The registration of working hours is a legal obligation and applies, on a general basis, to almost all workers regardless of the sector or the size of the organization or enterprise. Nevertheless, operational doubts remain that raise the risk before a Labour Inspectorate as to who should register the day of persons transferred by an ETT, whether it can be done on paper or how to coordinate time control when hiring and subcontracting at the same centre.
In this guide we solve the most frequently asked questions and provide practical measures for reduce friction in inspection and favouring the anticipation the possible changes in the procedure that seek to strengthen the control schedule in Spain (without treating them as an obligation in force until they are published as a definitive rule).
What the rules of working time records require today
To date, the basic obligation can be summarized as follows:
- Register every day the day of each working person.
- Include, at a minimum, the Real time of start and end of the daily day.
- Keep records for 4 years.
- Keep them available for the working person, legal representation and the Labour Inspectorate.
- In contracts part-timehanding over to the working person a copy of the monthly summary along with the payroll.
Practical recommendation: the system (manual or digital) must be reliable, traceable and consistent with the organization of the work (turns, flexibility, teleworking, displacements, etc.). The more “editable” it is without trace, the more friction it usually generates in a check.
Is manual paper registration still valid?
In January 2026 is still valid manual record (e.g. signed daily sheets), provided that it meets the minimum requirements and that its reliability.
Good practices if you register on paper:
- Use of daily leaves (avoid generic monthly quadrants as the only support).
- Identify: working person, date, time of entry, time of departure and firm.
- Avoid “regulations” after the test (tachones, reconstructions, changes without explanation).
- Keeping the record with access control and secure your conservation 4 years.
Important: a regulatory reinforcement is being processed (not yet in force).
In 2025, the process was promoted to strengthen the time control, with a focus on:
- digitisation,
- accessibility (including inspection),
- and limitation of unilateral changes in the registry seats.
Recommendation: if the company is still on paper, it is appropriate to plan the transition to avoid hasty changes when approved.
Who records the day of workers loaned by an ETT?
As a general criterion, the obligation to daily registration the fall on the user company, because he is the one who exercises the direction and control of the activity during the provision of services.
What does it mean in practice:
- Include persons transferred by ETT in the filing system (the same as used for your own template).
- Keep records 4 years and to have them available before an inspection.
- Provide the records to the ETT, since you need to know the hours actually worked to comply correctly with wage and social security obligations.
What if there are contracts or subcontracts in my workplace?
In sub-contracting, the registration obligation falls within the competence of the contractor/subcontractor, like employera of those workers.
Now, when the service is provided at your center, there is a particularly useful measure to win. reliability and reduce incidences: register in your center with a common system (by agreement). Agree with the contractor on the use of same time control system that uses your company (roofs, corporate app, terminals), so that:
- the file is done in its center, and
- you can forward the result to the employer for custody and fulfillment.
This usually reduces typical problems (reconstructed files, shift discrepancies, lack of traceability) and improves defense against inspections or hourly claims.
What I can review to reduce risks and comply with the regulations:
- Map of collectives: own staff, telework, mobility, ETT, contracts.
- Clear criteria: Computable/non-computable breaks, trips, waits, guards, cuts.
- Traceability of changes: if there are modifications, let there be a trace of the who/when/why.
- Incident protocol: what to do if Internet/light/terminal fails (how it is documented and who validates).
- Access and custody: who can see/download, where it is stored, access control and 4 years conservation.
- Operational integration: crossing with payroll, overtime/compensation and internal reporting.
- Contracts: contractual clause on registration at your place of business and regular delivery records.
If your current system is manualYou've got staff from ETT or you work with several ContractsA review of the registration method, the custody of records and coordination with third parties significantly reduces the risk of non-compliance and facilitates adaptation when regulatory reinforcement is approved.
