The Resolution of 14 April 2026 issued by the State Secretariat for the Civil Service (Secretaría de Estado de Función Pública) came into force on 16 April 2026. It sets the standard working week in Spain’s central government (Administración General del Estado, AGE) at 35 hours and gives ministerial departments and public bodies one month to adapt their work calendars and their time tracking systems. It is the latest step in a trend that has been under way for years: time tracking in public administration has gone from being a signing-in sheet at the front desk to an information system with security, traceability and interoperability requirements of its own. This guide explains which rules bind which groups of staff, what the system must do and how to implement it without repeating the most common mistakes.

Which rules require working time to be recorded in a public body

Two regimes coexist in the public sector, and the system has to serve both:

Contract staff (personal laboral, public employees hired under ordinary employment law): they are covered by Article 34.9 of the Workers’ Statute (Estatuto de los Trabajadores), introduced by Royal Decree-Law 8/2019 (Real Decreto-ley 8/2019). That means a daily working time record showing start and finish times, kept for four years and available to the Labour Inspectorate (Inspección de Trabajo) and the workers’ representatives. The Inspectorate has jurisdiction over public authorities’ contract staff, so a provincial council (Diputación) or a publicly owned company can be inspected just as any company can.
Civil servants (personal funcionario): their working hours are set by each public authority under Article 47 of the consolidated text of the Basic Statute of Public Employees (Estatuto Básico del Empleado Público). In central government this is done by the resolution setting out instructions on working hours and schedules; in autonomous communities (regions) and local authorities, by their own instructions, negotiated agreements or regulations. In every case a time tracking system exists because the rules themselves presuppose one: the April 2026 resolution requires staff to record “all arrivals and departures corresponding to their working time arrangement” and to enter absences and lateness in the system “whatever their cause”.

On top of those two layers come the cross-cutting rules:

National Security Framework (Esquema Nacional de Seguridad, ENS), governed by Royal Decree 311/2022 (Real Decreto 311/2022). The time tracking system processes public employees’ data and supports compliance with a legal obligation, so it is one of the public body’s information systems and must be categorised and protected in accordance with the ENS, just like the case management system. We explain this in the guide on what the ENS is and why your supplier must have it.
Data protection: Organic Law 3/2018 (Ley Orgánica 3/2018, Spain’s data protection act) regulates the use of digital devices (Article 87), the right to disconnect (88), video surveillance (89) and geolocation (90). Clocking in with geolocation requires staff to be informed beforehand and the measure to be proportionate; biometric clocking in requires an impact assessment and, in practice, a non-biometric alternative.
E-government: Laws 39/2015 and 40/2015 (Leyes 39/2015 y 40/2015) and the National Interoperability Framework (Esquema Nacional de Interoperabilidad, ENI) shape how the system exchanges data with the entity’s own HR management, payroll and registry.
The royal decree on digital working time records for the private sector, which at the time of writing (15 September 2026) has still not been published in the BOE (Boletín Oficial del Estado, the official state gazette), following the unfavourable opinion of the Council of State (Consejo de Estado, the Government’s supreme advisory body) of 23 March 2026 and the announcement by the Ministry of Labour, on 9 September, that the decree would be approved “immediately”. It will affect public authorities’ contract staff when it comes into force, and its requirement for records that are tamper-proof and remotely accessible to the Inspectorate sets the technical standard it makes sense to aim for now.

What the system must do: functional and technical requirements

A time tracking system for a public body is not a time clock with swipe cards. At the very least, it must handle:

Recording and calculation

Unique identification of each employee using the public body’s corporate credentials (directory, staff card, certificate) and several clocking channels: a terminal at the workplace, the web and a mobile app for staff who work off site.
Annual calculation of working time across the different arrangements that coexist within a single workforce: morning, morning-and-afternoon and afternoon schedules, shorter summer hours, reduced hours for work–life balance, and shifts in 24/7 services.
Core hours and flexible hours. The central government resolution sets compulsory attendance from 9:00 to 14:00 and leaves the rest in flexible bands; the system has to know which band each minute falls into in order to calculate balances, not just add up hours.
Balances, time to be made up and the hours bank (bolsa de horas), each with its deadlines: in central government, an absence is made up “during the same week in which the absence occurs or, at the latest, in the following week”, and hours taken from the bank are made up within a maximum of three months.

Exceptions and leave

Accounting for absences through an approval workflow involving the line manager and the HR department, with the supporting document attached.
Integration of leave, holidays, personal days (asuntos particulares) and sick leave into the calculation, so that the balance reflects reality without manual recalculation.

Traceability and security

Time-stamping and a tamper-proof record: any correction leaves a trail showing who made it, when and why. This is what the Inspectorate will ask for in respect of contract staff, and what will be needed in an administrative appeal involving a civil servant.
Retention for the statutory period, backups and access logs in line with the ENS measures for the applicable category.
Reports for trade union representatives and the Inspectorate, exportable and with the information limited to what is necessary.

Integration

With HR management (joiners, leavers, changes of post and of working time arrangement), with payroll for calculating additional payments or deductions and, where the public body requires it, with the e-office (sede electrónica), so that employees can submit requests that are administratively valid.
With the physical access control systems already installed, to avoid duplicating terminals.

How to implement it step by step

Assessment of staff groups and calendars. Draw up an inventory of working time arrangements, sites, shifts, the collective agreements covering contract staff and the agreements covering civil servants. In a provincial council it is common to find more than ten different calendars across central services, works crews, care centres and the fire service.
Decide on the model: off-the-shelf product or custom development. A generic product handles clocking in and out; it rarely handles core and flexible hours, an hours bank with deadlines of its own or integration with the public body’s payroll. Before setting the requirements in the tender specifications, it is worth reading how a generic ERP and custom software differ in the public sector and what to require of the supplier according to its size.
Categorise the system under the ENS and write that into the tender specifications. Category, applicable measures, where the data is hosted, who administers the system and what certification the successful bidder provides. Our guide on how to prepare technical specifications with ENS requirements covers the most common mistakes.
Negotiate with staff representatives. Introducing or changing the time tracking system is a matter for the relevant negotiating body (mesa de negociación). Bringing the design of the reports and the rules on making up time to the negotiating table avoids disputes later.
Pilot at a representative site. Two or three weeks with a unit that has both shifts and flexible hours, checking the system’s balances against those the HR department used to calculate by hand.
Roll-out, training and the end of paper. A cut-over date, a published internal instruction, brief training for each staff group and the withdrawal of the signing-in sheets. The one month that central government gave itself in 2026 to adapt its systems is a good indication that implementation cannot drag on indefinitely.

Common mistakes to avoid

Treating time tracking as an add-on to access control. The turnstile records who comes in; it does not calculate annual working time or manage time to be made up. They are different systems that need to talk to each other.
Setting up a single calendar for the whole workforce. The result is that the balances do not add up and the HR department goes back to the spreadsheet.
Allowing corrections that leave no trail. A record that can be edited without a log is of no use in an inspection or in an appeal.
Forgetting staff who work off site. Inspectors, field technicians, works crews and social services staff need mobile clocking, with or without geolocation as agreed, and the ability to work without coverage and synchronise later.
Hosting the data without categorising the system under the ENS. Time tracking holds personal data on the whole workforce and supports compliance with a legal obligation; it is not a minor system.
Failing to plan for interoperability with payroll. If overtime or reduced hours have to be keyed into the payroll application again, the system has failed in its main purpose.

CEDESA’s experience with public sector organisations

CEDESA has developed resource and staff management platforms for publicly owned operators with large workforces and complex shifts: the resource management platform for the fleet and staff of TITSA, the public bus operator in Tenerife, and staff management and internal organisation at Puertos de les Illes Balears, the Balearic Islands’ port authority. Our time tracking and HR systems include digital clocking with geolocation, shift and roster management, attendance control and communication with the General Treasury of Social Security (Tesorería General de la Seguridad Social), and they are developed under CEDESA’s medium-category ENS certification, together with ISO 27001 and ISO 9001.

We have been working with public authorities and public bodies for more than fifteen years; you can see how we approach these projects on our software for the public sector page.

Frequently asked questions about time tracking in public administration

Are civil servants obliged to clock in?

Yes, where the working time rules of their public authority say so, which is the norm. In central government, the Resolution of 14 April 2026 requires all arrivals and departures to be recorded in the workplace’s time tracking system, and absences and lateness to be logged. Article 34.9 of the Workers’ Statute, by contrast, applies to contract staff.

Can the Labour Inspectorate ask a local council for its working time records?

It can ask for them in respect of the council’s contract staff, who are subject to Article 34.9 of the Workers’ Statute. The Inspectorate has no such power over civil servants, but the record can still be required under the council’s own working time rules and by trade union representatives.

Does the time tracking system have to comply with the ENS?

Yes. Royal Decree 311/2022 applies to the information systems of public authorities and to those of their suppliers when they provide services to the public sector. A system that processes the working time data of the entire workforce must be categorised and must apply the corresponding measures, and the successful bidder must demonstrate its conformity.

Can staff clock in using facial recognition or fingerprints in a public body?

Biometric data is a special category of personal data. Before introducing biometrics, you have to carry out an impact assessment, show that no less intrusive alternative exists and offer an alternative method to anyone who does not want to use it. In most public bodies, a staff card, directory credentials and a mobile app meet the need without that risk.

How long does it take to implement a time tracking system in a public authority?

It depends on the number of calendars, sites and integrations. What sets the pace is not the clocking itself but configuring the working time arrangements and integrating with HR and payroll. Central government gave itself one month in 2026 to adapt existing systems to the 35-hour week; an implementation from scratch calls for the assessment and the pilot to be planned with more leeway.

Conclusion

Digitalising time tracking in public administration means taking working time rules that already exist and carrying them over into an information system, with the security and traceability that the ENS and employment law require. Central government’s 35-hour week and the royal decree on digital working time records that has been announced for the private sector push in the same direction: tamper-proof records, genuine annual calculation of working time and integration with HR management. If your organisation has to adapt or replace its system, CEDESA can help you define and build it; tell us about your project via our contact page.