Source documentation for every coefficient used in the //AIRGAPT working-time compliance liability calculator. Covers four enforcement vectors: wage recording duty, overtime and wage underpayment, mandatory rest periods, and right-to-disconnect obligations. Purpose: allow any CHRO, CFO, or procurement officer to verify the origin of every number.
As of v1.1, the Working-Time Compliance row in the calculator estimates liability across four distinct but legally connected enforcement vectors. These are not separate rows, they are aggregated into a single TEPR/AEL pair because in practice they arise from the same employee population, the same workforce management failure, and are enforced under a unified working-time statute in most jurisdictions.
TEPR is the statutory maximum exposure ceiling across all four working-time enforcement vectors, calculated at the organisation level. It represents the worst-case regulatory scenario, the total fine, compensation, back-pay, or penalty the organisation could theoretically receive if a regulator exercised maximum enforcement powers across all exposed workers simultaneously.
TEPR is not a forecast of what will happen. It is a boundary condition, the upper end of the risk envelope. Its primary use is as an insurance underwriting comparator: how large is the potential loss event relative to which you are buying coverage?
TEPR_WT = digital_workers × TEPR_factorTEPR_factor is the per-worker annualised statutory ceiling across all four enforcement vectors, derived from each jurisdiction's published enforcement schedule (see Section 2). The TEPR_factor is bounded by the highest applicable per-worker ceiling in each jurisdiction, typically wage underpayment or the RTD infraction maximum, whichever is greater.AEL is the probability-weighted annual expected loss from working-time non-compliance across all four vectors. It represents what a statistically average employer in the user's jurisdiction and sector would expect to pay per year in aggregate across claims, awards, back-pay recovery, settlements, and associated costs.
AEL is the operationally relevant figure for cost-benefit analysis: what a CFO should compare against the //AIRGAPT licence cost to assess payback period and ROI.
AEL_WT = digital_workers × incidence_rate × avg_fully_loaded_costThe following cost categories are not monetised in AEL:
The table below documents the source citation for each coefficient across all four working-time enforcement vectors. Colour coding:
— Black text: sourced from named public publication.
— Amber: partially sourced, proxy methodology applied.
— Red: estimate, no public source, conservative value applied pending research.
| Jurisdiction | TEPR_factor (proposed) | TEPR Source (all WT vectors) | Incidence Rate (proposed) | Incidence Source | Avg Fully-Loaded Cost (proposed) | Settlement/Cost Source | Cluster Factor | Cluster Source |
|---|---|---|---|---|---|---|---|---|
| Australia | €55,400 | Fair Work Ombudsman Annual Report 2022–23: maximum civil penalty A$93,900 per contravention (p.62), converted at AUD/EUR 0.59. Applies to wage underpayment (FW Act s.45), WT recording violations (s.535), rest-period failures (s.62), and OOH availability obligations. Published figure used directly, no actuarial discount. Note: actual awards typically below maximum per FWO enforcement discretion. | 5.5% (proposed) | FWO Compliance & Enforcement Annual Report 2022–23: 9,143 requests for assistance filed across all WT grounds (p.14). Underpinning digital workforce ~10M = ~0.09% formal filings; academic adjustment to include informal/constructive claims and wage underpayment (Stewart & Forsyth, "Australian Labour Law" 2022) brings combined incidence to ~3–6%. Midpoint 5.5%; high uncertainty flagged. | €42,000 | FWC median General Protections + WT award A$28,400 (2022–23 Annual Report p.71) = ~€17k. Fully-loaded cost (legal fees, back-pay recovery, HR time, productivity loss): 2.5× multiplier applied to tribunal award. Multiplier is an internal estimate, no verified published source for the multiplier value. €42k = median × 2.5*. Estimate, multiplier unverified. | Excluded, no public source | No FWO/FWC data quantifying multi-claim batch filing rates following single WT enforcement trigger. |
| Spain | €18,000 | ⚠ AMBER, TEPR construction uses an unsourced actuarial assumption. LISOS Art.8.13bis max Very Serious infraction = €225,018 (BOE, RD Legislativo 5/2000 consolidated 2022). Art.7.5 (recording duty per RDL 8/2019) adds separate Serious infraction ceiling €6,250/worker. TEPR_factor = €18,000 uses a divisor of 12.5 workers per infraction; this divisor has no cited regulator source and requires legal review before it can be treated as anything other than directional. Per-worker recording-duty ceiling (Art.7.5 alone) = €6,250, sourced. Pending legal review: treat Spain TEPR as directional estimate only. | 5.0% (proposed) | ITSS Memoria 2022: 4,234 infraction proceedings for WT + recording duty violations combined (p.118). Digital workforce ~8.5M = 0.05% formal rate. RDL 8/2019 recording-duty enforcement has added a distinct enforcement vector since May 2019. Informal/settlement adjustment: estimated 40× formal rate per ITSS survey data. High uncertainty, estimate. | €43,000 | LISOS max award per WT infraction €225,018. Median ITSS penalty for WT violations: €14,200 (Memoria 2022, p.122). Wage underpayment recovery plus legal burden per Aon EPL Spain 2023: 3–5× fine for contested matters. €43k = 3× median ITSS fine + back-pay estimate + legal fees. Estimate. | Excluded, no public source | No ITSS publication quantifies batch enforcement. Excluded. |
| France | €12,000 | Code du Travail Art.L2242-17 (RTD) + Art.L3171-2 (WT recording duty, employer must maintain time records; failure = "travail dissimulé" risk). Conseil de Prud'hommes awards for connected burnout, unrecorded overtime, and "travail dissimulé" can reach 6 months' salary. TEPR_factor: INSEE median gross monthly salary 2023 (INSEE T-ER-015-G2 = €2,920) × 6 = €17,520 → discounted to €12,000 reflecting subset of exposed workers. Travail dissimulé penalty (6 months guaranteed + social charges): additional vector not included. Source: INSEE Tableaux de l'économie française 2024, p.88. | 4.0% (proposed) | DARES Résultats "Les conditions de travail" 2022 (Analyses 2023-012): 18% of surveyed employees report inability to disconnect; significant share also report unrecorded overtime. Formal Conseil de Prud'hommes WT-related filings: <1% formal; combined informal/settlement 4–8%. Midpoint 4%. Estimate flagged. | €30,000 | DARES publication on WT dispute settlements (Analyses 2022-031): median settlement €22,000 for connected harassment/burnout + unrecorded overtime claims. Fully-loaded ×1.36 for legal costs, multiplier is an internal estimate; the 1.36× figure does not appear in the MEDEF publication and the MEDEF citation has been removed. €30k = estimate, multiplier unverified. | Excluded, no public source | No DREETS or Prud'hommes dataset on batch filings. Excluded. |
| Ireland | €9,500 | Workplace Relations Commission (WRC) Annual Report 2023: Organisation of Working Time Act 1997 (s.27) max award = 2 years' remuneration. OWTA covers rest periods, recording duty (s.25, employer must keep WT records), and OOH contact. Code of Practice on Right to Disconnect 2021 enforceable via WRC. WRC Adjudication Officers have awarded €8,000–€25,000 for WT/availability violations (WRC published decisions database, 2022–2024). TEPR_factor = €9,500 = median WRC published award per affected worker across all WT grounds. | 4.5% (proposed) | WRC Annual Report 2023 (p.12): 29,453 complaints received across all employment law. WT-specific subset incl. recording duty and availability: estimate 3–6% of digital workers per annum on informal + formal combined basis per IBEC Employment Law Survey 2023. Midpoint 4.5%. | €29,000 | WRC published decisions 2022–2024: awards in WT + availability claims range €2,500–€95,000 (Adjudication Officer Decision ADJ-00041781, 2023 = €95,000). Median reviewed decision: ~€14,500, sourced. Fully-loaded ×2.0 multiplier: Mason Hayes & Curran Employment Law Review 2023 is cited for the base award range; the specific 2.0× multiplier is an internal estimate, it does not appear as a stated figure in that publication. €29k = estimate, multiplier unverified. | Excluded, no public source | No WRC dataset on multi-claim batch patterns. Excluded. |
| Belgium | €10,000 | Social Penal Code (Wetboek Sociaal Strafrecht 2010) Art.183: Level 4 sanction €1,600–€16,000 per infraction applies to all WT violations including recording duty and rest periods. CLA 149 (Nationale Arbeidsraad, 26 January 2021) on right to disconnect adds a second enforcement vector via Social Penal Code. TEPR_factor = €10,000 = midpoint Level 4 fine across all WT vectors. Source: Belgisch Staatsblad. | 3.0% (proposed) | FPS Employment Annual Report 2022: 18,432 social inspections covering all WT provisions incl. recording duty (p.44). Workforce ~4.7M = 0.39% formal inspection rate. Informal estimate 2–4% per IPA Belgium Employment Law Survey 2022. Midpoint 3.0%. Estimate. | €25,000 | No published Belgian dataset of WT settlement values. SPF Employment mediated settlement data 2022 for WT disputes: median €12,400. Fully-loaded 2.0× consistent with French methodology. €25k = estimate. | Excluded, no public source | Excluded. |
| Luxembourg | €8,500 | Labour Code Art.L.211-27 (RTD, Law of 12 July 2021) + WT recording obligations under Art.L.211-29 (employer time-record duty). Inspectorat du Travail et des Mines (ITM) administrative sanction €1,000–€25,000 per infraction across both vectors. TEPR_factor = €8,500 = midpoint ITM sanction range. Source: Mémorial Journal Officiel, Law 12 July 2021. | 2.5% (proposed) | ITM Annual Report 2022: 3,847 workplace inspections (p.31). Active digital workforce ~480,000 = very small N. Estimate: 2–3% informal incidence applying French proxy. High uncertainty. | €23,000 | No Luxembourg WT-specific award database. Proxy from French methodology applied to combined WT + RTD vectors. Estimate. | Excluded, no public source | Excluded. |
| Italy | €7,000 | D.Lgs. 66/2003 (WT recording, rest periods, maximum WT, max admin fine €5,200 per INL Circolare 4/2022) + Legislative Decree 81/2017 Art.19 (smart working/RTD, employer must agree disconnection periods; violation subject to INL inspection). Combined TEPR_factor = €7,000 applying 1.35× INL maximum for litigation uplift across both vectors. | 3.0% (proposed) | INL Annual Report 2022: 86,412 inspections, 72.3% found violations (p.29). WT recording + smart working subset: INL does not publish dedicated RTD/WT stats. Estimate 2–4% per CGIL survey data (Rapporto CGIL 2023). Estimate. | €22,000 | Corte di Cassazione published employment awards 2022: median for overtime + WT recording claims €18,200 (LexisNexis Italia, 2023). Fully-loaded ×1.2 for legal fees, multiplier is an internal estimate, not a stated figure in LexisNexis Italia. €22k = estimate, multiplier unverified. | Excluded, no public source | Excluded. |
| Portugal | €6,000 | Código do Trabalho Art.199-A (RTD, Law 83/2021: employers with >10 employees may not contact workers outside hours) + Art.202 (WT recording duty). ACT (Autoridade para as Condições do Trabalho) fine schedule: Contraordenação Grave = €612–€6,120 per infraction. TEPR_factor = €6,000 = upper bound Contraordenação Grave, applying to both recording duty and RTD vectors. Source: ACT fine schedule 2022, act.gov.pt. | 2.5% (proposed) | ACT Annual Report 2022: 15,232 inspections; 2,847 related to WT including recording duty (p.38). Digital workforce ~1.4M = ~0.2% formal rate. Informal estimate 2–3% applying EU proxy. Estimate. | €18,000 | No ACT published WT settlement data. Proxy: 4× ACT maximum fine for fully-loaded cost in contested WT/recording-duty matters. €18k = estimate. | Excluded, no public source | Excluded. |
| Germany | €7,500 | AZG §§3–5 (max WT 10hrs/day; mandatory 11hr rest; administrative fines apply under ArbZG, specific ceiling subject to the pending recording-duty reform and not confirmed from a current 2026 source; €15,000 figure from prior BMAS Merkblatt is unconfirmed as current) + BAG ruling 13 September 2022 (1 ABR 22/21): general WT recording obligation under ArbSchG. Combined TEPR_factor = €7,500 = midpoint of AZG Bußgeld range; treat as directional pending ArbZG reform confirmation. | 2.5% (proposed) | BAuA "Arbeit und Gesundheit" Survey 2022: 14.7% of knowledge workers report regular OOH contact obligations; BAG ruling enforcement is ongoing. 2.5% informal incidence estimate applied to combined WT recording + AZG violations. Estimate. | €24,000 | Arbeitsgerichte median award for burnout + WT recording + overtime claims: ~€22,000 per IW Köln statistics 2022 (iw.de). Fully-loaded ×1.09 for legal fees, multiplier is an internal estimate, not stated in the IW Köln publication. €24k = estimate, multiplier unverified. | Excluded, no public source | Excluded. |
| United Kingdom | €6,500 | Working Time Regulations 1998 (SI 1998/1833): covers rest periods, maximum WT, and recording duty (reg.9). Maximum unfair dismissal compensatory award 2024–25: £115,115 (Employment Rights Act 1996, ACAS schedule). Note: a settled statutory UK Right to Disconnect code with a 25% ET uplift does not yet exist, that claim has been removed. TEPR_factor = €6,500 = median award range across WT recording + constructive dismissal claims per ACAS Annual Report 2022–23. | 3.0% (proposed) | ACAS Annual Report 2022–23 (p.19): 35,453 early conciliation notifications on WT recording, constructive dismissal, and availability grounds. UK digital workforce ~12M = 0.3% formal ET/ACAS rate. Informal incidence estimate 2–4% per CIPD Employee Relations Survey 2023. Midpoint 3.0%. | €23,000 | ACAS Tribunal Award Statistics 2022–23: median award for WT/constructive dismissal £16,300 = ~€19,000, sourced. Fully-loaded ×1.21 multiplier: Law Society Employment Practice survey 2023 is cited for context; the specific 1.21× figure is an internal estimate and does not appear as a stated multiplier in that publication. €23k = estimate, multiplier unverified. | Excluded, no public source | Excluded. |
| EU fallback (all other EU jurisdictions) | €5,000 | Conservative minimum derived from EU Working Time Directive 2003/88/EC Art.17 opt-out and member-state implementation minima. Covers recording duty, rest period, and RTD provisions at minimum national enforcement level. No specific source, conservative minimum across all four vectors. | 2.0% (proposed) | Estimate, no public source. Conservative minimum of documented EU jurisdictions. | €17,000 | Estimate, no public source. Conservative minimum. | Excluded, no public source | Excluded. |
| United States, California | $48,000 | Cal. Lab. Code §226.7, up to TWO premium hours per workday (one missed meal + one missed rest, separately) per United Parcel Service, Inc. v. Superior Court (2011) 196 Cal.App.4th 57 (Cal. Ct. App., 2d Dist.). Plus §226 wage-statement penalty ($4,000 aggregate cap), §203 waiting-time penalty (up to 30 days' wages), and PAGA §2699(f)(2) $100 (initial) / $200 (subsequent) per aggrieved employee per pay period. Lab. Code wage claims carry a 3-year lookback; the Unfair Competition Law (B&P §17200) a 4-year restitutionary reach; PAGA penalties a 1-year window, these are pleaded as parallel claims, not one claim reaching back three years. Engine normalises to EUR at pinned rate, see USD note. | 3.5% (proposed) | Estimate*, CA wage-and-hour class-action incidence. Seyfarth 2025: 5,702 private FLSA suits filed in federal court (2025), California disproportionately represented; DOL WHD FY2025 ($259.3M / 176,957 workers, avg $1,465) proxy. *Estimate. | $60,000 | Estimate*, DOL WHD FY2025 median back-pay $1,465 (sourced) × LC226/PAGA/§203 penalty stack + one-way fee shift (CCP §1021.5). The multiplier is an internal estimate. *Estimate. | Excluded, no public source | Excluded. |
| United States, New York | $36,000 | NY Lab. Law §195, wage notice $50 per workday + wage-statement $250 per workday (each capped $5,000 per employee), per NY DOL WTPA FAQ. §198, 100% liquidated damages (doubling) across a 6-year lookback (§198(3)); mandatory fee shift; 6-year recordkeeping under §195(4). Engine normalises to EUR, see USD note. | 3.0% (proposed) | Estimate*, NY DOL wage-hour enforcement + federal FLSA filings (Seyfarth 2025). *Estimate. | $48,000 | Estimate*, DOL WHD FY2025 median back-pay (sourced) × §195 daily-penalty stack + §198 double damages + mandatory fee shift. Multiplier internal. *Estimate. | Excluded, no public source | Excluded. |
| United States, Illinois | $28,000 | ODRISA (820 ILCS 140): ≥25 ee, up to $500 to the employee + $500 to the DOL per offence; fewer than 25 ee, up to $250 employee + $250 DOL per offence (IL DOL, eff. Jan 2023). Chicago Fair Workweek: $300–$500 per violation, each day and each affected employee a separate violation; $1,000 retaliation penalty. BIPA (740 ILCS 14): $1,000 (negligent) / $5,000 (intentional or reckless) single recovery per individual (post-Aug 2024), context only, excluded from this coefficient. Engine normalises to EUR, see USD note. | 2.5% (proposed) | Estimate*, IL DOL + Chicago Fair Workweek enforcement + federal FLSA filings proxy. *Estimate. | $32,000 | Estimate*, ODRISA + Chicago Fair Workweek per-day/per-employee stack + IL Wage Payment & Collection Act + fee shift. Multiplier internal. *Estimate. | Excluded, no public source | Excluded. |
| United States, Texas | $10,000 | No state overtime, meal-break, rest-break, or wage-statement regime, FLSA baseline only (TWC Texas Payday Law). Texas Payday Law administrative penalty ≤ the lesser of the wages in question or $1,000 (Lab. Code Ch. 61); 180-day wage-claim filing window. Engine normalises to EUR, see USD note. | 1.0% (proposed) | Estimate*, TWC wage-claim filings + federal FLSA filings proxy. Minimal state overlay. *Estimate. | $14,000 | Estimate*, DOL WHD FY2025 median back-pay (sourced) × FLSA liquidated damages + fee shift; §260 good-faith may reduce. Multiplier internal. *Estimate. | Excluded, no public source | Excluded. |
| United States, Other (Federal baseline) | $8,000 | FLSA §216(b), 100% liquidated damages (doubling); §255(a), 2-year lookback (3-year for willful); §216(b) mandatory fee shift; 29 CFR Part 516 records (3-year payroll, 2-year supplementary). §260 good-faith defense can avoid the doubling, see downward-factor note. DOL WHD FY2025: $259,294,764 back wages / 176,957 workers (avg $1,465); CMP assessed $58,699,936. Engine normalises to EUR, see USD note. | 1.0% (proposed) | Estimate*, DOL WHD FY2025 investigation rate + federal FLSA filings (Seyfarth 2025: 5,702 private suits) proxy. *Estimate. | $14,000 | Estimate*, DOL WHD FY2025 median back-pay $1,465 (sourced) × FLSA double damages + fee shift; §260 good-faith may reduce. Multiplier internal. *Estimate. | Excluded, no public source | Excluded. |
| Other (all remaining jurisdictions) | €1,500 | Estimate, no public source. Conservative minimum applied across recording duty, rest period, and RTD vectors. | 1.0% (proposed) | Estimate, no public source. | €11,000 | Estimate, no public source. | Excluded, no public source | Excluded. |
The single "United States" row in v1.1 collapsed five materially different wage-and-hour regimes into one €2,500 figure, the original "channel error" that prompted the v1.2 research phase. The calculator now exposes California, New York, Illinois, Texas and a Federal/Other baseline as distinct jurisdictions, each anchored to its primary statutes and enforced separately by the relevant state agency or the U.S. Department of Labor.
This is a structural property of the statutes, not a tuned multiplier. European working-time enforcement is overwhelmingly administrative, a single per-infraction fine schedule levied by a labour inspectorate (e.g. AZG €15,000, ACT €6,120, LISOS per-infraction bands). The high-exposure US states instead stack per-employee × per-pay-period × daily penalties across multi-year lookbacks:
Where an inspectorate fine is a flat envelope, these statutes are multiplicative, each aggrieved employee, each day, each pay period is a separate violation. That is why the statutory ceiling per worker is an order of magnitude larger than a comparable European figure, and why the methodology documents the penalty stack rather than a single number. A reader who understands the structural reason trusts the figure; one who only sees California at several times Germany assumes it was tuned.
The Federal baseline and every state row sit on the FLSA §216(b) liquidated-damages doubling, an additional 100% of unpaid wages on top of the wages themselves. This doubling is not automatic. Under 29 USC §260, an employer that shows both subjective good faith and reasonable grounds for believing its pay practices complied may avoid the doubling entirely.
The model states liquidated damages as the default, the higher, prosecution-side figure, and treats §260 as an explicit downward factor available to a documented employer. //AIRGAPT's tamper-evident, cryptographically signed working-time records are themselves affirmative evidence of good faith under §260: an employer that can produce verifiable time records has a materially stronger argument that any underpayment was not wilful. The calculator does not silently assume doubling always applies; the §260 reduction is a credibility lever this methodology acknowledges rather than hides.
The following disclaimer must appear on every calculator output screen and in any PDF export. This section is non-negotiable and must not be removed or condensed.
This estimate is directional and based on published tribunal data and regulatory enforcement schedules. It reflects only costs visible in public datasets across four working-time enforcement vectors: wage recording duty, overtime/wage underpayment, mandatory rest periods, and right-to-disconnect obligations.
Industry analysts estimate that the majority of employment dispute resolution by value occurs through private confidential settlements not reflected in this calculator (ACAS Annual Report 2022–23: 79% of UK notifications resolved pre-tribunal[A1]; EEOC FY2023: 87.8% resolved via mediation or dismissal[E1]). Class action uplift, reputational damage, executive time costs, employee turnover attributable to overwork, and insurance premium increases are not modelled. Actual exposure may be materially higher than figures shown.
Several coefficients are estimates where no public source was available (see Methodology at airgapt.io/resources/calculator-methodology). These are marked with an asterisk (*) in the detailed breakdown.
This calculator is for planning purposes only and does not constitute legal advice. For legal guidance, consult employment counsel qualified in the relevant jurisdiction.
Three worked examples with full intermediate steps, showing how the four WT enforcement vectors aggregate into a single TEPR/AEL output.
External legal and actuarial review of this methodology document is planned for Q3 2026. The review will cover the accuracy of cited regulator publications across all four working-time enforcement vectors, the actuarial reasonableness of incidence rate estimates and fully-loaded cost multipliers, and the legal defensibility of the TEPR construction for each jurisdiction. Disclaimer language will also be reviewed for adequacy across the jurisdictions where the calculator is used.
Until that review is complete, all coefficients marked as estimates in Section 2 and Appendix B remain subject to revision. The methodology document will be updated upon completion of review and any material changes will be noted with a version increment.
The table below shows the v1.0 → v1.1 changes. Numerical coefficients are unchanged; the scope of each TEPR_factor has been expanded from RTD-only to all four WT vectors.
| Jurisdiction | TEPR_factor, v1.0 | TEPR_factor, v1.1 | v1.1 Scope Change | Incidence, v1.1 | Avg Cost, v1.1 | Source Status |
|---|---|---|---|---|---|---|
| Australia | €55,400 | €55,400 (unchanged) | FW Act wage/time recording + RTD vectors added to TEPR scope | 5.5% | €42,000 | TEPR sourced (FWO AR 2022-23, p.62); cost estimate, Mercer multiplier attribution removed, relabelled as internal estimate |
| Spain | €18,000 | €18,000 (unchanged) ⚠ | RDL 8/2019 recording-duty (Art.7.5) added alongside LISOS Art.8.13bis | 5.0% | €43,000 | ⚠ TEPR uses unsourced divisor, directional only pending legal review; incidence + cost estimate |
| France | €12,000 | €12,000 (unchanged) | Art.L3171-2 recording duty + travail dissimulé uplift added to scope | 4.0% | €30,000 | TEPR sourced (Code du Travail + INSEE 2024); incidence + cost estimate |
| Ireland | €9,500 | €9,500 (unchanged) | OWTA s.25 recording duty + rest-period vectors formalised in scope | 4.5% | €29,000 | TEPR sourced (WRC decisions 2022–24); partially sourced cost (MHC 2023) |
| Germany | €7,500 | €7,500 (unchanged) | BAG recording-duty ruling (Sept 2022) added as primary WT vector | 2.5% | €24,000 | TEPR directional, AZG ceiling unconfirmed pending ArbZG reform; cost estimate |
| Italy | €7,000 | €7,000 (unchanged) | D.Lgs. 66/2003 WT recording + rest period added alongside D.Lgs. 81/2017 | 3.0% | €22,000 | TEPR sourced (INL Circolare 4/2022); cost estimate |
| Belgium | €10,000 | €10,000 (unchanged) | SSW Art.183 scope confirmed to cover all WT vectors incl. recording duty | 3.0% | €25,000 | TEPR sourced (SSW/CLA 149); cost estimate |
| Luxembourg | €8,500 | €8,500 (unchanged) | Labour Code Art.L.211-29 recording duty added to RTD scope | 2.5% | €23,000 | TEPR sourced (ITM/Mémorial 2021); cost estimate (proxy) |
| Portugal | €6,000 | €6,000 (unchanged) | Art.202 recording duty added alongside Art.199-A RTD | 2.5% | €18,000 | TEPR sourced (ACT 2022); cost estimate |
| United Kingdom | €6,500 | €6,500 (unchanged) | WTR 1998 reg.9 recording duty, ACAS RtD code claim removed (no settled statutory code exists) | 3.0% | €23,000 | TEPR sourced (WTR 1998); cost estimate, multiplier unverified |
| EU fallback | €5,000 | €5,000 (unchanged) | WTD 2003/88/EC full WT scope formalised | 2.0% | €17,000 | Estimate, no public source (conservative minimum) |
| United States, California | €2,500 (v1.1) | €44,444 ($48,000), v1.2 US split | LC 226.7 up-to-2 hrs/workday (UPS v. Superior Court) + §226 $4,000 cap + §203 30-day + PAGA §2699(f)(2) | 3.5% | €55,556 ($60,000) | Sourced statutes (CA Lab. Code); incidence + cost estimate |
| United States, New York | €2,500 (v1.1) | €33,333 ($36,000), v1.2 US split | NYLL §195 $50/$250 per workday + §198 100% LD, 6-yr lookback | 3.0% | €44,444 ($48,000) | Sourced statutes (NY Lab. Law); incidence + cost estimate |
| United States, Illinois | €2,500 (v1.1) | €25,926 ($28,000), v1.2 US split | ODRISA $500/$500 + Chicago Fair Workweek; BIPA context-only | 2.5% | €29,630 ($32,000) | Sourced statutes (IL); incidence + cost estimate |
| United States, Texas | €2,500 (v1.1) | €9,259 ($10,000), v1.2 US split | FLSA baseline; Payday admin penalty ≤ lesser of wages or $1,000 | 1.0% | €12,963 ($14,000) | Sourced (TWC / FLSA); incidence + cost estimate |
| United States, Other (Federal) | €2,500 (v1.1) | €7,407 ($8,000), v1.2 US split | FLSA §216(b) + §255 + §260 good-faith; 29 CFR Part 516 | 1.0% | €12,963 ($14,000) | Sourced (FLSA / DOL WHD FY2025); incidence + cost estimate |
| Other | €1,500 | €1,500 (unchanged) | All four WT vectors at conservative minimum | 1.0% | €11,000 | Estimate, no public source |
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