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The 20 mandatory annual training hours per employee: what Spanish law requires and how to meet it without overloading HR
Beñat Arrizabalaga
Co-founder & Business Development
Digitization
The 20 mandatory annual training hours per employee: what Spanish law requires and how to meet it without overloading HR
The 20 annual training hours are not your company's only training obligation — they are the most visible one. Without a clear system to manage them alongside PRL, sector agreements, and FUNDAE, complying with the law takes more time than it should.
If you have 300 employees, you have 6,000 training hours a year to coordinate. If you have 500, that's 10,000. And that's just the hours from Article 23 of the Workers' Statute. We haven't counted occupational risk prevention (PRL), equality training, adaptation to technological changes, or what your sector agreement requires on top of that.
The problem isn't that the obligation is impossible to meet. It's that most HR teams face it without a system, confusing which obligation requires what and who is responsible for paying it. The result: management hours pile up, legal risk grows, and training doesn't reach where it needs to go.
In this article we break down exactly what the law requires, how the different training obligations differ from each other, what it actually costs to comply, and how to structure a plan that works for an operational workforce.
Article 23 of the Workers' Statute establishes workers' right to company-related training. The clause that generates the most questions in HR is section 3: the paid training leave of 20 annual hours.
These are the conditions set by law:¹
That last point is where most companies stumble. A workforce of 400 people with no structured training plan and no governing agreement can generate 400 individual negotiations per year. This isn't a hypothetical scenario — it's what happens in many mid-sized companies that haven't made this a priority.
Here is the most frequent mistake: treating the 20 hours from Article 23 as if they were the company's only training obligation. They are not. They are just one layer of a Training Compliance Matrix that includes several obligations with different legal bases, different responsible parties, and different management timelines.
The table below summarises the main ones:
| Type of obligation | Legal basis | Responsible | Does it consume the 20 hours from Art. 23? |
|---|---|---|---|
| Individual training leave (20h/year) | Art. 23.3 Workers' Statute | Company satisfies through own plan, or employee requests externally | Yes |
| Occupational risk prevention training (PRL) | Law 31/1995, Art. 19 | Company — mandatory and at its cost | No |
| Training for technological or role changes | Art. 23 Workers' Statute | Company — mandatory and at its cost | No |
| Equality and diversity training | Organic Law 3/2007 | Company (mandatory with 50+ employees) | No |
| Sector-specific training (construction, hospitality…) | Sector collective agreements | Varies by agreement | Varies |
The distinction that matters most: PRL training, adaptation to role changes, and equality training are company obligations, not employee rights. The company organises and funds them, they take place during working hours, and they do not under any circumstances reduce the 20 annual hours to which the employee is entitled under Article 23.3.²
This means that in a mid-sized company with a demanding sector agreement, the total volume of mandatory training can be three or four times the ET's 20 hours. An operator in the food industry may need HACCP training, PRL specific to their role, procedure updates, and their Article 23 entitlement — all in the same year.
There are two costs that HR tends to track separately but should view together: the salary cost of training time and the cost of managing the process.
The salary cost is straightforward: if the average working hour in your workforce is worth 15 euros gross, each employee entitled to Article 23 leave represents 300 euros of paid time allocated to training. With 300 employees, that's 90,000 euros. It's not an extraordinary expense — it's a structural one that should be in the training budget from the first quarter.
The management cost is the most underestimated. Planning the calendar, notifying team managers, recording attendance, issuing certificates, and maintaining evidence for a potential inspection requires between two and three hours of administrative work per employee per year. With 300 employees, that's between 600 and 900 department hours — the equivalent of half a year of work for one person dedicated solely to managing training paperwork.
Without a system, that time is absorbed by the HR team between other tasks. The fact that it's invisible doesn't mean it doesn't exist.
The FUNDAE credit as a partial lever
What can partially offset the cost of training content is the subsidised training credit. Every company contributes 0.70% of its monthly payroll to Social Security under the heading of vocational training. That accumulated amount is the FUNDAE credit you can apply to fund training activities.³
The credit does not cover the salary cost of training time, but it does cover the cost of the content (provider, platform, materials). If it is not used before 31 December, it returns to the State. For companies with more than 250 employees, the mandatory co-financing requirement is 40% of the total training cost. The rest is covered by the credit.
The most common scenario in companies without a structured plan: the credit expires unused.
Managing training person by person does not scale. The first step is to group the workforce by segments with similar training obligations: production operators, warehouse staff, technical profiles, office-based employees.
For each group, identify which training is mandatory (PRL, sector-specific, equality), which training can be included in the company's own plan to satisfy Article 23, and which training is potentially eligible for FUNDAE bonification. The result is an obligation map by group that converts 400 individual situations into four or five manageable blocks.
If the company develops its own training activities and registers them correctly with FUNDAE, those activities satisfy the Article 23.3 ET right. This means that training the company plans and delivers to its employees can simultaneously fulfil two functions: satisfying the employee's training leave and being eligible for bonification.
The conditions are that the training be linked to the company's activity, that the employee have at least one year of seniority, and that the activity be communicated and registered correctly on the FUNDAE platform before the training begins. The process has specific steps and deadlines, but it is standard and can be automated.
The biggest bottleneck in companies with an operational workforce is not willingness to train — it's logistics. Pulling an operator off the production line for a two-hour in-person session has a cost that goes beyond salary: it affects production pace, forces shift reorganisation, and creates resistance from team managers.
Short-form video training, delivered asynchronously and accessible from any device, resolves this problem. A 12-minute module that an operator completes during a shift changeover or a planned break is easier to integrate operationally and easier to record than an in-person session. The knowledge infrastructure platform from Vidext makes it possible to produce and update that kind of content without an audiovisual team, and to automatically generate the consumption traceability you need for an inspection.
The format is not an aesthetic preference. It is an operational decision that directly affects how much the plan costs to run.
Non-compliance with PRL training obligations can lead to administrative penalties. But beyond financial sanctions, the company must be able to demonstrate, in the event of an accident or inspection, that the employee received the required training and that there is evidence of it.
This is not bureaucracy — it is risk management. A system of evidence-based training traceability resolves this systematically: who completed which module, when, from which device, and with what result. That record is what separates a company that complies from a company that can prove it.
If your company runs rotating shifts, plant-floor operations, or high turnover, you have three additional layers of complexity that a generic training plan does not address.
Availability is fragmented. You cannot schedule a training session on a Wednesday at 10am if half the workforce is on the night shift. The plan has to be designed so that training reaches employees when they are available, not the other way around.
The volume of new hires is constant. In high-turnover sectors, initial PRL and process training is repeated continuously. Without a system that allows that training to scale without multiplying HR workload, the department's operational burden grows in proportion to turnover.
Certification is ongoing. Certain roles in industry, logistics, and food processing require periodic renewal of certifications. Tracking that calendar manually, with workforces that rotate and change roles, is a constant source of errors and coverage gaps.
The solution is not to hire more HR staff. It is to scale compliance training with systems that handle planning, recording, and traceability without depending on manual intervention at each step.
The training obligation under Article 23 of the Workers' Statute is also, when well managed, a retention and development tool. A company that offers useful, accessible training linked to the role has a concrete argument for teams that value professional growth.
The problem is that most companies experience it as a formality because they manage it like one — late, without a system, and without integration with the rest of their training obligations.
Building your company's Training Compliance Matrix, integrating it with FUNDAE, and adopting formats that reach operational staff without stopping production is not a six-month project. It is a process that, with the right tools, can be structured in weeks.
If you want to see how it works in a company with an operational workforce, you can request a Vidext demo and see the full flow from content creation to traceability records.
Not to all of them. The right to 20 annual hours under Article 23.3 of the Workers' Statute applies to employees with at least one year of seniority at the company. Newly joined employees are not entitled to this leave until they reach that minimum threshold.
If the company fails to facilitate the training leave, the employee can file a claim. In the absence of a collective agreement regulating it, company and employee must reach an individual arrangement. Without agreement, it can escalate to a labour dispute. Non-compliance with PRL training obligations can also carry administrative and criminal consequences.
No. Occupational risk prevention (PRL) training is a separate company obligation regulated by Law 31/1995. The company organises and funds it, and the time spent counts as effective working time. It does not reduce or consume the 20 hours granted under Article 23.3 of the Workers' Statute.
Yes, as long as the training is linked to the company's activity. If the company has its own training plan that meets this criterion, employees can participate in it to satisfy their right. If an employee requests external training that does not fit the company's plan, it is negotiated individually or governed by the collective agreement.
Hours not taken can be accumulated for a maximum of five consecutive years. This means an employee can build up to 100 hours and use them in a concentrated block — for example, to complete a more extensive training programme. The collective agreement may regulate the specific terms of this accumulation.
FUNDAE can fund the cost of training content, not the salary cost of the time the employee spends training. The FUNDAE credit covers spending on providers, platforms, or materials, provided the training activity is correctly registered before it begins. The employee's salary during training hours is always borne by the company.
¹ Article 23 of the Workers' Statute - Iberley
² Mandatory training in companies: legal framework in Spain - Femxa
³ Complete FUNDAE guide 2026: how to subsidise company training - Cursossepeyfundae
⁴ 20 annual mandatory training hours for workers - Consultae
@ 2026 Vidext Inc.
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