The Entity That Employs Them
Which legal entity holds the employment relationship is a fact finance knows, HR half knows, and the working time register needs.
The second fact in the register is which legal entity is the employer. It matters because obligations attach to the employer, because inspections arrive at an entity rather than at a group, and because an organisation that cannot say which of its companies employs somebody cannot answer the first question anybody asks.
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It is also the fact most likely to be known accurately somewhere in the building. Finance and company secretarial functions maintain entity lists for reasons of their own, and payroll is run per entity because it has to be.
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What is missing is the join: a list of people against entities, available to whoever is thinking about working time, rather than scattered across several payroll instances that nobody has combined.
Why group structures complicate it
A person may work at a site operated by one company, be employed by another, and report to a manager in a third. All three can be perfectly ordinary arrangements with good commercial reasons behind them.
For working time purposes the employing entity is usually the one carrying the obligation, and the site operator may carry health and safety duties regardless. Where those are different companies in different countries, the obligations can point in two directions at once.
That is not a problem to solve in a register; it is a flag to raise. The register's job is to make the situation visible so that somebody qualified can say what follows from it.
Providers that employ on your behalf
Organisations hiring in countries where they have no entity frequently engage a third party that formally employs the person and places them with the organisation.
Under those arrangements the formal employer is the provider, and the working time obligations in that country generally sit with them. The organisation still directs the work, still sets the hours in practice, and will still be the one explaining itself if the hours are unreasonable.
The useful position is to treat those populations as requiring both: the provider's compliance, confirmed in writing, and the organisation's own rota discipline applied as if the obligations were its own. Relying entirely on the provider works until somebody asks who actually decided the shifts.
Acquisitions, which arrive with their own arrangements
A company acquired two years ago brings its entity, its contracts, its collective agreements and whatever working time arrangements it had.
Those do not harmonise themselves. In most acquisitions the payroll is integrated, the policies are circulated, and the underlying agreements continue in force unchanged — which means the group now has a population under terms nobody at the centre has read.
Add acquired entities to the register as their own rows, with a note of whether their arrangements have been reviewed and by whom. An unreviewed row is a known gap; an absent row is a surprise waiting for an inspection.
The dormant entity that still employs somebody
Worth checking specifically. Group structures accumulate companies, and occasionally one that was meant to be wound down still has a person or two attached to it for historical reasons.
Those people are frequently invisible to central HR reporting because the entity is not in the standard consolidation. They are visible to finance, who see the payroll cost, and nobody has connected the two.
A reconciliation of the entity list against the payroll list against the HR headcount finds them in an afternoon, and on most groups of any size it finds something.
What the register needs
Entity name, country of registration, the population it employs, and whether that entity has its own working time arrangements beyond the statutory ones — a collective agreement, a works council agreement, a sector agreement it is party to.
The last column is the one that distinguishes a usable register from a list of companies. An entity bound by a sector agreement may be under materially different obligations from the one next to it in the same country, and nothing about the entity name reveals that.
Confirm it with the entity rather than assuming from the centre. The local finance or HR lead will know whether an agreement applies; the centre will not, and will usually guess that it does not.
The entity that exists only on paper
Some rows in a group structure are holding companies, dormant vehicles or entities retained for a historical reason, and they employ nobody.
Marking them as such keeps the register honest and short. The entities worth a row are the ones with people attached, and separating the two lists at the outset avoids the common state where a working time register is thirty rows long because somebody started from the company list.
It also makes the exception visible: a dormant entity that turns out to employ two people is a finding, and it is only a finding if everything around it has been marked dormant deliberately.