Labour Ministry eyes July Cabinet meeting to approve time-tracking rules

Legal note: This article is informational and does not constitute legal advice. The Royal Decree described is still in progress and has not yet been published in the BOE.

For the first time in months, digital time tracking has a date window. On 2 July 2026, the Secretary of State for Labour, Joaquín Pérez Rey, stated that the Ministry is “technically fine-tuning” the reform and expects to approve it “at one of the Cabinet meetings before the summer break”. He said so at the press conference on June’s unemployment figures, as reported by La Voz de Galicia.

That phrase leaves two possible dates. August empties the Government’s agenda, so the only Cabinet meetings left before the break are those of 21 July and 28 July. Anything that does not come out on one of those two Tuesdays effectively slips to September.

Why this date is more credible than the previous ones

Caution is warranted: time tracking has spent months piling up deadlines that go unmet. That said, two things make this forecast carry more weight than those of the spring.

The first is the route. The reform will be approved as a standalone Royal Decree, without going through Parliament. When time tracking was part of the package to cut the working week to 37.5 hours, it depended on a parliamentary majority the Government cannot guarantee. By splitting it off from that law, approval rests with the Cabinet and no one else. That is one less political hurdle.

The second is the pressure. This very week, CCOO and UGT issued an ultimatum: time tracking before 31 July or they stop signing agreements with the Executive. The Ministry’s two working dates fall right within that window, aligning the Government’s interest with the unions’.

The obstacle the Ministry has had to work around

The preceding step was not simple. On 23 March, the Council of State issued an unfavourable opinion on the reform. It focused less on the substance —digital time tracking— than on the form: it questioned the lack of sector-by-sector tailoring, the extra burden on SMEs and, above all, that a measure of this scope should be approved by Royal Decree rather than by a law-ranking rule.

That opinion is not binding, and the Government has decided to press ahead down the regulatory route anyway. But it explains the delay: much of these months has gone into rewriting the text to, in Pérez Rey’s words, guarantee “the greatest possible legal integrity” before taking it to Cabinet. Hence he now speaks of “fine-tuning” the final details rather than negotiating the content.

What the register will require once approved

The core of the rule holds firm from the draft. Once it takes effect, time tracking will have to be digital and interoperable with the Labour Inspectorate, which will be able to consult it remotely and act on its own initiative in the face of possible breaches. For each working day, the register must break down:

• Clock-in and clock-out time.
• Start and end of each break.
• Regular, overtime and supplementary hours.
• Whether the work is on-site or remote.

The Ministry’s aim is for the Inspectorate to be able to check whether working-day limits are respected and whether extra hours are paid. Workers and their legal representatives will be able to consult and obtain a copy of the records immediately, and penalties for non-compliance are counted per affected worker, not per company.

What the date still does not clarify

Approving the decree in July does not mean the obligations land overnight. Two unknowns remain that directly affect companies.

One is the adaptation period. Decrees of this kind usually grant a window —often a couple of months from publication in the BOE— before they become enforceable. The other is the subsequent ministerial order, which will set the technical fine print of the register: the detail that determines exactly what a piece of software must meet to be valid. That order is processed separately and arrives weeks or months after the decree. For an SME, the preparation window starts running with the decree, not with the penalties.

What to do if you still clock in on paper

If your company records working hours on paper or in a spreadsheet, the final text barely changes the diagnosis: those formats do not comply, and the transition takes time. Bringing it forward avoids having to do it against the clock.

1. Check whether your current system stores the hour and minute of clock-in, clock-out and breaks, and whether that data is safe from untraceable edits.
2. If you clock in on paper or Excel, start the switch without waiting for the BOE.
3. Follow the ministerial order that comes after the decree: that is where the technical requirements any tool will have to meet will be set out.
4. If you have shifts, breaks or remote work, choose a solution that handles that reality and not just the legal minimum.

Cleverfy, ready for the decree ahead

Cleverfy records the working day to the exact hour and minute, leaves an immutable trace of every clock-in and every edit, separates regular, overtime and break hours, and keeps the data for the four years the regulation requires. It works from web, mobile and tablet, from €1.50/employee/month.

If approval arrives in July, the adaptation period will run afterwards. Try it free and face publication with compliance already sorted.

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Sources: La Voz de Galicia, Onda Cero, Expansión.

Image: Joaquín Pérez Rey, Spanish Secretary of State for Employment. © Ministry of Labour and Social Economy, via Wikimedia Commons (Attribution licence).