In recent months, many companies have been receiving communications or recommendations from external suppliers who insist on the supposed mandatory nature of electronic time recording. This situation has caused some confusion, especially among SMEs and self-employed workers with employees. However, as of today, current labour legislation in Spain does NOT require clocking in to be done using electronic systems.
📌 What does the current legislation say?
Article 34.9 of the Workers’ Statute, following its amendment by Royal Decree-Law 8/2019, establishes that all companies must ensure the daily recording of the working hours of their employees. But the important thing is this:
🔍 The law does not establish a mandatory format for such recording.
This means that time control can be carried out either electronically or on paper, provided that it is reliable, accessible and available for possible labour inspections for at least four years.
📄 Is paper recording valid?
Yes. Manual paper recording is still perfectly legal, provided that it meets the following requirements:
- It records the start and end times of each employee on a daily basis.
- It is accessible to the employee, the company and the Labour Inspectorate.
- It is kept for the legally established period.
- It is signed or validated by the employee.
🚫 What about external platforms that require it?
Many companies that provide HR or occupational risk prevention software are promoting the implementation of digital clocking-in systems, presenting them as ‘mandatory by law’. Although these systems can offer management and control advantages, they are not legally required.
✅ Conclusion
To date (October 2025), there is no regulation requiring companies to implement an electronic time recording system. What is mandatory is to keep track of working hours, and this can be done manually, on paper or using digital tools, depending on the reality and needs of each company.
Aaron Cheung Gallardo.