Companies can use this to combine different data entry methods while simultaneously establishing standardized processes for managing and analyzing work hours.
💡 FAQs on Mobile Time Tracking via App
Is time tracking via an app permitted by law?
Yes, employers are permitted to track working hours using a smartphone app. The key requirement is that the system enables objective, reliable, and accessible recording of working hours and complies with data protection requirements.
Are employees allowed to track their work hours using their personal smartphones?
In principle, this is possible. However, companies should explicitly establish rules governing the use of personal devices and take into account data protection, IT security, and operational requirements. The requirement to track working hours does not impose a general obligation to use personal smartphones.
Does a time tracking app have to use GPS?
No, location tracking is not required for general work time documentation. GPS data may only be processed on an appropriate legal basis and for a necessary, specified purpose.
Does mobile time tracking work without an internet connection?
Yes, provided the app you’re using supports an offline feature. The ZMI – App can temporarily store bookings without an active internet connection and synchronize them with the central system later.
Is a time tracking app also suitable for working from home?
Yes, the legal requirements for tracking working hours generally apply regardless of the work location. An app makes it possible to record start times, end times, and breaks even when working from home or on the go.
Can a time tracking app also track project hours?
Yes, if the software supports this feature. The ZMI – App allows not only for employee time tracking but also for assigning time to projects and orders. It is important to distinguish between project-related documentation and legally required time tracking.
Jonathan Martin is a managing partner at ZMI GmbH. For many years, he has been working in the fields of time tracking, HR software, access control, and the digitization of HR processes. In his articles, he provides practical insights into current developments, legal requirements, and digital solutions for businesses.
