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BOE-A-2026-991 ·17 January 2026 ·Act critical
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 99.2 and Annex I of Law 9/2023, requiring companies with more than 10 employees to update their working time records within 3 months. Failure to do so may result in fines of up to 7,500 euros per employee. This change aims to improve transparency and control of working hours in medium and large-sized companies (art. 99.2, Annex I of Law 9/2023).

In 2 key points

  1. Companies with more than 10 employees must update their working hour records within 3 months (art. 99.2)
  2. Failure to update records may result in fines of up to EUR 7,500 per worker (anexo I de la Ley 9/2023)

How it affects those involved

For companies with more than 10 employees, this entails an obligation to update their working hour recording system, with the risk of sanctions if deadlines are not met. Advisors must review their clients' records and provide guidance on adaptation. Workers will not experience direct changes, but their working hours will be more strictly monitored. Regional authorities will be able to better supervise compliance with the regulations.

Lifecycle

2026-01-17PublishedPublished in the BOE
2026-01-01Into forceComes into force (fecha_vigencia (indice oficial del BOE))
Official text Based on BOE data (boe.es). Information, not advice.

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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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