Keeping working time records for each employee is one of the employer's basic obligations under the Labour Code (Kodeks pracy). A properly prepared attendance list makes it possible to calculate pay and employee benefits accurately and is the foundation of sound HR management in a business.
Many companies wrongly treat attendance records as a formality, without realising how important they are for the payroll system to work properly. A properly kept attendance list not only meets legal requirements but is also the basis for settling overtime, excused and unexcused absences and other elements that affect pay.
The employer must keep working time records for each employee under Article 149 of the Labour Code. The detailed rules are set out in the regulation of the Minister of Family, Labour and Social Policy of 10 December 2018 on employee documentation (consolidated text, Journal of Laws (Dz.U.) 2026 item 474). Failure to comply with this obligation may lead to sanctions from the PIP (National Labour Inspectorate)
Differences between an attendance list and working time records
Many employers wrongly treat the attendance list and working time records as one and the same document. This is a fundamental mistake that can lead to problems in HR management and breaches of labour law. Article 149 of the Labour Code sets out the obligation to record employees' working time, but the details are laid down in the regulation of the Minister of Family, Labour and Social Policy on employee documentation.
Working time records are a detailed document that must contain precise information on the number of hours worked, the start and end times of work, night work, overtime, days off, on-call duty and the type and extent of absences (§ 6 point 1(a) of the regulation). This document is used mainly for settlement purposes and must be kept in compliance with all the formal requirements laid down in the law.
The attendance list, on the other hand, is not formalised by law in any way – it is also not included in the catalogue of employee documentation in § 6 of the regulation. However, the Labour Code requires the employer to set the way in which employees confirm their presence at work. Article 104¹ § 1 point 9 of the Labour Code states that the work regulations should set the method adopted by the employer for employees to confirm their arrival and presence at work and to justify absences. Work regulations are mandatory for an employer with at least 50 employees (Article 104 § 1¹); an employer without work regulations provides this information to the employee in the information on terms of employment (Article 29 § 3 point 1(m)).
This provision of the Labour Code means that the employer can adopt any method for employees to confirm that they have come to work. It can be a printed attendance list, an electronic system or, in smaller companies, even verbal confirmation. What matters is that the chosen method is applied consistently and properly documented
The attendance list has a control and organisational function, allowing ongoing monitoring of employees' presence at the workplace. It does not have to contain information as detailed as the working time records, but it should be kept systematically and reliably.
The difference in the purpose of the two documents is key to understanding their role in HR management. Working time records are used mainly for financial settlements and must meet strict legal requirements. The attendance list is more organisational and serves to confirm that the employee is actually present at the workplace.
Basic elements of an attendance list
An attendance list is a fairly simple document, but to fulfil its functions it must contain certain elements. A properly prepared attendance list should contain the first name and surname of the employee for whom the list is kept. This data must be legible and clearly identify the person the documentation concerns.
A key element is the signature of the employee and of the manager of the unit to which the employee reports. These signatures confirm the authenticity of the document and are proof that the employee actually confirmed their presence and that the supervisor accepted the information provided.
The list should also contain the details of the manager responsible for the unit, who can confirm the actual situation against the working time declared on the list. This information matters from the point of view of the organisational hierarchy and responsibility for the correctness of the documentation.
The period covered by the list should be clearly defined. Monthly lists are the most common and the clearest, allowing working time to be settled systematically. Some companies keep weekly or even daily lists, depending on the nature of their business
A useful convenience for the employer and the HR department is a summary of the data, which is worth including on the attendance list. It shows at a glance how many hours or days were worked in the chosen period, for example a month. This is very helpful when settling absences or overtime.
- Prepare an attendance list template with all the required fields
- Enter the employee's personal data and the settlement period
- Decide how the employee will confirm attendance
- Set the procedure for signing by the supervisor
- Introduce a system for archiving completed lists
- Train employees in the new procedures
| List element | Requirement | Details | Notes |
|---|---|---|---|
| First name and surname | Essential | Employee's full details | Legible and unambiguous |
| Employee's signature | Depending on the method adopted | Confirmation of attendance | Can be electronic |
| Manager's signature | Recommended | Verification of data | Line responsibility |
| Settlement period | Essential | Usually monthly | Clearly defined time frame |
| Summary of hours | Recommended | Total time worked | Makes settlements easier |
The attendance list and the GDPR (RODO)
The introduction of the General Data Protection Regulation (RODO in Polish) has significantly affected how employee documentation, including attendance lists, is kept. As mentioned above, recording working time is an employer's obligation under labour law. The employee, in turn, must confirm their presence at work in the way adopted by the employer.
An employer that has not set work regulations must inform the employee of the adopted method of confirming attendance no later than 7 days from the day the employee is allowed to start work (Article 29 § 3 point 1(m) of the Labour Code); in other cases this method is set out in the work regulations. This requirement is often overlooked by companies, which can lead to problems during an inspection or in employment disputes.
Data protection law classifies health data as special categories of data (Article 9 of the GDPR), which the employer may process only to the extent required by law. This means that the attendance list must not show reasons for absence such as illness, maternity benefit, care allowance or other information related to the employee's health.
The attendance list serves only to confirm that the employee was present at work on a given day. If the employee is absent, you can only enter "absent" for that day without giving a reason. Detailed information on the type of absence should be kept in the separate working time records
This distinction is key to GDPR compliance. The reason for an employee's absence should be given only in the working time records, because it is needed to calculate pay correctly. Even there, however, you should be particularly careful and process only the data that is strictly necessary.
Employers must also remember their other GDPR obligations, such as informing employees about the purposes of processing their data, how long it will be kept and their rights. As a document containing personal data, the attendance list is subject to all the requirements of the regulation.
- Personal data on the attendance list must be processed in line with GDPR principles
- Employees have the right to access their data contained in the documentation
- Keeping attendance lists is subject to specific time limits
- Disclosing health information on the attendance list is prohibited
- The employer must ensure the security of the personal data stored
Who is exempt from recording working hours
Article 149 § 2 of the Labour Code lists the cases in which the employer does not record employees' working hours. The other elements of the records (e.g. days off and absences) are still kept. These exceptions are strictly defined and concern specific employment situations or ways of organising work. Working time and the basic terms of work are set in the contract, whose elements we cover in employment contract – template and key elements.
The first case is an employee receiving a lump-sum allowance for night work. Even in such situations, however, the employer should keep some form of attendance documentation to be able to settle pay correctly.
Another exception is paying the employee a lump sum for overtime. In such cases, where overtime pay is set as a fixed monthly amount, detailed records may not be necessary. However, the employer should still monitor working time for occupational health and safety reasons.
The task-based working time system also exempts the employer from recording working hours. In this system the employee has specific tasks to complete in a given period, and how the working time is organised is left to the employee. Even in this case, however, the employer should keep basic attendance documentation
The last case is an employee managing the workplace on behalf of the employer. For people in top management positions, working hours are not recorded because of the nature of their duties and responsibilities.
It is worth stressing that being exempt from recording working hours does not mean having no documentation at all. The employer should still keep basic attendance documentation, if only for organisational and safety reasons.
A manufacturing company employing 50 employees introduced a task-based working time system for its design department. Employees in this department have specific projects to complete within a month, but organise their own working time. Despite being exempt from recording working hours, the company still keeps a basic attendance list to check whether employees actually come to the office and carry out their duties.
Practical aspects of keeping an attendance list
Keeping an attendance list in practice requires appropriate procedures that are followed systematically. The first step is to decide what form the documentation will take – a traditional paper list, an electronic system or perhaps a mobile app.
The paper form is still the most popular, especially in smaller companies. However, it requires proper storage of documents and can be time-consuming with a larger number of employees. Paper lists must be properly protected against loss or destruction.
Electronic systems offer more options for automation and integration with payroll systems. They make it easier to generate reports and analyse data. However, they require proper protection against unauthorised access and regular backups.
Whatever form you choose, the attendance list must be kept systematically and reliably. Employees should be informed about the procedures and deadlines for confirming attendance. Supervisors should regularly check and sign the documents
Another important aspect is setting procedures for when an employee is absent. The attendance list should provide a way of marking different types of absence while remaining compliant with the GDPR.
The employer should also set procedures for archiving attendance lists. These documents must be kept for a certain period and be available in the event of an inspection or employment disputes.
Regular training for employees on filling in attendance lists correctly is key to the effectiveness of the whole system. Employees must understand their obligations and the consequences of not following the procedures.
Integration with payroll systems
A properly kept attendance list should be closely linked to the payroll system. Data from attendance lists is the basis for calculating pay, overtime, bonuses and other pay components. We can take over payroll, overtime and ZUS settlements based on working-time records — see our payroll outsourcing.
Integration can take place at different levels – from manually copying data to automatically importing information from electronic systems. The choice of method depends on the size of the company, the number of employees and the technology available.
Small companies often transfer data from attendance lists to the payroll system manually. This requires particular attention to accuracy and can be time-consuming, but it is relatively easy to implement.
Larger companies are increasingly investing in integrated HR systems that combine working time records with payroll. Such solutions reduce the risk of errors and significantly speed up accounting processes. Automation also allows better control and analysis of data
It is essential to ensure that data is consistent across the different systems. Any discrepancies between the attendance list and the working time records must be explained and corrected immediately.
The system should also allow you to generate reports and analyses that help with HR management and with controlling labour costs. Data from attendance lists can be used to analyse absenteeism, plan holidays or assess work efficiency.
Checking and auditing the documentation
Regularly checking that attendance lists are kept correctly helps ensure compliance with the law and the effectiveness of the whole system. The checks should cover both formal and substantive aspects.
Formal aspects concern the completeness of the documents and the presence of the required signatures, dates and other elements set out in internal procedures. Each list should be checked for compliance with the adopted standards.
Substantive checks involve verifying that the data matches reality. You should check whether employees were actually present at work on the days marked and whether there are any discrepancies with other sources of information.
The law does not require an internal audit of attendance lists, but it is worth carrying one out regularly, e.g. once a quarter. It should cover a random sample of documents from different departments and periods. The audit results should be documented and corrective action taken if irregularities are found
It is also important to be prepared for external inspections, including by the National Labour Inspectorate. The documentation should always be up to date, complete and easily accessible.
Inspection procedures should be clearly defined and known to everyone responsible for keeping the documentation. Regular training and reminders about obligations are key to the system's effectiveness.
