Last updated: 9 October 2026
Mandatory digital time records: what changes, when, and how to comply
A daily working-time record is already mandatory. The royal decree that spells out the digital record was still unpublished in the official gazette on 9 October 2026. Once published, it is enforceable 20 days later. Until then it cannot be spoken of as if it were already applicable law.
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30-second summary
- Article 34.9 of the Workers’ Statute applies today: a daily working-time record.
- Status of the royal decree: pending. It was not in the official gazette on 9 October 2026.
- What has been described of the draft: digital, unalterable, remote access for Inspection and four years of retention. That is the draft, not a duty already published.
- Paper and Excel can exist as a file and they get lost or rewritten. There is no official seal of approved software.
- Penalties move inside the LISOS ranges. An indicative calculator is not a case file.
Deadlines
| Milestone | Date | Status |
|---|---|---|
| Daily working-time record | Already required | Article 34.9 of the Workers’ Statute |
| Royal decree on the digital record | Waiting for the gazette | Unpublished on 9 October 2026 |
| Enforceable after publication | 20 days after the gazette | Only once the decree exists |
What is required today
Article 34.9 of the Workers’ Statute requires the company to guarantee a daily working-time record, including the specific start and end of each worker’s day. You do not need to wait for the royal decree to have a record.
The reform: the royal decree still pending
The royal decree on the digital time record is pending. It was not published in the official gazette before 9 October 2026. This page shows the update date so the status can change the day it appears.
Once published, the duty arrives 20 days later. Until that day, citing the decree as mandatory is getting ahead of a rule that is not there.
What it has been said it will require
The draft that has been discussed asks for a digital, unalterable record, with remote access for Inspection and four years of retention. That describes the text that is expected, not an article in force. If the published decree says something else, the decree wins.
Is paper or Excel enough?
A sheet or a piece of paper can record one day. They get lost, they are corrected with no trail and they are not handed over by themselves when four years of a site are requested. They are not banned by a magic sentence. They are a poor archive as soon as the team does not fit in one tab.
There is no official approval that turns one program into the only valid record. Anyone selling that seal is selling something the law has not created.
Penalties
Failure to keep the record is penalised under the LISOS, in the ranges that match the seriousness and the number of people. This guide does not put a figure as if it were your company’s fine. The site’s calculator, when published, will be indicative and will say it is not advice.
Remote work and flexible hours
Someone working away from the site still has a working day. Clocking in at the start and the end does not require a geofence around the office if the work is remote. The geofence is a site option, not the legal definition of the record.
How to roll it out in an SME
Sites, people, a clock-in channel the team will actually use and a weekly review of misses. Friday is not the day to rebuild the month. Vacly Time stores the entry and exports the period.
Free template
There is a template to see which columns a decent record asks for and to understand its limits: it is not unalterable and it does not give Inspection remote access. It helps you organise the idea. It does not replace the system when the decree is in force.
Frequently asked questions
Is the digital record already mandatory?
The daily record is. The royal decree that details the digital form was not published on 9 October 2026. That is why this page’s status is pending.
When will the decree be enforceable?
Twenty days after it is published in the official gazette. Without publication that period does not start.
Is there an approved program?
No. There is no official list that approves time-record software. The program has to make it possible to keep the record, not display an invented seal.
Leave the month clocked, not reconstructed
Vacly Time is the module for clock-in, absences and shifts. The commercial time-tracking page sits beside this guide.
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Vacly editorial team. TODO-REVISAR: name of the author and of the adviser who reviews the legal content.