New working time record, before summer 2026

The digital working time tracking reform now has a hard deadline: before summer 2026. This was confirmed by Yolanda Díaz, Spain's Deputy Prime Minister and Minister of Labour, who stated that the Government will bring the text to the next Delegated Government Commission for Economic Affairs without introducing 'significant changes' to the version already rejected by the Council of State.

This is a turning point for millions of Spanish businesses. The new regulation will require the implementation of digital time-tracking systems with specific technical requirements — and the window to adapt is shrinking week by week.

Why did the Council of State reject the draft?

In March 2026, the Council of State issued a critical report on the draft decree. Among other objections, the advisory body questioned technical aspects of the regulation and raised concerns about the burden it would impose on businesses. However, the Government has decided to maintain its position and approve the text with only minimal adjustments.

"The fact that in the 21st century the Council of State talks about time clocks says a lot about a country that no longer exists, because the reality is that Spanish companies already have digital systems in place." — Yolanda Díaz, Minister of Labour.

The Minister also highlighted that workers currently carry out two and a half million irregular overtime hours that are neither paid nor subject to social security contributions, and that tackling this is one of the reform's key goals.

What will the new decree require?

Although the final text has not yet been published in the Official State Gazette (BOE), the draft circulated to date sets out the following requirements for all companies with salaried employees:

Requirements of the new digital working time record

• Digital time-tracking system: paper records and spreadsheets will no longer be valid.
• Recording of start and end time of each working day, breaks, and overtime hours.
• Tamper-proof records: any modification must be logged with user, date, and reason.
• Real-time employee access to their own time record.
• Data retention for a minimum of four years.
• Immediate export of records for Labour Inspectorate requests.

What about companies still using paper or spreadsheets?

Once the new decree comes into force, non-digital record-keeping methods will no longer be valid. Companies still using paper, Excel, or any non-compliant system will face the same sanctions as those keeping no record at all:

Penalties for non-compliance with working time records (LISOS)

• Minor infractions: €70 to €750.
• Serious infractions: €751 to €7,500 (applicable per affected employee).
• Very serious infractions: €7,501 to €225,018.

Under the new rules, serious infractions will be applied individually for each employee whose record is non-compliant, which can significantly multiply the total fine amount.

What should companies do now?

Time to adapt is limited. These are the priority actions to be ready before the regulation comes into force:

Steps to prepare before summer

• Audit your current time-tracking system: is it digital? is it tamper-proof? does it meet the technical requirements of the draft?
• Assess whether your current tool can be adapted or whether it needs to be replaced.
• Implement a digital time-tracking system recording start, end, breaks, and overtime for all employees.
• Make sure remote workers are also clocking in correctly.
• Set up automatic alerts to detect incomplete or missing time entries.
• Guarantee each employee's real-time access to their own record.

Horalia: compliance made simple and affordable

The good news is that adapting to the new decree doesn't have to be expensive or complicated. Horalia is a workforce management platform designed specifically for SMEs and self-employed with staff, at a price that works for real businesses. It already meets all the requirements set out in the new digital working time tracking decree, so you won't need to switch tools when the regulation comes into force: with Horalia, you're already compliant from day one.

Why Horalia complies with the new decree

• Multi-device digital time tracking: mobile, browser, or physical terminal, in-person or remote.
• Tamper-proof record with modification log: every change is traced with user and reason.
• Real-time access for each employee to their own record.
• Automatic four-year data retention.
• Exportable reports for the Labour Inspectorate in seconds.
• Integrated management of absences, holidays, shifts, and employment documents.

Want to know how much a fine could amount to in your company if you don't comply with working time tracking rules? Use our sanctions calculator and get an estimate in seconds.