Mandatory digital time registration: where it stands
The Ministry of Labour is processing a Royal Decree that would require working time to be recorded digitally, with reliable records and remote access for the Labour Inspectorate. As of 17 October 2026 it is a draft: it has not been approved or published in the BOE.
What the draft Royal Decree proposes
Exclusively digital registration
Time would be recorded by digital means. Only after a justified technical incident could another medium (e.g. paper) be used, with the entries moved to digital afterwards.
Immutable records
Entries could not be changed without the approval of both company and worker, and any change would record who made it.
Personal entries
Each entry would be made «freely, personally, directly and immediately» by each worker. The draft does not regulate a specific identification method.
Real-time access
The Labour Inspectorate could access the record at any time and immediately, remotely and at the workplace.
Minimum 4-year retention
Four-year retention stays, as already required today by article 34.9 of the Workers' Statute.
What would stop being valid if approved
Paper registration or sign-in books
Excel or Google Sheets spreadsheets
Systems without individual credentials
Records that can be edited without audit trail
Systems without remote access for inspection
How Ficha.Work complies with the regulation
100% digital registration with mobile app and web
Individual credentials: PIN, QR, and NFC
Immutable records with correction history
Real-time access from any device
4-year data retention with exportable reports
In practice, the simplest way is for each worker to log their day with a time clock app on their own phone: individual credentials, exact timestamps and no hardware to buy.
Current regulation status
As of 17 October 2026: a prior public consultation took place (12–26 September 2025), the Council of Ministers authorised urgent processing on 30 September 2025 and the draft went to public hearing in October 2025. It has not been published in the BOE and has no entry-into-force date. Separately, the 37.5-hour workweek bill was rejected by Congress in September 2025.
Recommendation: a daily working-time record is already mandatory today (art. 34.9 Workers' Statute). A digital system with individual credentials, corrections with history and exports lets you comply now and leaves you better prepared if the reform is approved.
For the law in force, the fines and who must comply, read our guide to Spain's time-recording law.
We'll tell you when digital time recording becomes mandatory
Spain's Government is drafting a royal decree that would require working time to be recorded digitally, with every change traceable and access for the Labour Inspectorate. It isn't in the BOE yet. Leave your email and we'll let you know the day it's published, with what changes and how to adapt.
Frequently asked questions
When does the new regulation take effect?+
There is no date. As of 17 October 2026 the Royal Decree is a draft and has not been published in the BOE.
Can my company be penalized for using paper?+
RDL 8/2019 already requires a daily working-time record, but it does not set the format: paper is valid if it meets the requirements. Not keeping the record is a serious infringement (€751 to €7,500). If the Royal Decree is approved, the record would have to be digital.
What if I already use Ficha.Work?+
Ficha.Work already covers the main points of the draft: digital recording, personal entries, corrections with history, immediate access and export, and 4-year retention. If the final text changes, we will adapt the product.
Can facial recognition be used?+
The draft does not expressly mention biometrics. What limits fingerprint and face recognition today is the GDPR: the AEPD considers biometric attendance control high-risk processing and says worker consent cannot legitimise it.
How much does it cost to comply?+
Ficha.Work costs from €1 per user per month with all features included. You can try it free for 14 days.
Prepare your company for the new regulation
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