Spain is stepping up the digitalisation of road haulage by mandating that the administrative control document for third-party freight transport must be issued and managed solely in digital format. This is provided for by Ley 9/2025 de Movilidad Sostenible, published in the Boletín Oficial del Estado (the official state gazette) on 4 December 2025 and entering into force the following day. The measure is set out in the Disposición Transitoria Octava of the law and establishes a ten-month adaptation period from the entry into force of the legislation.
The rule applies to all third-party freight transport operations with origin or destination in Spanish territory. Its enforcement will be overseen by the Ministry of Transport through the Dirección General de Transporte por Carretera, in coordination with the Guardia Civil and the Autonomous Communities. The obligation will apply to companies, both corporate and sole traders, as well as to shippers and carriers that physically perform the service. Joint liability for the correct formalisation of the control document between the parties is already in place, with the requirement to prepare two copies of the paper document. Digitalisation does not alter this allocation of responsibility, but requires the parties to adopt appropriate tools for the electronic management of the document.
As regards foreign hauliers operating in Spain, the obligation depends on the type of operation. Those carrying out exclusively international transport are not required to carry the Spanish control document on board and are therefore not subject to its digitalisation, as the CMR and standard cargo documentation are sufficient. However, foreign hauliers performing road cabotage operations may be subject to the digitalisation of control documents relating to transport carried out within Spain.
The informational content of the digital control document remains that already provided for under existing legislation. It must indicate the name, NIF (equivalent to the Italian tax code), and address of the contractual shipper, the name and NIF of the actual carrier, the places of origin and destination of the goods, the nature and weight of the load, the date of transport, and the vehicle registration number, including tractor and semi-trailer. The absence or incompleteness of this information continues to constitute a sanctionable infringement.
Alongside the informational requirements, the legislation introduces specific technical conditions for the digital document. Amendments to the Reglamento de Ordenación del Transporte Terrestre of June 2023 establish that the document must be uniquely linked to the signatory, allow their identification, be created using means under the signatory’s exclusive control, and be linked to the data in such a way that any subsequent modification is detectable. To this end, an advanced electronic signature compliant with the eIDAS Regulation is required, preferably issued by a Prestador Cualificado de Servicios de Confianza (Qualified Trust Service Provider).
During roadside inspections, the digital control document may be presented via an electronic device such as a smartphone, tablet or computer, or through rapid access systems such as QR codes or secure repositories that allow officers to immediately verify the documentation. The legislation does not impose a single technological solution, but requires that access to the data be immediate and verifiable at the time of inspection.
With regard to sanctions, the Ley de Ordenación del Transporte Terrestre provides for a regime that is already applicable to the digital document. Serious infringements due to missing essential data are punishable by fines ranging from €401 to €600, rising to up to €1,000 in cases involving the transport of dangerous goods. Very serious infringements may result in fines of between €4,001 and €6,000, while repeat offences within twelve months can lead to penalties ranging from €6,001 to €18,000. In certain circumstances, the administrative immobilisation of the vehicle is also provided.
According to the government, digitalisation is expected to improve administrative efficiency by eliminating paper-based processes, strengthen data traceability and integrity, speed up inspections and increase transparency in document management. The law also forms part of the reforms envisaged under the Plan de Recuperación, Transformación y Resiliencia and is linked to the fifth package of NextGenerationEU funds, amounting to around €24 billion, of which approximately €7 billion are grants.
Despite the regulatory framework now being clearly defined, the sector’s level of preparedness appears uneven. A study conducted in October 2025 by the association Fenadismer, in collaboration with Continental, involving 750 transport professionals, indicates that only 17% of operators consider themselves ready for the introduction of the digital control document. A further 35% say they are poorly prepared, 23% not prepared at all, and 25% state that they rely on the shipper. According to the same survey, almost 70% of hauliers feel little or not at all ready for the introduction of electronic invoicing as well.
To support the digital transition, companies have been able to access the Kit Digital programme, which has provided grants of up to €2,000 for self-employed operators without employees and up to €12,000 for larger companies with 10 to 49 employees. At the same time, the market has developed a range of technological solutions for managing the digital control document, integrated with electronic signature systems and document management platforms.
Trade associations have expressed mixed views on the new obligation. Astic has welcomed it, highlighting its potential to encourage the adoption of other electronic documents such as the e-CMR. Fenadismer has pointed to the difficulties of adaptation, particularly for smaller companies, while Cetm has entered into agreements with digital solution providers to support its members during the transition.
Antonio Illariuzzi
