Working time records for autónomos with employees: the 2026 guide

Published on 15 March 2026

If you are an autónomo with people on the payroll, time tracking affects you, though perhaps not in the way you think. We settle once and for all who has to clock in, what the law requires and how to comply without it eating your time.

Do I have to clock in as an autónomo?

No. Article 34.9 of the Estatuto de los Trabajadores places the obligation on the company in respect of its employees, and you, as the owner of the business, are not one. The Ministry of Labour's Guía sobre el registro de jornada says so without hedging: as regards work excluded from the scope of the Statute, «como socios trabajadores de cooperativas, trabajadores autónomos, etc., no se aplicará el artículo 34.9 ET y, por tanto, no existirá obligación de registro horario» — such as worker members of cooperatives, self-employed workers and so on, article 34.9 ET will not apply and there will therefore be no obligation to keep a time record.

That said, the complete answer has four nuances worth looking at before treating it as settled:

• If you are also an employee at another company (pluriactividad), at that company your working hours are recorded. As an autónomo no, as an employee yes.
• If you are an economically dependent self-employed worker (TRADE), your working hours are governed by article 14 of Ley 20/2007, the Estatuto del Trabajo Autónomo, and by your contract, not by article 34.9. Your client does not have to record your hours, and if they did so in the detail of an employee they would be feeding an indication of an employment relationship.
• If you are a haulier, you do have obligations to record time, but by another route: the tachograph, which covers self-employed drivers too. It is a separate set of rules with penalties of its own.
• If the «autónomo» is not really one, the exemption falls away entirely. If the Inspectorate reclassifies the relationship as employment, it is not only the record-keeping obligation that appears: everything else appears too.

And the mirror case: the members and directors of a company who have an ordinary employment relationship do fall within the record. The only ones left out are senior management staff under article 2.1.a) of the Workers' Statute, which is one specific special employment relationship, not «whoever is in charge».

And my employees?

Yes, emphatically. From the first worker you take on, you are required to record their daily hours (in and out) and to keep those records for 4 years. It does not matter whether you have one or ten: the time tracking law applies just the same.

If you take someone on part-time, take care: they have a separate and more demanding regime, that of article 12.4.c). You have to total the hours monthly and give them a copy of the summary with their payslip. If you do not, the contract is presumed to be full-time, with everything that means for wages and contributions.

What you have to record for your employees

• The time in and out for every employee, every day.
• Reliably and impossible to manipulate after the fact. You choose the medium: the law accepts paper or digital.
• Available to the worker, to their legal representatives and to the Inspectorate.
• And organised according to what your collective agreement or a company agreement says; if they say nothing and there is legal representation of the workers, you have to consult it first.

How to comply as an autónomo, without complicating things

You do not need an HR department or expensive software. A simple app where your employees clock in from their phones is enough for you to comply and forget about it. You set it up in an afternoon (we explain it in how to roll out time tracking).

And what is more, you can do it without spending anything

Complying with article 34.9 does not cost money as a matter of legal obligation: with a signature book or a well-kept spreadsheet, you comply. What you buy when you pay for a tool is convenience and evidence, not legality. We go over the free options, and their real risks, in free time tracking.