On 18 April 2023, the Federal Ministry of Labor and Social Affairs published the much anticipated draft bill on the exact requirements of how to meet the duty to record working time. The Draft Bill was published against the backdrop of a ruling by the Federal Labor Court in September 2022. Germany’s highest labor court ruled that employers — regardless of the size of the company and the existence of a works council — must record the working hours of their employees (Ref.: 1 ABR 22/21).