Are electronic pay statements valid?

Since 2011, the Spanish Supreme Court’s position, reflected in the judgment handed down on December 22 that year, has been to hold that salary receipts, i.e. pay statements, should be delivered on paper. The court’s view was that this transpires from article 29.1 of the Workers’ Statute (“Salary documentation shall be provided by delivering an individual receipt to the employee which justifies payment of same”) and also from the Ministerial Order of December 27, 1994, which requires that employees be given a duplicate of the receipt.