Mandatory digital time recording in Spain: what is and is not in force (October 2026)
Quick answer
As of the last review of this guide (11 October 2026), we are not aware of any rule published in the official gazette (BOE) requiring working-time records to be digital. Article 34.9 of the Workers' Statute remains in force and does not prescribe a format. Check the BOE before making decisions.
This guide describes a rule that is still going through approval. We review it when there is news, but the only reliable source for what is in force is the BOE.
What is in force today
Article 34.9 of the Workers' Statute: a daily record with start and finish times, kept for four years and available to staff, representatives and inspectors. It does not require a digital format. See what Spanish law requires.
What is in the pipeline
The Ministry of Labour is promoting a royal decree to reform time recording. According to press and advisory-firm reports — which we have not been able to check against an officially published text:
- the Council of Ministers agreed in September 2025 to fast-track it;
- the Council of State is reported to have issued a critical opinion in 2026;
- in early October 2026 it had still not been approved.
Treat this as background, not as verified fact.
What the known drafts propose
With the same caution, the reported outline is:
- a digital, personal record that identifies who is clocking;
- traceability of any change;
- employee access to their own data and inspector access to the record, including remotely;
- an adaptation period after publication.
None of this is enforceable until published, and the final text may differ.
Wait, or switch now?
It depends on how you record today.
- If you use paper or an editable spreadsheet. The issue is not the future decree but the present: a record that can be changed without trace is hard to defend as "reliable". Moving to a digital system makes sense now.
- If you already use a digital system. Nothing to do except confirm it logs who changed what and when, and that data can be exported.
- If you are buying now. Choose a system that already offers individual identification, change traceability, export and each person's access to their own record. That is where the drafts point, and it is good practice under current law anyway.
What to ask a vendor
- Is every correction logged, with author and date?
- Can each employee see their own clockings?
- Which export formats are available?
- Will you adapt the product if the decree is approved, and at what cost?
- Where is the data hosted?
- Is the employee-facing app available in English as well as Spanish?
What does not change
Neither current law nor the known drafts make fingerprint or facial clocking acceptable without a very solid justification: see can staff clock in by fingerprint?.
How to follow developments
Check the BOE and the Ministry of Labour website. Be wary of headlines giving an effective date without citing the official publication.
If you want time recording sorted with a system ready for that change, see our time and attendance service.
Frequently asked questions
Can I be fined today for not having a digital record?
Not for it not being digital, as of the last review of this guide. You can be fined for having no record, or one that is not reliable.
Will a spreadsheet still be acceptable once the decree is approved?
Based on the reported drafts it seems unlikely, since they would require traceable changes. The published text will have to be read.
Sources
This guide is for information only and is not a substitute for legal advice or for the technical design of each installation. Regulations change: always check the current text at the official source.