From timekeeping to cultural shift
The digitalization of time control marks a turning point in the management of working hours, with implications that go beyond the technical to transform workplace culture
Experts: María José Sánchez, partner at RocaJunyent; Enrique Ceca, labor partner at Ceca Magán; and Jaime Silva, partner at Labormatters Abogados.
by mercedes galán
Since the entry into force of Royal Decree-Law 8/2019, time tracking has been mandatory in all Spanish companies. However, until now, compliance was allowed through analog means, such as Excel sheets or paper records. The new Draft Law, published on May 16, 2025, in the Official Gazette of the Spanish Parliament, proposes to amend Article 34 bis of the Workers’ Statute to establish the requirement of an exclusively digital time tracking system, traceable and with real-time access for the Labor Inspectorate and workers’ legal representatives.
This new regulation, still under parliamentary review, not only reinforces control mechanisms but also points to a structural transformation of the labor model, at a time when flexibility and digitalization are key pillars of the organizational debate. María José Sánchez, partner at RocaJunyent, reminds us that “for now it is a Draft Bill, and we must wait for the outcome of the parliamentary procedure, which does not seem easy. The obligation of an exclusively digital registry may be problematic, especially for small businesses, and will generate additional costs for those that are not yet digitized.”
MORE THAN JUST A CONTROL TOOL
Although time tracking is not new in Spanish legislation, its application has so far been uneven, especially in hybrid environments or sectors with high mobility. The new law toughens the sanctioning regime, with fines of up to 10,000 euros per affected worker, and sets technical criteria that limit managerial discretion.
For Enrique Ceca, labor partner at Ceca Magán, this reform “goes beyond being a mere control tool. It is, undoubtedly, a structural reconfiguration of how working time is managed and certified within our legal-labor framework.” María José Sánchez adds that “the recording of interruptions, immediate accessibility, and future interoperability imply a structural change in time management, with effects on flexibility, self-organization, and the protection of personal data.”
Jaime Silva, partner at Labormatters Abogados, warns that “it is premature to make an assessment today. We will have to wait for the final version of the text, if approved. Precisely, the requirement that the time tracking system be exclusively digital may be one of the elements of the law to be adjusted during the parliamentary process, as it raises serious doubts about the feasibility of its real implementation in many Spanish companies.”
REGISTRATION, TRACEABILITY AND TECHNOLOGICAL CHALLENGES
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