Time tracking for field staff: app, location and Polish law
Time tracking for field staff in Poland means the same working-time records required by Article 149 of the Labour Code, only kept without an office or a reader at the door: for each person and each day, the number of hours and the start and finish times. What works best is an app where people start and end their shift on site and a coordinator sees it straight away. If the app also checks location, you are in monitoring territory and have to meet those rules before you switch it on.
In short
- Under Polish law, working-time records must show, for each employee and each day, the number of hours and the start and finish times, plus night hours, overtime, days off, on-call duty, time off and absences.
- The law requires the records but not the way you collect them. A paper sheet, spreadsheet, card reader or phone app is your choice, and employee records may be kept on paper or electronically.
- If the app records location in order to supervise work, follow the monitoring rules of Article 22³ § 4 of the Polish Labour Code: purpose, scope and method in the work rules, and notice to staff at least 2 weeks before launch.
- For civil-law mandate contracts (umowa zlecenia) the Labour Code records do not apply, but the contract must set how the number of hours is confirmed, and the hour records must be kept for 3 years.
- Since 8 July 2026, breaching working-time rules or failing to keep employee records can be fined PLN 2,000 to 60,000.
Contents
- What working-time records must contain
- Records versus time registration
- Why field work is harder to track than office work
- Location in the app and monitoring: what to do first
- Mandate contracts: confirming the hours
- An example from practice: shifts in Reefa’s bot
- Paper, an off-the-shelf app or your own system?
- When an app is not worth it
- Frequently asked questions
Legal position as of 2 November 2026. This is not legal advice: before rolling this out in your company, check the work rules with HR or a lawyer.
What working-time records must contain
The content is set by § 6(1)(a) of the regulation on employee records. For each employee you record:
| Item | What it means for field work |
|---|---|
| Work on each day | number of hours and start and finish times, also when someone starts at one site and finishes at another |
| Night time | hours worked at night |
| Overtime | everything above the norm, even when a job “just ran over” |
| Days off | with the reason, for example for working on a Sunday |
| On-call duty | hours, start and finish, and where it took place |
| Time off and absences | type and length of time off, excused and unexcused absences |
Article 149 § 1 of the Labour Code says what it is for: the records are there to calculate pay and other work-related benefits correctly, and the employer must show them to the employee on request. The exception in § 2: under task-based working time, for people managing the workplace on the employer’s behalf and where overtime or night work is paid as a flat rate, you do not record hours. The other items, such as time off and absences, still apply.
Fines and record keeping
Article 281 § 1 of the Labour Code provides for a fine of PLN 2,000 to 60,000, among other things for breaching working-time rules and for failing to keep employee records. This range has applied since 8 July 2026, after the act of 11 March 2026 (Dz.U. 2026 item 473) (Polish).
Employee records, including working-time records, are generally kept for the period of employment and 10 years from the end of the calendar year in which employment ended (Article 94(9b)). Hour records for mandate contracts are kept for 3 years from when the pay became due (Article 8c of the Minimum Wage Act). Whatever app you choose must be able to export and keep this data for that whole period, including after you stop paying for it.
Records versus time registration
Time registration is collecting raw data: tapping “start” in an app, swiping a card, a note on paper. The records are the organised document HR uses to calculate pay, with the norm, overtime and absences. The law requires the second one.
This matters when you pick a system. An app that only collects taps will not turn itself into records. Someone has to build the monthly summary, correct mistakes with a note of who changed what and why, and mark days off. A good app does this for you, or at least exports data HR can use without retyping.
The Labour Code (Article 94(9a)) lets you keep employee records on paper or electronically. No provision requires a specific reader, app or attendance sheet.
Why field work is harder to track than office work
Working time is the time an employee remains at the employer’s disposal at the workplace or another place designated for work (Article 128 § 1 of the Labour Code). In an office there is one place and you can see who came in. A service, cleaning or installation crew works at several sites a day and nobody stands at the door.
In my experience the problems are always the same:
- a sheet filled in at the end of the week from memory, so the hours are round and look alike;
- a coordinator retyping sheets or messages into a spreadsheet, which costs hours and adds errors;
- an overtime dispute where nobody has a reliable record of when work started;
- travel between sites that is counted on some days and not on others, because nobody wrote down the rule.
Settle the last point in writing before choosing a tool. Whether travel counts as working time depends on whether the employee is at your disposal during it, and that is a question for the work rules and a lawyer, not for an app.
Location in the app and monitoring: what to do first
The Labour Code has separate rules for monitoring. Article 22³ § 4 applies them to “other forms of monitoring” beyond checking work email, where these are necessary for the purposes in § 1: organising work so that working time is fully used, and proper use of work tools. An app that records where an employee was during work in order to supervise it fits that description. The safe assumption is that location at shift start and finish is monitoring too, so meet the requirements.
Steps before an app with location goes live:
- Define the purpose. Write one sentence on why you need location, for example “confirming that the shift started at the site”. The purpose must come from Article 22³ § 1.
- Limit the scope. Location at shift start and finish is different from a full-day route trace. Collect only what the purpose needs. Monitoring must not infringe the employee’s personal rights either (Article 22³ § 2 read with § 4), so location should be off outside working hours.
- Put it in the work rules. Purpose, scope and method go in the collective agreement, the work rules, or a notice if you have no work rules (Article 22² § 6 read with Article 22³ § 3).
- Tell the team at least 2 weeks ahead. Article 22² § 7 requires this, in the way usual in your company.
- Inform every new person. Before they start work, give them the information on paper or electronically (Article 22² § 8).
- Decide who sees the data and how long you keep it. The GDPR Article 13 information duty also applies: location data is personal data, so staff must know who processes it, why and for how long.
The full text is in the Labour Code, consolidated text Dz.U. 2026 item 1245 (Polish).
Mandate contracts: confirming the hours
The Labour Code records cover employees. For mandate contracts (umowa zlecenia) the duty comes from the Minimum Wage Act (Polish):
- Article 8b: the parties set in the contract how the number of hours worked is confirmed; if they do not, the contractor submits the number of hours in writing, electronically or in documentary form before the payment date;
- Article 8c: you keep the documents confirming the hours for 3 years from the day the pay became due;
- Article 8d: these rules do not cover contracts where the contractor decides on the place and time of work and is paid commission only.
In practice one app can serve both groups. The legal basis and what you do with the data differ, but an on-site shift start and finish is good confirmation of hours in both cases, as long as the mandate contract names it as the method.
An example from practice: shifts in Reefa’s bot
At Reefa, a cleaning company in Kraków and Katowice, people work across many sites at once. For logging shifts I built a Telegram bot: the worker starts and finishes a shift with a button, with location tied to the site, and adds photos of the work.
The edge rules taught me the most. A start can be cancelled within 3 minutes, because people tap by accident. After 6 hours the bot asks to confirm the finish. A shift someone forgot to close is closed after 14 hours using the median length of that person’s usual shifts on that site, instead of counting 14 hours of work.
Hours logged through the bot (shifts up to 12 hours) were 848 hours in 251 shifts in June, 960 hours in 329 shifts in July and 1,100 hours in 364 shifts in August 2026. To be honest, coverage was partial: in June roughly half of planned visits went through the bot. An app does not solve this on its own. You have to make sure everyone uses it and check the gaps every week.
Paper, an off-the-shelf app or your own system?
It depends on how many people work in the field and what else should happen when a shift starts.
| Method | Enough when | Watch out for |
|---|---|---|
| Sheet or spreadsheet | a few people, fixed workplaces | entries from memory, retyping, no evidence in a dispute |
| Off-the-shelf time app | a dozen or more people, standard shifts | per-user subscription, export to HR, location settings |
| Your own system | the shift ties into other data: photos, tasks, client billing | build cost and time, someone has to maintain it |
Worked example (a made-up company). 15 people in the field, 22 working days a month. If filling in the sheet, collecting it and retyping it takes 5 minutes per person per day in total, that is 15 × 22 × 5 = 1,650 minutes, or 27.5 hours a month, before disputes and corrections. Put your own numbers into the savings calculator.
An off-the-shelf app is usually a good first step. Your own system makes sense when a shift start should trigger other things, such as a client report or tasks on site. I explain how to decide without guessing in custom system or off-the-shelf tool. If you are still choosing which process to start with, begin with a process map or read where to start with automation.
When an app is not worth it
- You have a few people at fixed places. A properly kept sheet is enough, and an app only adds a subscription.
- Your staff work task-based time. You do not record hours then (Article 149 § 2), so logging start and finish may be unnecessary.
- Nobody looks after the data. An app used by half the team gives a false sense of control. First decide who checks the gaps every week.
- You want to track people, not count hours. A continuous route trace without a clear purpose under Article 22³ § 1 is a legal risk and hurts trust in the team.
If you want an on-site shift start to produce the records, a client report and order for the coordinator in one go, that is typical work under custom business systems. Start with the savings calculator, then book a 30-minute call: I will tell you straight whether an off-the-shelf app is enough.