The Supreme Court reinforces transparency in salary receipts

In its ruling on 24 March 2026, the Supreme Court dismissed the appeal filed by the Renfe Group and fully confirmed the ruling of the National High Court, which had ordered the company to improve the clarity and breakdown of the salary receipts issued to its staff. The controversy arises from a collective labour dispute presented by the ALFERRO union, which alleged that, although the payslips included the various salary components, they did not allow employees to correctly understand how they were calculated or verify the accuracy of the amounts paid. The National Court upheld the claim and ruled that the company was obliged to clarify and break down variable salary components, arrears, and other payments, specifying the dates they refer to and the actual days paid, as well as ensuring the proper separation and transparency of payments.

In response to this ruling, Renfe filed an appeal on legal grounds, alleging, among other issues, a violation of Article 29.1 of the Workers' Statute (ET) and the regulations governing the official template for the payslip. The Supreme Court focuses the debate on the interpretation of Article 29.1 of the Workers' Statute, pointing out that the employer's obligation is not limited to providing a payslip that formally lists the remuneration concepts, but requires that this document allows for a real and effective understanding of the salary.

In this regard, the Chamber considered that the payslip model used by the company, although detailed concerning the concepts, had significant deficiencies from the standpoint of clarity, particularly:

• The accrual periods for certain concepts were not adequately indicated, especially in the case of arrears.
• It was not specified whether the amounts corresponded to full or partial payments, depending on circumstances such as temporary incapacity, strikes, or contract suspensions.
• In the case of supplements linked to units of time (days or hours), these units were not specified, and the payslip only indicated the amount.

In the Court's view, these omissions prevent the worker from knowing the basis for the salary calculation (time, percentages, or criteria applied) and hinder the verification of the accuracy of the payment made. The ruling emphasizes that the clarity requirement is an essential element of the payslip and cannot be considered fulfilled when it forces the worker to perform complex mathematical operations or reconstruct information that the company has not provided.

In this sense, it expressly rejects the notion that the burden of verifying and checking the necessary data to verify their salary can be transferred to the worker and emphasizes that this violates the principle of transparency that should govern the employment relationship. Furthermore, the Court rejects the company's argument regarding an alleged violation of the principle of equality in demanding a higher standard from Renfe than from other companies, considering that this is not about imposing additional requirements but correctly applying the legal requirements according to the circumstances of the case.

Moreover, the Chamber specifies that there was no valid agreement with the workers' representatives allowing a deviation from the official payslip template, as the employer's participation in the mixed committee was limited to a mere explanation of the template, without any record of its formal approval.

Consequently, the Supreme Court concludes that the ruling of the lower court is lawful and confirms the employer's obligation to include in salary receipts all necessary information so that the worker can directly and easily ascertain and verify the origin, calculation, and amount of each salary payment. The ruling dismisses the appeal, affirms the decision of the National Court, and orders the forfeiture of the deposit posted for the appeal, without imposing costs.

Article from the Department of Labour Law of ECIJA Madrid.