Spain: from paper records to digital clock-in
Since Royal Decree-Law 8/2019 (article 34.9 of the Workers' Statute), all companies must record each worker's daily working time. Until now, doing so on paper or in a spreadsheet was accepted.
The 2025-2026 reform eliminates paper: the record must be digital, objective and remotely accessible to the Labour Inspectorate, and sets the maximum working week at 37.5 hours without a pay cut.
Germany: mandatory recording by court ruling
The German Working Hours Act (Arbeitszeitgesetz) limits the working day to 8 hours. Following the 2019 Court of Justice of the EU ruling and the Federal Labour Court ruling, recording working time is mandatory.
The law implementing that recording is in the pipeline, but the obligation already exists de facto for companies with staff in Germany.
France and Portugal: recording required by law
France requires working time tracking (décompte du temps de travail) with a 35-hour week, and penalises those who fail to document it.
Portugal requires working hours to be recorded under the Código do Trabalho and those records to be kept available to the inspectorate. It is one of the most detailed systems in the EU.
Italy and Dubai: a more relaxed approach
Italy does not impose general daily clock-in: collective agreements and overtime recording take precedence. The obligation to document depends on the sector and company size.
In Dubai there is no obligation to clock in working time. The WPS (Wage Protection System) checks that wages are paid on time and by bank transfer, but not hours worked.
What it means for your subsidiary
If you operate in several countries, each requires its own record and its own format. A single system rarely works for all, and penalties for failing to record are expensive.
The practical approach is to rely on local advisers who handle the registration in line with each country's rules, with the documentary evidence required by each inspection.
