New changes in the area of labour registers

At its session on 21 April 2023, the National Assembly adopted an amendment to the Labour and Social Security Registers Act (ZEPDSV), which introduces certain changes to registers of working time, the recording of additional information on working time and the introduction of mandatory electronic registers for violators of these rules. It should be noted that the daily obligation to keep records of working time already exists and that the changes only specify the maintenance of the register. The aim is to pursue the interests of both parties, employees and employers, and to ensure the authenticity of the registers.

In practice, there has been confusion for which employees records of working time should be kept. The amendment to Article 2 of the ZEPDSV clarifies the definition of a worker – it extends to not only persons working on the basis of an employment contract, but also to those working on other legal bases (including student and author work, contract for work, etc.).

The amendment also provides a more detailed obligation of the employer to provide information from the register of employees referred to in Article 15 of the ZEPDSV. Employers must provide employees’ information to the Health Insurance Institute of Slovenia, on the day of commencement of work under the employment contract, and no later than by the time they start working. If the employee does not start work on that day for justifiable reasons, the employer shall provide the information no later than the day agreed in the employment contract as the day of commencement of work. The employer shall communicate the information at the time of registration for insurance on the prescribed forms.

The biggest change concerns the register of working time, where the following information that the employer must enter in the register on a daily basis is added to Article 18 of the ZEPDSV, namely:

  • the time of arrival at work and the time of departure from work,
  • the use and extent of use of breaks during working time,
  • the hours worked in other special working conditions arising from the organisation of working time,
  • hours worked during irregularly distributed working time or during temporarily reassigned working time, and
  • the running total of hours in the week, month or year, showing the reference period taken into account for the purposes of the irregular working time and the temporary redeployment of full-time work.

The records may be kept electronically or manually, however it is important to note that the new Articles 19a and 19b of the ZEPDSV provide for the obligation of electronic record-keeping in the case of breaches of the provisions of ZEPDSV, when the employer has been fined and has complied with the trade union’s proposal for electronic record-keeping.

A new obligation is also imposed on employers, namely to provide their workers with access to the register of working time regarding information relating to them. Employers must inform them on the information in writing or digitally for the previous month by the end of the payday. Also, employers must keep the register of working time and documentation on the basis of which the information is entered into the register, at the employee’s registered office or place of work.

Fines for offences are now determined in a range, the persons who can be also be sanctioned are responsible persons of employers of legal persons, individual entrepreneurs or self-employed individuals, responsible persons in state bodies or local authorities, and responsible persons in state bodies or other organisations with public authority. A fine higher than the minimum fine may also be imposed under the fast-track procedure.

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Law firm Sibinčič Novak & Partners
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SI-1000 Ljubljana, Slovenia

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