Digital control document for road transport: mandatory in Spain from 5 October 2026

From 5 October 2026, the administrative control document required for public road freight transport in Spain — and the route sheet for public passenger transport — has to exist in digital format. A printed copy no longer counts, and not just any PDF works either: the rule sets specific technical requirements, and a document that doesn't meet them isn't legally valid.

Here's what changes, who it applies to, and how to solve it without generating the document by hand on every trip.

What the law requires, and from when

Law 9/2025, of 3 December, on Sustainable Mobility sets the deadline in its eighth transitional provision: ten months from its publication in the BOE (4 December 2025), which puts the deadline at 5 October 2026. From that day, the administrative control document for public freight transport and the route sheet for public passenger road transport are only valid in digital format — paper stops being sufficient.

What the digital document has to include

The Resolution of 5 June 2026 from the Directorate-General for Road and Rail Transport (which replaces the 2023 one) sets the format: a native PDF generated by an application — not a scan of a paper document —, up to 5 MB in size, with a QR code linking to a unique URL for that specific document, creation and modification metadata, and a minimum one-year retention with direct download available for inspection. Any PDF put together by hand, without a QR code or metadata, doesn't meet the rule even if all the information in it is correct.

Who's liable if a field is missing

Order TRM/282/2026, of 25 March, splits liability by type of data rather than assigning it generically to both parties: the contractual shipper is liable for the parties' details, the origin, the destination and the goods; the actual carrier is liable for the special authorisation, the date and the vehicle's details. If a company contracts the transport of its own products — without being a carrier itself — and the document has the destination or the goods description wrong, that liability is the company's, not only the carrier's.

Who it applies to

It applies to public road freight and passenger transport, both domestic and cabotage. No prior approval of the system that generates the document is required, and an electronic consignment note (eCMR) is valid if it contains the required data — there's no need for a separate document if the eCMR already covers them.

Where the document comes from: the system, or by hand

For a company with an ERP or a TMS (transport management system) that already organises its shipments, the sensible approach is for the document to be generated automatically from there, with the correct QR code and metadata on every trip — not for someone to fill it in and convert it to PDF by hand each time, risking a missing field or a file that doesn't meet the format. Docuten, a partner Tecnea works with as an integrator, offers the DeCA (the digital administrative control document) and the eCMR with an API, built to connect directly to the system a company already uses.

Before 5 October

• Check whether your current ERP or TMS already generates the document in the required format (native PDF, QR code, metadata, one-year retention).
• If it doesn't, decide whether to solve it with an integration (API) or a separate application that generates and archives it.
• If your company contracts transport without being a carrier, review which fields on the document are your responsibility as the contractual shipper.
• Confirm the system keeps the document for one year and allows a direct download for an inspection.

Frequently asked questions

Does this affect my company if I'm not a transport company? If you contract freight transport as a shipper — for example, to distribute your own products — yes: Order TRM/282/2026 makes you liable for the parties' details, the origin, the destination and the goods on that document, even if the vehicle and driver belong to another company.

Does a digitally signed PDF count? No, not unless it includes the QR code with the unique URL and the metadata the Resolution of 5 June 2026 requires. A digital signature doesn't replace those technical requirements.

What if I already use an electronic consignment note (eCMR)? It counts as the control document if it contains the data the rule requires — there's no need to duplicate the process with a separate document.

Sources

1. Law 9/2025, of 3 December, on Sustainable Mobility, eighth transitional provision: https://www.boe.es/buscar/doc.php?id=BOE-A-2025-24545
2. Resolution of 5 June 2026, from the Directorate-General for Road and Rail Transport, on the characteristics of electronic administrative control documents: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-12784
3. Order TRM/282/2026, of 25 March, on the allocation of liability for the control document's data: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-7128
4. Docuten, Mandatory DeCA: the digitalisation of the administrative control document reaches its final stretch

This article is informational, and applies to Spain only. Tecnea is a partner and integrator of Docuten, the provider mentioned as an example solution — the legal content it describes applies equally whether the integration is done by Tecnea, by Docuten directly, or by any other provider.