Time tracking and remote work: how to record working hours off site

Published on 16 June 2026

Remote work does not exempt you from working time records: the law requires them just as it does in the office. The good news is that doing it properly remotely is easy and does not mean monitoring anyone. We explain how to keep time tracking for remote work in line with the law while respecting privacy.

Is time tracking compulsory for remote work?

Yes. The working time records law applies to all employees, wherever they work: the Ministry of Labour's guide says so expressly for people working remotely. Ley 10/2021 on remote work reinforces it in its article 14.

With one nuance worth knowing: Ley 10/2021 only applies to regular remote work, which its article 1 defines as work performed, over a reference period of three months, for a minimum of 30% of the working time. If your team works remotely for one odd day, that law does not come in, but the obligation to record working hours remains intact, because it comes from article 34.9 of the Workers' Statute, which draws no distinction.

How to record working hours remotely

The employee clocks in from their phone or computer when starting and finishing. Article 14 of Ley 10/2021 requires the system to «refleje fielmente el tiempo que la persona trabajadora dedica a la actividad laboral, sin perjuicio de la flexibilidad horaria» — faithfully reflect the time the worker spends on work activity, without prejudice to flexible hours — and to include «el momento de inicio y finalización de la jornada», the moment the working day starts and finishes. Marking that they are in remote-work mode is not required by law, but it helps to distinguish periods and to evidence the agreed on-site share.

Before any clocking in there is a compulsory piece of paper: the written remote work agreement (article 7). Its minimum content includes, among other things, the working hours and, within them, the availability rules, the percentage and distribution between on-site and remote work, and the employer's means of monitoring the activity. If you are going to clock in with a tool, that is where it has to be set down.

Privacy: what you may NOT do

Recording working hours does not make you the supervisor of anybody's living room. Article 22 of Ley 10/2021 does allow the company to «adoptar las medidas que estime más oportunas de vigilancia y control» — take whatever surveillance and monitoring measures it considers most appropriate — including electronic ones, but with two limits that are not decorative: «guardando la consideración debida a su dignidad», with due regard for the worker's dignity, and respecting article 20 bis of the Workers' Statute, which refers to Ley Orgánica 3/2018 on data protection.

In practice that rules out what people usually ask about: continuous screenshots, keystroke logging or a webcam left on are disproportionate measures for checking someone's hours, because there is a far less intrusive way of doing it — having the person clock in. And whatever you do has to be declared in the remote work agreement and communicated in writing. We go into it in clocking in and privacy.

One point that often gets forgotten: if clocking in is done from the worker's personal phone, in remote work that runs up against articles 11 and 12 of Ley 10/2021, which require the company to provide the means and to cover the costs. It is best to agree it or to offer an alternative from the work computer.

What the remote work law says

Ley 10/2021 devotes two articles to this:

• Article 14, «derecho al registro horario adecuado» (the right to an adequate time record): the system in article 34.9 of the Workers' Statute must faithfully reflect the time spent on work activity, with the start and the end of the working day, and always «de conformidad con lo establecido en la negociación colectiva» — in accordance with what is established in collective bargaining.
• Article 18, «derecho a la desconexión digital» (the right to digital disconnection): it refers to article 88 of Ley Orgánica 3/2018. It is not just «do not ring at night»: the employer's duty entails «una limitación del uso de los medios tecnológicos de comunicación empresarial y de trabajo durante los periodos de descanso» — a limitation on the use of company communication and work technology during rest periods. And it requires something concrete that almost nobody has done: drawing up an internal disconnection policy, after hearing the workers' legal representatives, covering people in management posts too.

A good record helps precisely to mark out those hours, because it puts in writing where the working day ends.

How to set it up without intruding on anyone's privacy

The short recipe: put the hours and the availability rules in the remote work agreement, declare the clocking-in system there as a means of monitoring, record only the start and the end (and breaks, if there are any), capture nothing else, and have your disconnection policy in writing. With that you comply with article 34.9, and with articles 14 and 18 of Ley 10/2021, and you touch nobody's privacy.