BOE-A-2026-991 ·17 January 2026 ·Act High impact
Tax

Companies with more than 10 employees: 3 months to update working time records or fines up to 7,500 EUR/employee

The Law 9/2025 modifies Article 31 ter and adds new provisions requiring companies with more than 10 employees to maintain an updated working time record in electronic format. This record must be updated within three months of entry into force. Fines of up to 7,500 euros per employee are established for non-compliance (art. 31 ter, ad. disp. 8).

In 3 key points

  1. Employers with more than 10 workers must update their electronic shift records (art. 31 ter)
  2. Fines of up to €7,500 per worker for failure to maintain shift records (disp. ad. 8)
  3. Three-month adaptation period from the law's entry into force (art. 31 ter)

How it affects those involved

Employers with over 10 staff must maintain electronic shift records, with fines of up to €7,500 per worker for non-compliance. A three-month transition period applies from the law's entry into force. Affected SMEs and large firms must update their shift registration systems. Workers are not directly involved, but their working hours are subject to administrative control.

Lifecycle

2026-01-17PublishedPublished in the BOE
2026-04-01Into forceComes into force (disposicion final segunda)
Official text Based on BOE data (boe.es). Information, not advice.
PDF on boe.es

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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