Key considerations for business in light of the Labour Inspectorate’s Strategic Plan 2025-2027
Understanding the new Strategic Plan of the Labour and Social Security Inspectorate 2025-2027
The recent publication of the Strategic Plan of the Labour and Social Security Inspectorate (ITSS) for 2025–2027 marks the start of a new cycle of inspection activity characterised by digitalisation, large-scale data analysis, and increased specialisation in specific sectors and organisational models.
For businesses, this scenario entails the need to thoroughly review internal processes, but it also represents an opportunity to strengthen regulatory compliance, mitigate risks, and consolidate best practices.
The Plan does not introduce new legal obligations, but it does identify areas in which the Inspectorate will intensify its activity. Based on our experience in inspection proceedings, we outline the main contingencies that may arise and to which the ITSS will pay particular attention under the new Plan.
1. Digital platforms, self-employed collaborators and hybrid models in the Strategic Plan of the Labour Inspectorate
The engagement of self-employed collaborators for the provision of services will remain a central focus of inspection actions. The growing prevalence of mixed model -employees, outsourced services, self-employed contractors, and work through digital platforms- has significantly expanded the scenarios in which indicators of an employment relationship may be identified.
In practice, the Inspectorate will concentrate its analysis on three key aspects:
- Organisational dependence (whether the collaborator is integrated into the company’s structure and operations).
- Use of the client’s resources (computers, tools, vehicles, proprietary software, etc.).
- Lack of operational autonomy (working hours, supervision, detailed instructions).
All of this makes the area a significant risk point for companies combining on-site work, remote work, digital platform services, and external collaborations, scenarios in which the Inspectorate will increase its scrutiny.
2. Temporary contracts, working time and time recording in the Strategic Plan of the Labour Inspectorate
As expected, employment stability and working time regulation are positioned as core themes of upcoming inspection initiatives.
There will be heightened review of time-recording systems, working time distribution, and the proper compensation or payment of overtime. In practice, the most common infringements detected by the ITSS tend to involve:
- Unjustified temporariness (chained temporary contracts or contracts lacking real cause).
- Discrepancies between recorded and actual working hours, including undocumented overtime.
- Irregular use of part-time contracts, especially systematic extensions of hours or non-agreed availability.
- Deficiencies in time-recording systems, whether due to the absence of reliable controls or the use of generic or pre-determined records.
This is a major area of risk, particularly for organisations with variable shifts, seasonal peaks, or high turnover.
3. Remote work and digital disconnection in the Strategic Plan of the Labour Inspectorate
Remote work has a dedicated section in the Plan, confirming an already evident trend. With the widespread adoption of hybrid models, companies are increasingly required to have:
- Up-to-date remote working agreements.
- Appropriate time-recording systems.
- Documentation regarding resources made available to the employee.
- Proper risk-prevention arrangements for the home workplace.
- Effective digital disconnection policies and practices.
The most common contingencies arise from outdated agreements, insufficient adaptation of health and safety measures, or breaches of the right to digital disconnection.
4. Equality, non-discrimination and the effective implementation of mandatory plan according to the Strategic Plan
Equal treatment and non-discrimination remain priorities for the Inspectorate. The Plan reinforces the idea that compliance is measured not only by having documentation in place but by ensuring its effective implementation.
The Inspectorate will focus on:
- Coherent pay registers and pay audits.
- Recruitment and promotion processes aligned with the Equality Plan’s criteria.
- Operational and accessible anti-harassment protocols.
The most frequent shortcomings do not stem from the absence of documents but from their lack of application in day-to-day practice, including Equality or LGTBI Plans that are not actually implemented.
5. Occupational risk prevention in the Strategic Plan of the Labour Inspectorate
Occupational risk prevention continues to be a central pillar. Possessing preventive documentation is not enough: the most common issues arise when it is not updated, adapted, or implemented.
The main deficiencies identified include:
- Generic risk assessments that are not job-specific.
- Lack of traceability in the provision of PPE.
- Failures in the coordination of business activities.
- Outdated health and safety training.
The trend indicates an Inspectorate increasingly demanding coherence between risk, preventive measures, and actual execution.
Conclusion: Preparing for the Labour Inspectorate’s Strategic Plan 2025–2027
In this context, it is essential for businesses to review their labour structure with a comprehensive approach that goes beyond formal compliance.
Experience shows that risks seldom arise from major breaches but from misalignments caused by day-to-day operations, regulatory changes, and organisational evolution.
A preventive review aligned with the Plan allows companies to:
- Anticipate risks,
- Avoid costs and disputes,
- Improve efficiency,
- Strengthen legal certainty,
- And ultimately, invest in stability and competitiveness.
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