Employment
Digital working-time register: what is mandatory today, what the Government is preparing and how to adapt your company
The Ministry of Labour is preparing a royal decree that would make digital clocking-in mandatory. It is not yet published, but the working-time register has been mandatory since 2019. We explain what the law requires today and how to prepare.
What is already mandatory
Recording working time is not new. Since 12 May 2019, article 34.9 of the Workers’ Statute has required companies to keep a daily record of working time for each worker, showing the specific start and end times. Records must be kept for four years and be available to workers, their representatives and the Labour Inspectorate.
What the Government is preparing
The Ministry of Labour is processing a royal decree that would develop that register and make it digital and accessible to the Inspectorate, with the stated aim of ending paper entries. The Secretary of State for Labour has expressed confidence that it can be taken to the Council of Ministers during October.
To be precise: as of the date of this article it has not been published in the BOE and has no date of entry into force. As it is a royal decree and not a royal decree-law, it does not require parliamentary validation.
And the reduction of working hours to 37.5?
It is not in force. The statutory maximum working week remains 40 hours on an annual average, and the reform that would reduce it has not passed in Parliament.
The situation at a glance
| Measure | Status as of 19 October 2026 |
|---|---|
| Daily working-time register (art. 34.9 ET) | In force since 2019 |
| Mandatory digital working-time register | Royal decree in progress, not published in the BOE |
| Reduction of working hours to 37.5 | Not approved; remains at 40 hours per week |
What to do now
- Check that your register is daily, with start and end times, and that it cannot be modified afterwards without leaving a trace.
- If you use paper or spreadsheets, consider moving to a digital tool with traceability.
- Keep records for four years and guarantee access for representatives and the Inspectorate.
- Review your collective agreement and working-time arrangements, remote work and overtime.
- Accompany it with a digital disconnection policy, which the royal decree is likely to reinforce.
In summary
The obligation to record working time already exists, and what will change is the how: presumably, a digital and verifiable system. If you need to review your time-control system or your working-time policy, we can analyse it with you.
Sources: Workers’ Statute (art. 34.9, Royal Decree-law 8/2019); statements by the Ministry of Labour; business and specialist labour press consulted on 19 October 2026. This article is for information purposes and does not replace individual legal advice.
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