The Judicial Council in Spain, El Consejo General del Poder Judicial, developed formulas for the average time required to handle different types of proceedings. These “Módulos” are workload benchmarks and form the basis of the Consejo’s efforts to measure and assess judicial productivity. In 2003, a law was introduced setting judicial salaries as a combination of fixed and variable factors; the variable quotient was linked to productivity measures. The Supreme Court of Spain ruled this law violated judicial independence. A new system was introduced in 2008 authorizing a bonus to judges who reached certain productivity goals. This law also was successfully challenged: the judges’ association argued that such metrics are not an accurate reflection of the quality of a judge’s work.