Mandatory digital time recording in 2026: planned schedule, requirements, and practical guide for SMEs and the self-employed

Planned timetable for entry into force

This new regulation on mandatory digital time recording is expected to come into effect during the first half of 2026. Although there is no exact date yet, publication in the Official State Gazette (BOE) will establish the deadline for compliance. It is essential that companies, especially SMEs and self-employed workers , begin preparing for this legislative change well in advance.

The change in legislation will affect all companies, regardless of their size, so it's important to know all the details and requirements to avoid penalties for noncompliance. Want to learn more? We'll explain it to you at Puigverd Assessors.

What are the requirements for digital time recording?

Digital time recording must be carried out using digital tools that meet a series of requirements established by regulations. These requirements are essential to ensure transparency and proper implementation of the working day. The most important requirements are the following:

• Complete digitalization : Starting in 2026, time recording must be completely digital. This eliminates the use of manual systems such as spreadsheets or paper recording. Appropriate technological tools must be implemented for this recording.
• Remote access for the Labor Inspectorate : Recording systems must allow the Labor Inspectorate to access them in real time and remotely. This will ensure transparency and compliance with labor regulations.
• Individualized worker identification : Each worker must personally identify themselves when clocking in and out. This can be done using fingerprints, personalized cards, or other secure identification methods.
• Data inalterability : Digital records cannot be modified without the worker's explicit consent. This will ensure that the data is reliable and verifiable.
• Data retention for 4 years : The data collected must be stored and retained for a minimum of four years, so that any inspection or audit can be carried out at any time.

These requirements not only aim to ensure compliance with the work schedule, but also to prevent possible fraud in recording hours worked.

Practical guide for SMEs and self-employed workers

To adapt to this new legislation, SMEs and self-employed workers must follow a series of steps to comply efficiently :

1. Needs assessment : Before implementing any record-keeping system, it's essential to assess the company's specific needs. Each type of activity may require a different record-keeping system, so it's important to analyze what's actually needed.
2. Selecting an appropriate digital system : It's necessary to choose a digital tool that meets all legal requirements. There are various options available, such as mobile apps, labor management software, or recording systems based on the use of specific machinery.
3. Staff training : Once the system has been selected, all employees must be trained to properly use the new recording tool. Training will be key to avoiding errors and ensuring that all employees can record their hours correctly and securely.
4. Implementation of the recording system : It is important to implement the system well in advance of the regulations' entry into force to ensure it is functioning correctly. This includes internal testing and verification that all data is properly recorded and retained.
5. Internal reviews and audits : Once the system is implemented, regular internal audits are necessary to verify that the system is still functioning correctly and that data is being recorded accurately. This will also help detect potential errors before an inspection occurs.

It's important to remember that any failure in the implementation or use of the system can result in penalties. Therefore, it's essential to ensure that the digital timekeeping system complies with current legislation at all times.

Consequences of non-compliance with regulations

Failure to comply with regulations on digital time recording can result in significant financial penalties for companies. These penalties will be imposed by the Labor Inspectorate and may vary in nature, depending on the severity of the violation.

Possible penalties include:

• Financial fines : Fines can be substantial and may be imposed gradually, depending on the number of employees affected and the severity of the violation.
• Temporary disqualification : In some cases, the company may be temporarily disqualified from hiring new workers until it complies with the regulations.
• Operating Prohibition : In very serious cases, a company may be forced to temporarily cease its activities until it complies with legal requirements.

Therefore, it is crucial that all businesses, including SMEs and self-employed workers , take the necessary measures to comply with these new regulations and avoid sanctions that could jeopardize their economic activity.

The Puigverd Assessors team is available to advise and help you implement digital time recording in your business.

Contact us for more information and personalized advice.