What is compulsory, and has been since 2019
Since May 2019 every company has had to record the daily working time of each employee, with a start and an end time. Royal Decree-Law 8/2019 introduced it by amending the Workers' Statute, and it applies to hospitality like any other sector.
The rule does not say how. A signed notebook, a spreadsheet or an app all comply equally, as long as the record is daily, individual, truthful and available to the labour inspectorate.
- Daily: every day worked, not a weekly summary.
- Individual: per employee, not per shift or per venue.
- With a start and an end time for the working day.
- Kept for four years and accessible to the inspectorate.
- Available to employees and their representatives too.
What is NOT compulsory yet, however often you read otherwise
There is a regulation in progress that would require the record to be digital, interoperable and remotely accessible to the inspectorate. It has been widely reported as though it were already in force. It is not.
As at the date of this article, that royal decree has not been published. It went back for revision after the Council of State opinion in March 2026 and its progress was postponed. If approved, it would come into force twenty days after publication, and an adaptation period for smaller firms has been discussed.
The practical consequence: if your paper record meets the 2019 requirements, you are compliant today. What is worth avoiding is buying anything in a hurry because of a date that does not yet exist.
Why it is harder in hospitality than in an office
Time recording was designed with continuous shifts and fixed posts in mind. A restaurant works the other way round: split shifts, cover staff coming in for two hours, people moving between venues within the same group, and high turnover.
Which is why the usual failures are not bad faith but operational: the record gets filled in from memory at the end of the week, or the rota time gets written down instead of the actual one.
- Writing down the scheduled hours instead of the hours actually worked.
- Filling in several days at once at the end of the week.
- Not recording overtime or the close-down overrun.
- Forgetting cover staff and weekend casuals.
- Not keeping the records of people who no longer work for you.
The meal break and the split shift
What has to be recorded is actual working time. If your collective agreement or contract sets unpaid breaks, the record should let you separate them: if you only note a start and an end on a split shift, the total comes out inflated.
On a split shift the clean approach is recording the two stretches separately. It is more work and it heads off the argument that appears when somebody claims hours.
What to look at before buying a system
If you are going to put one in, four questions save trouble. And if you already have one working on paper, the first question is whether you really need to change it now.
- Does it keep records for four years and let me export them if I change supplier?
- Can an employee see their own record?
- Does it let me separate stretches within the same day, for split shifts?
- What happens when somebody forgets to clock: can it be corrected, and does the correction leave a trace?
Frequently asked questions
Is there anything like this in the UK?
Not equivalent. The UK has working time limits and record-keeping tied to them, but no general duty to log a start and end time for every employee every day. If you are coming from there, this is a genuinely new obligation rather than a stricter version of one you already know.
Does the record have to be digital?
Not today. What has been compulsory since 2019 is recording working time; the rule does not impose the medium. The regulation that would require a digital record remains unpublished.
Does a signed paper sheet count?
Yes, as long as it is daily, individual, reflects real start and end times, is kept for four years and is available to the inspectorate and to employees.
How long do records have to be kept?
Four years, including those of people who no longer work for you. It is one of the most frequent oversights in venues with high turnover.
Do I have to record weekend casuals?
Yes. The obligation is per employee and per day worked, with no minimum hours and no minimum contract length.
Does Ordeli work as a time recording system?
It records the data the rule asks for: an individual shift, with a start and an end time, opened and closed by the employee themselves. Two caveats against the list above: today the history is consulted by the admin and the manager, and closing the till closes any shifts left open.
What if the rule changes in September?
If the regulation is approved, it would come into force twenty days after publication and an adaptation period for smaller firms has been discussed. We will revise this article when it happens.