Spain's working-time record in Odoo: registro de jornada, step by step.

Article 34.9 of the Estatuto de los Trabajadores (Workers' Statute) says that the company shall guarantee a daily record of working time, which must include the specific start and end time of each employee's working day. It was added by Royal Decree-law 8/2019, published in the BOE on 12 March 2019, which made it apply two months after publication.

According to the Ministry of Labour guide on the working-time record (Spanish), it applies to all employees, whatever their category, in all sectors and in all companies, whatever their size. It expressly includes people who work fully or partly away from the workplace: sales staff, mobile and temporary workers, and remote workers.

• Senior management: senior management staff (art. 2.1.a ET) are excluded, according to the guide. As a rule, middle managers and positions of trust with flexible hours are still recorded.
• Part-time: part-time work already had its own record (art. 12.4.c ET): hours are recorded day by day and totalled each month, and the employee gets a copy of the summary with the payslip. If this record is not kept, the contract is presumed to be full-time unless proven otherwise.
• Overtime: art. 35.5 ET requires working time to be recorded day by day and totalled per pay period, with a copy of the summary on the payslip. The guide says the art. 34.9 record can also be used for this.
• Temp agencies and subcontractors: for agency workers the user company keeps the record; for subcontracting, the contractor, as the employer (Ministry guide).

• Minimum content: the specific start and end time of each person's working day, every day (art. 34.9 ET).
• Breaks: the Ministry guide advises recording breaks too. Otherwise all the time between clock-in and clock-out may be presumed to be working time.
• Who decides the system: the record is organised by collective agreement or company agreement or, failing that, by the employer after consulting the workers' legal representatives (art. 34.9 ET).
• Format: the law sets none. According to the guide, any system on paper or electronic is valid if it gives reliable information that cannot be changed or manipulated afterwards, by the employer or the employee, and ensures traceability.
• Privacy: if the system uses digital devices, video surveillance or geolocation, the privacy rights of art. 20 bis ET and Organic Law 3/2018 on data protection apply, as the guide points out.

Article 7.5 of the Law on Social Order Infringements and Sanctions (LISOS) classes breaches of the rules on working time, rest and the working-time record, among others, as a serious infringement. Its article 40.1.b sets fines for serious infringements of €751 to €1,500 (minimum degree), €1,501 to €3,750 (medium degree) and €3,751 to €7,500 (maximum degree).

Not yet. Spain's Ministry of Labour has published a draft royal decree on its public participation portal that would develop the working-time record and require it to be kept by digital means. As of 18 October 2026 it has not been published in the BOE (Spain's official gazette): it is a draft, it is not in force and it has no date of entry into force. Today art. 34.9 ET applies, and it does not require any particular format.

If it is published, we will review this guide and the app against the final text.

Our app Registro Jornada Spain (l10n_es_hr_registro_jornada) builds the working-time record on top of Odoo Attendances (hr_attendance): clocking in stays the same, by kiosk, systray or manual entry. It works on Odoo 17, 18, 19 and 20, Community and Enterprise, on Odoo.sh or on-premise.

1. Install the app. The Setup checklist opens (later: Registro de jornada › Configuration › Setup checklist). It lists employees without a working schedule, without an ID document or without a date of birth (used to apply the limits for minors), who cannot sign online, and forgotten check-outs, each with a button to fix it.
2. In Configuration › Settings, match the alerts to your collective agreement: maximum ordinary hours per day (9 by default), minimum rest between workdays (12 hours), break after 6 hours (at least 15 minutes) and weekly, monthly and yearly alerts. By default, correcting an attendance requires a reason.
3. In the same settings, retention cannot go below 48 months, the four years of art. 34.9 ET. Automatic deletion after that period is optional and off by default.
4. In Configuration › Break types, review the default breaks (rest break, paid rest break “bocadillo” of up to 15 minutes, meal break, personal matters and medical visit) and mark which are paid under your agreement. Paid breaks count as working time.
5. Employees clock in and out as usual. Each attendance can be marked on site or remote, with the type of the preceding break. Per workday the app computes worked hours, breaks, split shifts, night hours (22:00–06:00), remote hours and hours above schedule, and warns about excess hours, missing breaks or rest, missing check-outs, overlaps and scheduled days without a record. Every attendance creation, change or deletion goes to the Audit log, append-only, chained with SHA-256 and verified daily.
6. Each month the records for the previous month are prepared automatically (or use Prepare month). Review the warnings, correct attendances with a reason and click Close month: the attendances of that month are locked. Only an administrator can reopen it, and must give a reason.
7. Employees sign under My records or in the portal (/my/working-time, also on a phone); with the default setting they get an e-mail with the link. Paper signatures are registered with Signed on paper. With Download my data, each person gets their own record and change history.
8. When the inspectorate or the workers' representatives ask, create a link in Inspection › Inspector links: read-only, limited to a period and a set of employees, with an expiry date (at most 30 days by default) and revocable; every use is logged. Or use Export for inspection: the daily record as CSV, JSON or XML, the monthly records as PDF and the audit trail as CSV.

• It does not decide which hours are overtime. “Hours above schedule” is a daily figure; how it is classed depends on your collective agreement and the annual distribution of hours.
• It does not replace the collective agreement, company agreement or consultation with the workers' representatives on how the record is organised.
• It does not hand out the monthly summaries with the payslip for you (part-time and overtime); the monthly PDF with the month's totals is a basis for them.
• It sends nothing to the inspectorate or to Normalane: the data stays in your Odoo. The inspectorate only sees it if you create a link or export.
• Gaps between attendances without a break type count as unpaid breaks, unless you set a default break type.
• Signing in Odoo or the portal is a simple electronic signature (login, time and IP address).
• It does not run on Odoo Online, which does not allow third-party modules.