Situation assessment
We review the current registration system, the applicable collective agreement, and any remote-work clauses. We identify non-compliance and quantify the real sanction exposure.
Cumplimiento laboral
Working hours register
Time tracking is mandatory for every company with employees, regardless of size or sector. Since 2019, the Labour Inspectorate (ITSS) has been issuing infringement notices: if your system is still a spreadsheet or paper log, you face a real and quantifiable risk.
Royal Decree-Law 8/2019 made daily working hours registration mandatory for all Spanish companies. The Royal Decree on digital time tracking — currently being processed and expected to be published in the Official Gazette during 2026 — goes further: once in force, paper records and editable spreadsheets will no longer be valid, as they cannot guarantee data integrity or traceability, and the ITSS will be able to demand remote access to the system during any inspection. In 2024, nearly 1,900 infringement notices were issued for working hours violations, with a sustained year-on-year increase.
The most common problem among SMEs is not a lack of willingness to comply: it is that nobody has checked whether the current system — often a shared spreadsheet or a paper sign-in sheet — would survive a Labour Inspectorate visit. A record that can be altered, that does not show start and end times per employee, or that has not been kept for four years, constitutes a serious infringement. If the company also lacks a digital disconnection protocol for remote workers, the exposure multiplies.
At Summum Consultoria we audit the existing system, identify the gaps against current regulations, draft the internal policy and the digital disconnection protocol, and support the implementation of the digital tool that best fits your company's size and operations. We do not sell proprietary software: we evaluate market solutions (or integrate with an existing ERP) and ensure the chosen system meets the evidentiary requirements demanded by the ITSS. We work with SMEs of 5 to 250 employees in Castilla y León and the Canary Islands, and we understand the specific needs of sectors as different as hospitality, construction, and professional services.
The Working hours register process.
The process · four stagesSolution design
We draft the internal working hours policy and the digital disconnection protocol. We evaluate digital tools compatible with the company's operations (mobile app, ERP integration, time-clock terminals) and recommend the most suitable option.
Implementation and training
We support the rollout of the chosen system, configure user access profiles, and train HR managers and employees alike. We document the procedure so the company can manage it independently going forward.
Regulatory review and maintenance
We update documentation when regulations or collective agreements change, and carry out periodic reviews to ensure the system remains valid for ITSS inspections.
What is included
What Working hours register includes.
The operational detail: what we deliver as part of the work and what we keep alive afterwards.
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Audit of the current system
Analysis of the existing registration method, detection of gaps against RDL 8/2019 and the digital reform, and a risk report with quantification of potential penalties.
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Internal registration policy
A formal document governing how, when, and who records working hours, covering on-site, remote, and hybrid work arrangements.
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Digital disconnection protocol
Drafting of the mandatory protocol for companies with remote workers, in accordance with Article 88 of Organic Law 3/2018 (LOPDGDD).
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Tool selection and implementation
Evaluation of market solutions (app, ERP, terminal) based on company size, sector, and budget. Support throughout implementation and initial configuration.
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Training for managers and staff
A practical session for HR teams and managers on using the system, handling incidents, and retaining data for the four years required by law.
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Ongoing regulatory updates
Monitoring of legal changes (working hours reform, Labour Statute amendments, new ITSS criteria) and updating documentation as required.
Summum cluster
How it connects with its sisters.
Working hours compliance connects naturally with the digital HR management offered by Summum Sistemas and with the equality plans we also handle in Consultoria.
consultoría
Summum consultoría
Equality plans include measures on working-time organisation that must be aligned with the working hours registration system in place.
View service → sistemasSummum sistemas
When a company needs a time-tracking solution integrated with payroll and HR, Summum Sistemas implements the relevant module in the ERP.
View service →Frequently asked questions about Working hours register.
Is working hours registration mandatory for all companies, including micro-businesses?
Yes. RDL 8/2019 sets no headcount threshold: any company with at least one employee is required to comply, regardless of sector or legal form. Micro-businesses and self-employed employers with staff are equally subject to the rule.
Are spreadsheets or paper records still valid in 2026?
The Royal Decree on digital time tracking — in process since late 2025 and pending publication in the Official Gazette — will require the system to guarantee data integrity, immutability, and traceability. Under the current rules (RDL 8/2019), the Labour Inspectorate already has grounds to reject an editable spreadsheet or a paper log as valid evidence if it considers the record lacks the required reliability guarantees, making it prudent to upgrade before the reform takes full effect.
What information must the register contain?
The start time and end time of each employee's working day must be recorded daily. The company is required to retain those records for four years and make them available to employees, their legal representatives, and the ITSS upon request.
What happens if the company fails to comply?
Failure to maintain a working hours register is classified as a serious infringement under Article 7.5 of the LISOS, with fines ranging from €751 to €7,500 per infringement. In 2024, the ITSS issued nearly 1,900 specific notices for this reason, with a sustained increase compared to previous years.
Does the obligation apply to remote and hybrid workers?
Yes. The obligation applies regardless of where the work is performed. In addition, companies with remote staff must have a digital disconnection protocol in place, in accordance with Organic Law 3/2018 (LOPDGDD). Both documents must be in force and communicated to all employees.