What operation and parties does the Order cover?
Article 1 concerns each consignment under a road freight transport contract within the Order’s scope. Article 4 identifies the actual carrier (transportista efectivo) and the party contracting directly with that carrier (cargador contractual). The latter may be an intermediary, rather than the physical loading site.
Article 2 provides exemptions, including certain operations not requiring a transport authorisation, removals, recovery of damaged vehicles using special vehicles and specified parcel services. Another legally compliant transport document may also serve as the control document if it contains all Article 6 data. Check the actual operation before deciding whether a separate document is needed. Source: FOM/2861/2012, Articles 1–4.
What information must be included?
Article 6 requires the following essential information:
- Contractual consignor’s name or business name, tax identification number and address.
- Actual carrier’s name or business name and tax identification number.
- Origin and destination of the consignment.
- Nature and weight of the goods; the provision allows another measure to determine weight where the loading circumstances make exact weight difficult to establish.
- Identification of a special circulation authorisation when the vehicle requires one.
- Date of carriage and vehicle registration; for an articulated combination, both the tractor and the trailer or semi-trailer.
- Observations, reservations or other useful indications requested by the parties.
A vehicle change during the operation must be recorded by the carrier. See the precise wording in Article 6.
Responsibilities changed in March 2026
The current Article 7, amended by Order TRM/282/2026 with effect from 29 March 2026, allocates missing or inaccurate Article 6(a)–(d) data to the contractual consignor and Article 6(e)–(g) data to the actual carrier. Each is also responsible for observations it includes under Article 6(h). Article 7(1) separately addresses failure to issue or carry the document.
Article 9 requires the obligated parties to retain a copy for at least one year, available to transport inspectors and preserving all required, readable information. Sources: Article 7 and its amendment; Article 9.
The digital requirement from 5 October 2026
Transitional provision 8 of Law 9/2025 requires this document to be digital ten months after the Law entered into force. The BOE records entry into force on 5 December 2025; this gives 5 October 2026. That deadline is still upcoming on this guide’s review date, 28 September 2026. Source and date calculation: Law 9/2025, transitional provision 8 and entry-into-force information.
The Resolution of 5 June 2026 sets the requirements for electronic documents and systems (DeCA) and replaces the Resolution of 22 May 2023. Among its requirements are creation before the service starts, timestamping, availability for inspection and a unique document URL. It expressly states that the repository domain does not require prior notification. Assess the complete resolution when choosing or configuring a platform; simply scanning a paper form is not a complete implementation plan.
The Resolution does not require a signature solely to make the administrative control document valid. A document used for an additional contractual purpose needs a separate review of that purpose and the relevant signature requirements.
Coordinate this with your dangerous goods documents
Map the administrative control document, contractual carriage document and dangerous goods information separately, even where one document will fulfil more than one purpose. Check the required data and the chosen electronic process for each purpose.
For an English-speaking business arranging operations in Spain, a useful starting point is a sample document, the contracting chain, the route and an explanation of who creates and updates the information. DGSA can discuss the dangerous goods documentation review through its advisory service.
Discuss your operation in Spain
Tell us which goods, activities and transport stages are involved. We will discuss the scope of the advice or training you need.