Payslips
Article 29.1 of the Spanish Workers' Statute requires an individual receipt evidencing payment of wages. The Supreme Court accepted electronic delivery in its judgment of 1 December 2016.
What is required is that the worker can access and keep the document, not that they sign it. A read receipt documents the delivery.
Contracts and amendments
Employment contracts and their amendments are routinely signed electronically. An advanced or qualified level is advisable, as this is the paperwork most often disputed.
Data protection
A signature that uses biometric data falls under article 9 of the GDPR. The Spanish Data Protection Agency's November 2023 guidance clearly restricted its use in the workplace.
A handwritten signature captured on a tablet with pressure and speed data is biometric processing. A certificate-based signature is not.
What an auditor usually asks for
- Read receipt on payslip delivery
- Advanced or qualified level on contracts and amendments
- Permanent worker access to their own paperwork
- A review of whether any signing method involves biometric data
How employment paperwork is signed in Kimobox
- 1Publish the paperwork in the employee portal with a read receipt.
- 2Request a signature only on documents that genuinely need one.
- 3Leave the history accessible to the worker without them having to ask.
Delivering and signing are not the same: asking for a signature where a receipt suffices adds friction without adding assurance.
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- Regulation (EU) 910/2014 (eIDAS) on electronic identification and trust services EUR-Lex · 23/07/2014
- Regulation (EU) 2024/1183, European digital identity framework (eIDAS 2) EUR-Lex · 11/04/2024
- Spanish Law 6/2020 on certain aspects of electronic trust services BOE-A-2020-14046 · 12/11/2020