Since 2019, daily working hours recording has been mandatory for all companies in Spain. With the new digital regulation, Excel and paper are no longer valid systems. Is your company up to date?

Royal Decree-Law 8/2019 established the obligation to record the daily working hours of all employees. However, many companies are still failing to comply or are using systems that do not meet the new technical requirements. The regulation has evolved: the record must be digital, unalterable and accessible in real time.

What does the law actually say?

The Workers' Statute requires recording the start and end time of each employee's working day every working day. Records must be kept for four years and be available to the Labour Inspectorate at any time. The latest regulation requires the system to be digital, immediately accessible and with full traceability of any modification.

The new regulation also establishes that employees must receive a monthly copy of their record together with their payslip, and that the system must document not only ordinary hours but also overtime and how it is compensated.

Who is required to record working hours?

The obligation is practically universal: it affects SMEs, large companies, full-time and part-time employees, and workers in face-to-face, hybrid and remote working arrangements. Only senior management employees are exempt. The sector, company size or type of contract do not exempt from compliance.

What information must be recorded

  • Start and end time of each work shift
  • Breaks and rest periods (duration and schedule)
  • Ordinary hours worked during the shift
  • Overtime, indicating whether compensated with rest or monetary payment
  • Complementary hours for part-time contract workers

Valid systems and systems that no longer comply

The new regulatory framework sets clear technical criteria for recording systems:

  • Mobile time tracking applications
  • PC software with per-user login recording
  • Biometric terminals (fingerprint, facial recognition)
  • GPS geolocation systems for mobile employees
  • Email or messaging-based recording (with verifiable traceability)

Technical requirements the system must meet

  • Encrypted data with automatic backups
  • Full traceability: any modification is recorded with who, when and why
  • Data export in standard formats for auditing
  • Immediate access for the Labour Inspectorate at any time
  • Record retention for a minimum of four years

The risks of non-compliance

Non-compliance with time recording requirements can result in fines ranging from €625 to €6,250 per serious infringement, under the Law on Infringements and Sanctions in the Social Order (LISOS). In the event of a labour dispute, the absence of records automatically puts the employer at a procedural disadvantage.

Want to implement a digital time tracking system that meets all legal requirements? Contact our team .