Last reviewed: July 10, 2026. Spanish employers have been required to keep a daily working-time record since 2019. At the time of this review, however, no generally applicable rule published in Spain's Official State Gazette (BOE) requires every company to replace paper or spreadsheets with a digital system.
A regulatory proposal aims to strengthen digital records, but a proposal, draft or fast-track procedure is not the same as a rule in force. This guide separates today's legal duties from changes that are still being considered.
What Spanish law currently requires
Article 34.9 of the Workers' Statute requires employers to guarantee a daily record of working time. The record must include the specific start and end time, be organized through a collective agreement, company agreement or employer decision after consultation, and be retained for four years.
The current rule does not prescribe one format for every business. The chosen system must provide reliable, accessible records suited to the activity, collective agreement and way work is organized. Employers should review the method with worker representatives and appropriate employment-law advisers.
What is still proposed for digital records
The Spanish government has worked on rules intended to digitize working-time records, strengthen traceability and improve access for employees, their representatives and the Labor Inspectorate. As of July 2026, those requirements should not be presented as a generally applicable duty unless and until a final rule is published in the BOE.
The same caution applies to penalties discussed during the legislative process. A future amount per employee must not be presented as though it already applies to every record-keeping issue. The current penalty depends on the conduct, its classification under the applicable rules and the circumstances of the case.
How to prepare without confusing forecasts with obligations
- Document the current process. Define who records time, how errors are corrected and who reviews each closing period.
- Check traceability. Corrections should be explained and open to later review.
- Provide appropriate access. Each person should be able to consult the information relevant to them.
- Review privacy and proportionality. Geolocation and biometric data require specific assessment and should not be enabled by default.
- Retain the records. The current Spanish duty specifies a four-year retention period.
- Follow official sources. Check the BOE before treating a proposal as a final obligation.
How TalentoHQ supports the process
TalentoHQ brings clock-ins, record reviews and reporting into one environment. It also connects time tracking with absence and workforce planning so employers can review hours in their operational context.
The software supports administration but does not replace organizational decisions or legal advice. Each company remains responsible for configuring the system, informing its team and applying the relevant collective agreement and legislation.
To evaluate the workflow with your own schedules, you can request a guided TalentoHQ demo or explore our time-tracking and attendance solution.