My understanding of this is you need to have a basic time and attendance system in place by the 1st July, so people can record their hours of work, breaks and overtime. Records need to be kept by the employer to show compliance. It doesn't sound too dissimilar to what we do for Payroll and HMRC.

Do you not currently have a system for your UK based employees to record their hours of work?
Can this not be rolled out across the business? Are your employees salaried or hourly paid?

We have a time off recording system accross the business but not a daily time-tracking system.

All our staff are salaried and we don't have a time tracking system in the UK.

We have a time off recording system accross the business but not a daily time-tracking system.

All our staff are salaried and we don't have a time tracking system in the UK.

In reply to Kathryn:

We have a mix of hourly and salary paid employees. Everyone clocks in on a terminal when they come into the building.

What systems do you currently use for recording absence and your payroll?

In reply to Kathryn:

Hi Kathryn
Given you work at a multi-national do you have the ability to do different time tracking by location in the HR system?
So for those that need to clock in and out you could have that.
For those that just need to report time and get TOIL you can have that system
For those who do NOT need to report at all you have that.

Let me know if you have questions, I'm happy to help :)