Spain’s move towards digital transport documentation is now just weeks away. From 5 October 2026, DeCA documents for applicable road freight operations must be managed digitally.
In this second article in our Legal Focus series, Shippeo’s Legal team breaks down what Spain’s latest DeCA Resolution means in practice for shippers, carriers and freight forwarders, and what steps they should be taking now.
Spain has now defined the technical requirements for DeCA
Spain’s move to digital DeCA has developed in the following stages.
First, the Sustainable Mobility Law1 , published and entered into force in December 2025, introduced the obligation for the administrative control document for public road freight transport - the DeCA - to become digital as of 5 October 2026.
Then, in January 2026, the Road Transport Inspection Plan announced that the existing DeCA framework would be revised during the year to introduce new technical requirements supporting the digitalization obligation, provide greater legal certainty during inspections, and align the Spanish regime with the eFTI Regulation.2 3
That revision was implemented in June 2026, through the publication of the Spanish Resolution of 5 June4, defining the technical requirements that digital DeCA applications and documents must meet.5 Importantly, it does not change the underlying rules governing when a DeCA is required or which parties are responsible for it. Instead, it sets out how the existing administrative obligation must operate in a digital environment.
From 5 October, DeCA documents must therefore be generated and managed digitally through a compliant solution, whether developed internally or provided by a third party.
DeCA and eCMR
DeCA and eCMR both form part of the wider move towards digital transport documentation, but they serve different legal purposes.
The DeCA is an administrative control document used in interactions with Spanish authorities.
The eCMR is the electronic version of the CMR consignment note and primarily governs the contractual relationship between transport parties.
That does not mean organisations need completely separate digital workflows. Where the relevant requirements are met, transport documentation processes can potentially be connected or consolidated.
The technical requirements in detail
The June Resolution sets out specific requirements for how DeCA documents must be generated, accessed and retained, as well as the characteristics they must meet.
Key requirements, as clarified by the new Resolution6 include:
- DeCA documents must be natively digital. Electronic files obtained from scanning paper documents are not valid. Creation shall precede the actual start of the service.
- Traceability of file metadata: creation time and date, as well as any update of data during the transport; all metadata must be recorded.
- Storage in a repository ensuring availability of DeCA documents for download during inspections.
- A mandatory retention period of 1 year for DeCA documents is applicable to transport operators (shippers, carriers, transport companies).
- A unique and specific web address (URL) for each DeCA document, complying with characteristics explicitly defined in the June Resolution, including direct download (no credentials or authentication allowed).
- The DeCA must include a QR code linking directly to the stored document URL. Drivers can present the QR code alone, as an independent file.
- Signature is not mandatory for DeCA to be valid, but if the DeCA is used also for contractual purposes by the operators, the requirements of the advanced electronic signature according to eIDAS Regulation7 apply as a minimum.
- Domain URL registration within the Spanish authorities no longer applies. Prior to the publication of the June Resolution, Shippeo had already completed this requirement and is therefore known as a DeCA service provider by the Spanish Ministry of Transport and Sustainable Mobility.
Scope of application of the digital DeCA obligation
DeCA documents are mandatory for domestic transport and cabotage operations carried out within Spanish territory8. International transport operations that only partially run through Spain - with origin and destination outside the country - are outside the scope of this obligation.
Example: A German or French haulier carrying out a domestic load entirely within Spain must comply with the DeCA rules in the same way as a Spanish carrier.
Who is responsible for DeCA?
The new Spanish legislation requiring the DeCA to be electronic does not amend Order FOM/2861/2012 of 13 December9, which continues to govern the general DeCA framework. Consequently, existing rules on liability remain unchanged: the contractual shipper10 and the actual carrier11 both have obligations relating to the DeCA and may therefore be held liable for non-compliance. This can include:
(i) Failure to issue the DeCA
(ii) Failure to carry the DeCA on board during transport. The shipper can, however, be exonerated from liability in this case if it proves the document was duly issued.
(iii) Incorrect or missing data.
Responsibility depends on the information concerned: in short, each party is liable for the data it controls12. This makes DeCA compliance relevant not only for carriers, but also for shippers – particularly where transport involves subcontracting or more complex operating models.
No additional transition period after 5 October
The Spanish Ministry of Transport has clarified that no further transition period after 5 October 2026 during which the digitalisation obligation would not be subject to sanctions will apply.13
Operators within scope must be ready to issue and carry compliant DeCA documents from October 5th 2026.
Applicable fines are defined in the Spanish Sanctioning Schedule, starting at 400 EUR per infringement14. A single inspection may identify more than one compliance failure and could therefore result in several separate infringements.
Shippeo is in close contact with the Spanish Ministry of Transport, which has confirmed that an update to the Sanctioning Schedule is expected in early September 2026. Shippeo’s Legal team will provide a further update in this Legal Focus series when the revised Schedule is published.
Practical considerations for shippers and carriers
With the deadline approaching, organizations operating road transport in Spain should move beyond assessing whether the regulation applies and start validating their operational readiness.
Key steps can include:
- Map your Spanish transport flows
- Identify which movements qualify as domestic public road freight transport, including cabotage
- Confirm who is the contractual shipper and actual carrier for each relevant transport model, in accordance with applicable definitions
- Analyze subcontracting models15
- Verify that your DeCA solution meets the technical requirements defined in the Resolution of 5 June 2026
- Ensure drivers carry a copy of the required document/QR code on board before transport starts
- Confirm how DeCA documents will be retained and retrieved in the event of an inspection
The challenge is not simply producing a digital document. Organizations need a reliable process for creating it at the right point in the transport workflow, sharing it between relevant parties, keeping it accessible to drivers, and retaining the necessary evidence afterwards.
How Shippeo is supporting DeCA readiness
Shippeo has been closely following the evolution of Spain’s digital transport documentation framework and has been engaging directly with the Spanish Ministry of Transport and Sustainable Mobility. Shippeo’s DeCA capabilities have been designed to support the requirements defined in the June Resolution and to help shippers and carriers manage compliant digital transport documentation as part of their broader transport operations.
What’s next?
Spain may become an important reference point for other European countries as digital freight requirements continue to develop alongside eFTI. Shippeo’s Legal team will continue to monitor regulatory changes and share updates as the legal framework evolves.
Disclaimer: This article is intended for general informational purposes only and does not constitute legal advice or tailored legal counsel. Shippeo accepts no liability arising from or in connection with its content.
- https://www.boe.es/buscar/act.php?id=BOE-A-2025-24545
- https://eur-lex.europa.eu/eli/reg/2020/1056/oj/eng
- https://www.transportes.gob.es/recursos_mfom/20260129_sgitcyf_planinspeccioncarretera2026.pdf
- https://www.boe.es/buscar/doc.php?id=BOE-A-2026-12784
- The June Resolution replaces the previous Resolution of of May 22 2023: https://www.boe.es/eli/es/res/2023/05/22/(4)
- https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-12784.
- https://eur-lex.europa.eu/eli/reg/2014/910/oj/eng
- https://www.boe.es/buscar/act.php?id=BOE-A-1987-17803, art. 65.2.
- https://www.boe.es/buscar/doc.php?id=BOE-A-2013-154
- The contractual shipper is the natural or legal person who directly contracts with the actual carrier for the transportation of the shipment, whether as the actual shipper or as another carrier, a cooperative or marketing company, a transport agency, a freight forwarder, a warehouse-distributor, a logistics operator, or any other entity that habitually contracts transportation or habitually acts as an intermediary in its contracting. Order FOM/2861/2012, art. 4 (b) https://www.boe.es/buscar/doc.php?id=BOE-A-2013-154.
- The actual carrier is the natural or legal person that holds the authorisation under which the transport is physically carried out. Order FOM/2861/2012, art. 4 (a) https://www.boe.es/buscar/doc.php?id=BOE-A-2013-154.
- Art. 7 Orden FOM/2861/2012 https://www.boe.es/buscar/doc.php?id=BOE-A-2013-154.
- https://www.transportes.gob.es/transporte-terrestre/profesionales-transporte/servicios-transportista/documento-electronico-control-administrativo-deca/preguntas-frecuentes-faq-deca, FAQ 3rd question.
- https://cdn.transportes.gob.es/portal-web-transportes/transporte-terrestre/marco_referencia_sector/inspeccion_seguridad_transporte/baremosancionador-7.3--sa-.pdf (V. 7.3), EB02.01.
- E.g. If a carrier A subcontracts another carrier B for a particular consignment, carrier B is the actual carrier, while carrier A is the contractual shipper (https://www.transportes.gob.es/transporte-terrestre/profesionales-transporte/servicios-transportista/documento-electronico-control-administrativo-deca/preguntas-frecuentes-faq-deca).
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