Hiring seasonal staff for a small hotel: which contract to use and how to record working hours (2026)

Updated: 10 November 2026

You open in spring, close in autumn and need reception, housekeeping and breakfast staff for just a few months. We read the Spanish labour reform in the BOE, the time-recording rule, the draft digital-recording decree, the Portuguese Labour Code, the Italian Labour Ministry pages and the Greek circular on the digital work card (links at the end). Where we could not confirm something, we say so. This is not legal advice: check it with your payroll adviser.

Spain: for the season, a 'fijo discontinuo' contract

After the labour reform (Royal Decree-law 32/2021, BOE-A-2021-21788), art. 16 of the Workers' Statute:

It is the contract for seasonal work or work tied to seasonal activity: the typical case of a hotel open a few months a year.
It must be in writing.
It does not end with the season: the person comes back when you call them the next year.
Seniority counts the whole length of the employment relationship, not only the months worked.

Spain: the call-back

Art. 16.3 of the Statute:

The call-back criteria are set by the collective agreement or, failing that, a company agreement.
The call must be in writing or by another means that leaves a record (email, a message you can keep), with reasonable notice.
At the start of each year the employer gives the workers' representatives, if any, a calendar of expected call-backs.
Check the hospitality collective agreement for your province: it usually sets the order and notice of call-backs.

Spain: a temporary contract is not for the whole season

Art. 15 of the Statute, also after the reform:

A fixed-term contract is only allowed for production circumstances or to replace someone.
For production circumstances: six months at most, extendable to one year by a sector agreement. Staff holiday peaks count.
For short, occasional and foreseeable peaks (a long weekend, an event): ninety days a year at most, not in a row.
Hire in breach of these rules and the worker becomes permanent. The same if you have not registered them with Social Security after a period equal to the probation period.

Spain: fines for the wrong contract

The same reform changed the Spanish law on labour offences and penalties (LISOS):

Misusing temporary contracts is a serious offence, counted once for each worker affected.
Fine for each one: 1,000 to 10,000 EUR depending on the grade (art. 40.1 c bis LISOS).
Three waiters on the wrong contract means three offences.

Spain: time recording is mandatory

Art. 34.9 of the Statute (since Royal Decree-law 8/2019):

The employer must keep a daily record of each worker's hours, including seasonal and temporary staff.
It must show the exact start and finish time of the working day.
Records are kept four years and made available to workers, their representatives and the Labour Inspectorate.
We could not read the fine for not keeping records in the current LISOS text, so we give no figure.

Spain: digital time recording is still a draft

The Labour Ministry is preparing a draft Royal Decree on time recording:

It would require an objective, reliable and accessible system, with minimum content, technical requirements and Inspectorate access.
According to the draft, it would enter into force twenty days after publication in the BOE.
As of 10 November 2026 we found no sign that it has been approved or published in the BOE. What applies today is the daily record of art. 34.9, in whatever format you use.
If you choose a clock-in system now, pick a digital one that cannot be edited without a trace and lets you export the data.

Portugal: fixed-term contracts and time records

Labour Code (unofficial copy updated with Law 13/2023):

Seasonal activity justifies a fixed-term contract ('contrato a termo', art. 140, no. 2 e). It must be in writing and state the term and its reason (art. 141).
Very short contract of up to 35 days in seasonal tourism or farming: no written form, but it must be notified electronically to Social Security; 70 working days a year at most with the same employer (art. 142).
Maximum length: two years for a fixed end date, four for an open end date (art. 148).
Time records (art. 202): start and finish times and breaks, kept in an accessible place for five years. Not keeping them is a serious offence.

Italy: seasonal contract and the 'Libro unico'

Italian Labour Ministry and Circular no. 6 of 27-3-2025:

The fixed term must be in writing (except jobs of up to 12 days).
Seasonal contracts can be renewed or extended without the justifications required for other fixed-term contracts.
According to the 2025 circular, seasonal contracts have no maximum length or limit on renewals, although each renewal needs objective reasons. Which activities are seasonal is set by Presidential Decree 1525/1963 and collective agreements.
A seasonal worker has priority for new seasonal hires for the same activities.
The 'Libro unico del lavoro' (Decree-law 112/2008, art. 39) includes an attendance calendar with the hours each employee worked each day. Check current deadlines and fines with your labour consultant.

Greece: digital work card in accommodation

Labour Ministry circular 3496/10-02-2025 (Ministerial Decision 44485/2024, Government Gazette B' 5151/11-09-2024):

Since 11 September 2024 the digital work card is mandatory if your main activity code (KAD) is accommodation or food service.
It covers all staff working on site, seasonal staff included.
Each clock-in and clock-out is recorded in the ERGANI II system, with a delay of 15 minutes at most; together with the declared digital work schedule it sets the actual hours.
Penalties apply since 1 March 2025; the circular gives no amount. Up to 3 single missed punches per worker per month count as a warning.
The exact KAD codes and Greece's own rules for seasonal contracts are not confirmed in an official source: ask your accountant.

Before the season opens

Pick the right contract: in Spain, 'fijo discontinuo' for the season; a temporary contract only for peaks.
Sign in writing and keep proof of each call-back.
Register each person with Social Security on time: in Spain a temporary worker not registered after the probation period becomes permanent.
Start recording hours from day one (in Greece, the digital card).
Read the hospitality collective agreement for your province (or the one that applies in your country): it sets pay, job grades and call-back rules.

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Frequently asked questions

Which contract do I give someone who only works summers at my hotel?

In Spain, 'fijo discontinuo' (art. 16 of the Workers' Statute): in writing, with a recorded call-back each season. Temporary contracts are for specific peaks of up to six months, or ninety days a year for foreseeable occasions.

Is digital clock-in mandatory?

In Spain, as of 10 November 2026, the digital time-recording decree has not been published in the BOE: it is a draft. What is mandatory is a daily record of start and finish times, kept four years. In Greece, the digital work card is mandatory in accommodation since September 2024.

What is the fine for hiring a seasonal worker on the wrong contract?

In Spain, 1,000 to 10,000 EUR for each worker affected, and the worker becomes permanent.

Sources

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