To reduce the shadow economy, there are amendments planned in the law "On Taxes and Fees" that provide electronic working time recording system for construction projects as of 1 October 2017.

The stipulated regulation in the draft law provides the implementation of an electronic working time recording system (EDLUS) that foresee the electronic registration of working time of employees on the site, recording and storing of registered data, as well as provision of information on all contracts concluded with subcontractors for the previous month for a contract in amount of 15 000 EUR or more.

The establishment and maintenance of the EDLUS will only apply to the construction of a new 3rd group buildings[1] or construction if the construction costs are EUR 1 million or more.

The main performer of construction work will be responsible for establishing and maintaining of EDLUS. The subcontractor will be obliged to control employees or affiliated parties registering the working time in EDLUS.

According to the draft law, the person employed on the construction site will be deemed to be the main performer of a construction work or a subcontractor who performs work on the construction site for carrying out a construction contract. Also, a natural person registered as economic operator will be regarded as a person employed on the construction site. The same applies to a local employee of a foreign employer, a foreign employee to a foreign employer, a person who performs work at the construction site for the benefit and under direction of beneficiary of the labour supply services and a construction supervisor.

The new regulation provides that the main performer of construction work will have to provide an electronic identification solution also for a person who stays in a delimited territory of construction site but not being employed in the construction work at the site (for example, but not limited to - suppliers of materials, suppliers of mobile construction equipment, couriers, visitors, including customer representatives or invited persons).

The implementation of EDLUS is foreseen in the following stages:

  • stage 1 – implementation of EDLUS at construction sites;
  • stage 2 – transfer of stored data in EDLUS to the centralized unified electronic working time database -VEDLUDB.

As regards the 2nd stage and implementation of the VEDLUDB, the Cabinet of Ministers is obliged to determine the holder, it duties and rights by 1 December 2017.


[1] Buildings shall be divided into three groups depending on the complexity of the construction and possible impact on the environment. The first group is the lowest one, but the third is the highest (Paragraph 4 of the Cabinet Regulation No. 500 of 19 August 2014 “General Construction Regulations”).