Spain's digital time-tracking regulation expected imminently
The Spanish government is finalising a new Royal Decree that will require all working-time records to be fully digital, tamper-proof, and remotely accessible to the Labour Inspectorate. The regulation is expected to be approved in April or May 2026 and represents a significant tightening of Spain’s existing time-recording obligations under the Workers’ Statute. Paper timesheets and spreadsheets will no longer be considered compliant.
Why this matters for remote workers: Every employee in Spain — including remote and hybrid workers — must have their start and end times recorded digitally under the new rules. The system must generate auditable records in real time, support employee visibility into their own data, and meet GDPR standards. Fines for non-compliance range from EUR 1,000 to EUR 10,000 per affected worker, depending on severity. For digital nomad visa holders and remote workers on Spain’s telework law (Law 10/2021), this means employers must ensure time-recording infrastructure extends seamlessly to remote locations.
The regulation builds on the existing obligation under Royal Decree-Law 8/2019, which already requires daily time recording but allowed paper-based methods. A&O Shearman advises companies to “review their existing systems to ensure they meet the forthcoming requirements.” The shift to digital-only recording aligns with Spain’s broader push for workplace transparency — the stalled 37.5-hour working week bill, if eventually passed, would further amplify the importance of accurate time records for enforcement purposes.
What to watch: The exact date of approval and any transition period. Companies will likely have six months from publication in the BOE to adapt their systems. The Labour Inspectorate has been increasing enforcement activity, with hundreds of public employees dedicated to preventing irregularities. Remote workers should ensure their employers have a compliant digital system in place, not just for Spanish law compliance but also as documentation for tax residency purposes.