Digital time tracking in Spain (registro de jornada digital) is not mandatory yet. As of October 2, 2026, the royal decree (real decreto) that would impose it has been neither approved nor published in the BOE, Spain’s official gazette, so there is no date for it to take effect. Spain’s Ministry of Labour says it expects to take it to the Council of Ministers during October.
On this page we follow the royal decree step by step: where it stands, what it would require according to the official text known so far, and what deadline there would be to adapt. We update it every time there is a development.
Status as of October 2, 2026
Approved by the Council of Ministers? No.
Published in the BOE? No.
Is there an effective date? No.
Latest development: on October 2, the Secretary of State for Labour said he expects to clear the way for the record to go to the Council of Ministers in October.
Where it stands
The draft has been in process for more than a year. It has already gone through the public consultation, the public information period, and the opinion of the Council of State, which was unfavorable. Only the one thing that matters is missing: approval by the Council of Ministers and publication in the BOE.
Since summer it has been announced several times and has not arrived. In July it was postponed to September. In September the Labour Minister said it would be approved “immediately,” and none of that month’s Council of Ministers meetings brought it forward. Now the Ministry is talking about October.
Until it is published, what applies is the 2019 rule: daily recording of start and end times, in whatever medium the company chooses.
Timeline of the royal decree
| Date | What happened |
|---|---|
| May 12, 2019 | Daily working time recording becomes mandatory (Real Decreto-ley 8/2019). It does not say in what medium it must be kept. |
| Sept 10, 2025 | Spain’s Congress sends back to the Government the bill to cut the working week to 37.5 hours, which included the digital record. |
| Sept 11, 2025 | The Ministry of Labour separates the digital record into its own royal decree and opens the prior public consultation (from September 12 to 26). |
| Sept 30, 2025 | The Council of Ministers authorizes urgent processing. |
| Oct 9, 2025 | The draft text is published for public hearing and information (from October 10 to 20). It is the only official text that has been published. |
| March 6, 2026 | The Ministry opens the prior consultation on a ministerial order (orden ministerial) that will set the technical and security requirements for the recording systems. There is still no text for that order. |
| March 23, 2026 | The Council of State issues an unfavorable opinion. Among other things, it criticizes doing it by royal decree rather than by law and the burden on small businesses. The opinion is not binding. |
| July 24, 2026 | The Ministries of Labour and Economy postpone approval until September to rewrite the text. |
| Sept 9, 2026 | The Labour Minister says there is agreement and that it will be approved “immediately,” once the legal adjustments are finished. |
| September 2026 | The Council of Ministers meetings on the 15th, 22nd, and 29th do not approve it. |
| Oct 2, 2026 | The Secretary of State for Labour says he expects to take it to the Council of Ministers in October and that the text has been revised to strengthen data protection and give more weight to collective bargaining. |
The 2025 dates and the March 2026 date for the technical order come from the Ministry of Labour website and the official summaries of the Council of Ministers meetings. The opinion and the statements come from what Europa Press published at the time.
What the royal decree would require
What follows comes from the text the Ministry published in October 2025. It is a draft: the Ministry has said it has changed it after the Council of State opinion, and the final text is not known.
| Topic | Today | With the draft |
|---|---|---|
| Medium | Paper, Excel, or app | Digital only. Paper only if a breakdown prevents clocking in, and then transferred to digital later |
| What is recorded | Start and end time | Also each break with its hour and minute, whether the day is on-site or remote, which hours are ordinary, overtime or complementary (the extra hours of part-time contracts), and the total for the day and month |
| Who clocks in | It does not say | Each person, by themselves and at the moment of starting and finishing |
| Corrections | Not regulated | With authorization from the company and the person, leaving a trace of what was changed and who did it |
| Each person’s access | The record is “available” | Consultation and copy of their clock-ins at any time, and a summary with each payslip |
| Labour Inspectorate | Requests it and is shown it | Immediate access, also remotely |
| How long it is kept | Four years | Four years |
| Company paperwork | Put in writing how it is organized | A record protocol, consulted with employee representatives, and training for those who clock in, during working hours |
Three details from the same text are worth knowing:
- It applies to all companies. There is no headcount threshold or different treatment for small businesses.
- There are no approved apps. The draft leaves the choice of system open: one that meets the technical requirements set by the ministerial order, or another one with a technician’s report justifying it. The order does not yet exist.
- Domestic work is treated separately. Someone who employs a person at home could keep the record “by any means” proportionate to their resources.
When it would take effect
The October 2025 text says, in its final provision, that the royal decree enters into force “twenty days after its publication in the Official State Gazette.” It does not give a separate adaptation period.
That very short period was one of the most criticized points, and the text has been revised since then. Until it is published, it is not known whether the final version keeps the twenty days or gives more time.
What can be taken as certain:
- As long as it does not appear in the BOE, no deadline runs.
- The deadline will be written in the final provisions of the royal decree. That is the first thing to check on the day it is published.
- It could be as short as twenty days. With that margin, there is no time to choose an app, sign up the staff, and teach them how to clock in.
What is required today
Today’s obligation is in article 34.9 of the Spanish Workers’ Statute (Estatuto de los Trabajadores) and does not depend on the royal decree:
- daily recording of each person’s start and end time;
- kept for four years, available to staff, their representatives, and the Spanish Labour Inspectorate (Inspección de Trabajo);
- in the medium chosen by the company, as long as it is reliable and cannot be altered afterward.
Not keeping it is a serious offense, with a fine of €751 to €7,500. The royal decree does not change those amounts, because they are set by a statute. We explain it in full in the guide to working time recording in Spain.
Anyone who keeps it today on paper or in Excel complies, if done properly. For that, you have our free timesheet template for Spain in Excel.
What to do in the meantime
You do not need to wait for the BOE to be ready. These five things work under today’s rules and are what the draft asks for:
- Move the record to digital. It is the only change that cannot be done in an afternoon, because the staff has to get used to it.
- Have each person clock in their own time. No one in the office should fill in everyone’s hours at the end of the week.
- Record breaks. With their start and end time, not as a fixed deduction.
- Stop correcting on top of the entry. A wrong clock-in is not overwritten: it is corrected separately, with the reason, and the person sees it.
- Write down how it works. A sheet explaining how to clock in, who corrects, and how breaks are counted. If there is employee representation, consult it.
Get ready with Fichómetro
Fichómetro (our own product) is a time-tracking app designed for small businesses, and it already works the way the draft asks on the main points. Each person clocks in with one tap, with their breaks and marking whether they are on-site or working remotely. The server sets the time and nobody can change or delete a clock-in: corrections are added with their reason, author, and time, and the person can see them. Each person checks their days from their phone, the monthly summary is prepared automatically, and the Labour Inspectorate enters with a read-only link. When the final text and the technical order are published, we will adapt whatever is needed. It is free forever if 1 person clocks in. With more, €2 per active person per month (VAT not included), with a 30-day free trial and no card required. The app is available in Spanish, Catalan, Galician, Basque and English.
A warning, whichever app you use: today nobody can say their software “complies with the royal decree,” because there is no final text or technical order. What can be checked is whether it already does the things in the table above.
Frequently asked questions
Is digital time tracking already mandatory?
No. As of October 2, 2026, the royal decree has not been approved or published in the BOE. Today the record can be kept on paper, in Excel, or in an app.
When does digital time tracking take effect?
There is no date. The October 2025 draft provided for it to take effect twenty days after publication in the BOE, but the text has been revised and the final deadline is not known.
Can I keep using paper or Excel?
Today yes, if the record is daily, with the actual time and cannot be altered afterward. When the royal decree takes effect, according to the draft, paper would only be valid if a breakdown prevents clocking in.
Does it affect small businesses?
Yes. The draft applies to all companies, with no minimum headcount. A self-employed person with no employees does not have to keep a record.
Will an approved app be required?
There is no official list or approved apps. The draft refers to technical requirements that will be set by a ministerial order that still has no text.
Will fines increase with the royal decree?
No. The fine for not keeping the record is set by Spain’s Law on Offenses and Penalties in the Social Order (LISOS), from €751 to €7,500, and a royal decree cannot change it.
What happens with the Council of State opinion?
It was unfavorable, but it is not binding. The Spanish Government can still approve the royal decree, and says it has changed the text to address its criticisms.
Conclusion
Digital time tracking has no date, and it has been announced for months as “any day now.” The sensible thing is not to wait: the day it appears in the BOE, the deadline could be weeks away, and what it requires can already be in place today. We will return to this page with every step.
This article is informational and does not replace the advice of your labour adviser (asesoría laboral). It describes a draft regulation that may change before publication.
Useful links
- Working time recording in Spain: what the law requires today, with the fines.
- Timesheet template for Spain in Excel: to comply today without an app.
- Part-time working time record in Spain: the monthly summary and complementary hours.
- Fichómetro: time tracking for small businesses, free for 1 person.
- Draft text of the royal decree that the Ministry of Labour put out for public information in October 2025 (PDF, in Spanish).
- Summary of the Council of Ministers meeting of September 30, 2025, with the decision to fast-track it (in Spanish).
- Article 34 of the Workers’ Statute, in the BOE (in Spanish).
