Working-time records in Spain in 2026: what the law requires today and what it doesn't yet
Since May 2019, every company in Spain has had to record each employee's daily working time. This is set out in article 34.9 of the Workers' Statute (Estatuto de los Trabajadores), and it doesn't depend on company size or sector.
What the law requires today
The record must show the specific start and end time of each person's working day, every day. The company must keep it for four years and make it available to employees, their representatives and the Labour Inspectorate.
What it doesn't require yet
There has been a lot of talk about a regulation that would require the record to be digital and remotely accessible to the Inspectorate. Art. 34.9 on its own doesn't specify a digital format. We haven't verified regulatory changes as of the review date: check the Spanish Official Gazette (BOE) and a professional before deciding on the format or remote access required.
Why traceability matters
The format not being fixed doesn't mean anything goes. The record must be reliable. If anyone can open a file and change a time without leaving a trace, defending that record before an inspection or a court is hard. A good record has three properties: it's made at the time, it can't be changed without leaving a trace, and it can be shown in full without touching anything.
What to do now
Choose a system where corrections don't replace the original but are added as a new record showing who made it and why. Make sure each person can see their own. Keep the data for four years. A digital system doesn't on its own guarantee compliance with future rules.
How peopleOS handles it
The Time tracking module works exactly like this: each entry is stored and can't be deleted, corrections are stored as new records with author and reason, and you can export everything for the Inspectorate.
Read also: Building your HR software by talking to an AI: what People does and doesn't do.
This article is informative and reflects Spanish law as of November 2026. It is not a substitute for professional advice. Check the current rules and your collective agreement with a professional.
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