At a glance
- The Spanish government has published a draft Royal Decree that aims to standardise and enforce digital systems for recording working hours.
- Employers must implement a digital working time registry that is objective, reliable, and accessible at all times.
- The requirement applies to all types of employment contracts, including full-time, part-time, fixed-term, training, flexible, and hybrid arrangements. Notably, senior executives are now included within the scope.
- Time records cannot be modified unilaterally; any changes require explicit employee consent.
- Employees must have real-time access to their own working time records.
- Labour inspectors are granted continuous remote and on-site access to the registry.
- An official registry of approved digital time-tracking systems will be established.
On 10 October 2025, the Spanish government published, for the purpose of public audience, a draft Royal Decree that aims to standardise and enforce digital systems for recording working hours across all companies. This regulation, if approved by the government, will apply universally (ie regardless of company size or employee count) and is intended to prohibit manual or paper-based tracking methods. Instead, companies must adopt digital systems that are objective, reliable and accessible.
The decree extends to all types of employment relationships, including those under Article 2 of the Workers’ Statute. This means that even senior executives, subject to the provisions of Royal Decree 1382/1985, of 1 August, regulating the special employment relationship of senior management personnel, which were previously excluded, will now be required to register their working hours.
Employees will have the right to access their time records in real time, and any changes to those records must be explicitly approved by the employee. Further, the Labour Inspectorate will also be granted immediate access to these records, whether remotely or on-site, to ensure compliance.
Companies will be required to implement formal protocols for working time registration (subject to information and consultation with worker representatives) and provide training. The regulation also addresses special employment arrangements, such as outsourcing and temporary agency workers.
The Spanish government is also considering the creation an official registry of approved working time digital registries, ensuring that the apps and tools used meet legal requirements for security, traceability and accessibility. This may require many companies to replace their current tools with certified solutions, opening a new market for software developers and technology providers.
In short, the Spanish government has stated that this initiative is designed to be proportionate and enforceable, aligned with EU directives, and focused on improving labor conditions, employee wellbeing and national competitiveness.
These measures, which are now open to public consultation, are expected to be approved by Royal Decree, which means that they will be implemented shortly, as it does not require parliamentary approval. 20 days after its publication it will enter into force, although a transitional period will very likely be granted to allow companies to adapt to the new legal requirements.
Additionally, contrary to expectations, administrative fines for non-compliance are not expected to be increased at this stage.
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