December 24, 2025

Mandatory digital time tracking 2026/27

Everything companies need to know about the upcoming mandatory digital time tracking regulation in Spain: deadlines, requirements, valid systems and obligations.

Mandatory digital time tracking will become a reality for all companies in Spain starting in 2026, although its practical implementation could be delayed until 2027, as has happened with other recent regulatory reforms. This obligation will apply to all companies with employees, regardless of their size or sector.

Approval process and entry into force

The legislative process for the new regulatory framework began in September 2025, when mandatory digital time tracking was proposed as part of a broader labour reform. In October 2025, the public consultation phase started, and final approval of the decree is expected during 2026.

Once published in the Official State Gazette (BOE), the regulation is expected to enter into force shortly thereafter. Although the initial target was early 2026, there is a realistic possibility that full enforcement will be postponed until 2027 due to administrative and implementation timelines.

Is digital time tracking mandatory?

Yes. The new regulation will require working time to be recorded using digital or electronic systems. Until the decree formally enters into force, traditional methods such as paper sheets or Excel files may still be temporarily accepted. However, companies are strongly advised to transition to digital solutions in advance to avoid compliance risks during inspections.

Key requirements of mandatory digital time tracking

Digital system: time tracking must be carried out using software or electronic devices; paper and simple spreadsheets will no longer be valid.
Complete records: daily entries must include start time, end time, breaks and, where applicable, overtime and its compensation.
Individual identification: employees must clock in using unique credentials (user and PIN, QR code, card or NFC), excluding high-risk biometric systems.
Traceability and immutability: records must not be alterable without leaving a clear technical audit trail.
Remote access: Labour Inspection authorities and employee representatives must be able to access records remotely without prior employer intervention.
Employee access: each worker must be able to consult their own time records easily and transparently.
Data retention: records must be stored for a minimum of four years with guarantees of integrity and availability.
Security: data must be encrypted both in transit and at rest, with access controls and secure backups.
Usability: the system must be intuitive and accessible for all types of workers.
Ongoing compliance: the software provider must adapt the system to legal changes without requiring manual intervention from the company.

Employer obligations

The obligation to implement digital time tracking applies to all employers, although its impact will vary depending on company size, resources and working models. The common challenge is to deploy a reliable, simple and legally compliant digital system that adapts to different schedules, locations and employment arrangements.

Among the main obligations for employers are:

Implementing or adapting digital systems that ensure traceability and data integrity.
Ensuring employees can clock in directly, personally and immediately.
Providing accessible tools for all workers, including alternatives for employees without personal devices.
Training staff and defining clear internal procedures for using the system.
Allowing remote access to records for employees and Labour Inspection authorities.

Valid digital time tracking systems

The regulation does not impose a single technological solution, but it does require certain standards of security, traceability and accessibility. Valid systems may include:

Web-based or desktop systems accessible from authenticated computers.
Mobile applications for smartphones or tablets with user authentication and options such as QR codes or punctual GPS use.
Physical terminals connected to centralized software using PINs, cards or NFC.
Other traceable digital methods that reliably identify the worker and generate immutable records.

Recommendation

The mandatory digital time tracking requirement for 2026/27 calls for early preparation. Reviewing current systems, eliminating practices that will no longer be allowed, and selecting a secure and traceable digital solution will significantly reduce the risk of sanctions while improving control, efficiency and transparency in working time management.

Explicit limitations and prohibited practices

The future regulation will also clearly define certain practices that will be restricted or prohibited in order to ensure effective compliance:

Recording working time on paper or using Excel files without certified traceability.
Using high-risk biometric systems (fingerprints, facial recognition) without strong legal and technical justification.
Forcing employees to use their personal devices without company-provided alternatives.
Applying continuous geolocation or tracking outside the strictly necessary context of time registration.
Altering, deleting or overwriting records without leaving a complete technical audit trail.

Conclusion

Mandatory digital time tracking in 2026/27 represents a major shift in how companies must manage and document working hours. Beyond legal compliance, this transition offers an opportunity to improve internal processes, reduce errors, avoid sanctions and strengthen transparency in labour relations.