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U.S. federal law does not require an agricultural business to use a physical time clock. Employers may use a clock or another recordkeeping method, provided required records are complete and accurate. A paper timesheet, employee timekeeping app, or payroll system may be a fit; the right choice depends on how workers report actual hours and how the business reviews and corrects records.
Does a farm have to use a time clock?
No—not under the Fair Labor Standards Act (FLSA), according to the U.S. Department of Labor (DOL). Its Hours Worked Advisor says time clocks are not required, and the DOL’s recordkeeping guidance allows employers to use a method of their choice if it produces complete and accurate records.
A physical employee time clock is therefore one option for capturing start and stop times—not a compliance guarantee. Employers remain responsible for recording hours and other required information accurately, whether workers punch a clock, enter hours on a timesheet, or use software.
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The FLSA sets federal minimum-wage, overtime, recordkeeping, and child-labor standards. In Fact Sheet #12, dated January 2025, the DOL describes primary agriculture—including cultivation, dairying, crop production, and raising livestock—and certain secondary agricultural practices performed by a farmer or on a farm in connection with farming. Work associated with agriculture does not automatically qualify: for example, packing or storing another farm’s commodities may fall outside the agricultural definition in particular circumstances.
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Do not assume every farm job is exempt
Agricultural employees are exempt from FLSA overtime in some circumstances, and the statute also provides exemptions affecting minimum wage, overtime, or both. Those provisions are conditional; they do not mean that every farm or every agricultural worker is exempt from all federal wage requirements.
One specific exemption uses a threshold of 500 man-days in any quarter of the preceding calendar year to determine whether it applies in the subsequent calendar year. The DOL defines a man-day as a day on which an employee performs agricultural work for at least one hour. This is a test tied to a particular exemption, not a general rule that agricultural work is outside the FLSA. The January 2025 fact sheet explains the exemptions and their qualifications.
State and local laws may impose additional requirements. The federal guidance described here is not a state-by-state compliance guide, so employers should check the rules that apply where their workers are employed.
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What hours and records should the method capture?
The recordkeeping method needs to reflect the work employees actually perform, not just the time they were scheduled or expected to work. The DOL says employers must count any part of an employee’s fixed or regular working time, however small, as well as identifiable periods when the employee is regularly required to perform assigned duties.
- Record actual work time. If an employee starts work before punching in or continues working after punching out, that identifiable work time must be counted. A punch outside the scheduled shift when no work is performed does not, by itself, make that time hours worked.
- Keep hours for piece-rate workers. Paying by the piece does not remove the need to track hours. The DOL’s agriculture guidance flags missing hours for piece-rate employees as a recordkeeping problem.
- Keep other required employee information. The DOL also identifies missing names and permanent addresses for temporary agricultural employees, and missing birth dates for minors under 19, among common recordkeeping issues.
- Account for labor contractors. Using a farm labor contractor can create joint-employment responsibilities; using the contractor’s records does not automatically settle the farm’s obligations.
How to choose a timekeeping method
Federal guidance does not prescribe a device or software product. Choose a method that workers can use at the places they begin work and that gives the business a dependable process to review and correct records. For multiple fields or remote worksites, assess access and connectivity directly; the DOL guidance does not evaluate particular devices or farm layouts.
| Method | What it can offer | What to assess |
|---|---|---|
| Physical employee time clock | A way to record start and stop times at a chosen location. | Whether workers can reach it when work begins, whether missed or incorrect punches can be corrected clearly, and whether it fits the worksite. A clock is optional under federal FLSA guidance and does not itself establish compliance. |
| Paper timesheet or employee self-recording | A non-device way for workers to report their hours. | Whether entries capture actual hours, how supervisors review them, and how corrections are documented. |
| DOL Timesheet App | A free option listed in the DOL’s agriculture toolkit, available in English and Spanish. | Whether the app works for the operation’s worksite access and recordkeeping workflow. |
| Payroll or timekeeping software | A possible way to combine hour capture with payroll records. | Whether it handles the business’s hourly and piece-rate categories, provides clear review and correction processes, and works at its sites. Federal guidance does not endorse a specific service. |
The practical test is whether employees can report the time they actually worked and whether the employer can review and correct errors while maintaining clear records. Compare purchase and operating costs against the needs of the workforce; a small operation may not need to buy a clock if a paper process or the free DOL app is workable.
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Can a farm round time-clock punches?
The DOL describes longstanding rounding practices to the nearest five minutes, one-tenth of an hour, or one-quarter of an hour as acceptable only when, over time, they do not result in failing to count all time actually worked. Rounding is not automatically safe simply because the same rule is applied to every punch.
Major differences between clock records and actual hours should be discouraged because they raise doubts about accuracy. If a method or rounding practice repeatedly shortchanges time worked, the employer needs to address the discrepancy rather than rely on the clock’s recorded totals.
How long should agricultural businesses keep time records?
Under the DOL’s general federal recordkeeping guidance, payroll records should be kept for three years, while wage-calculation records such as time cards should be kept for two years. These are the general periods in that guidance, not a complete retention rule for every agricultural labor arrangement. Other laws or agricultural requirements may add obligations.
For applicable requirements, consult the DOL’s Agriculture Compliance Assistance Toolkit and the relevant federal, state, and local rules.
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