The DeCA in cabotage: a guide for foreign carriers in Spain

If your company is Portuguese, French or from any other country and you carry out a transport operation with its origin and destination in Spain, that is, cabotage (cabotaje), you need the DeCA (Documento electrónico de Control Administrativo) just like a Spanish company. If the trip is international and only passes partly through Spain, you do not: the documents of the international conventions are used there. That is what the technical resolution of 5 June 2026 (Resolución de 5 de junio de 2026) and the DeCA page of Spain’s Ministry of Transport (Ministerio de Transportes y Movilidad Sostenible) say. From 5 October 2026, that document must be generated digitally.

Cabotage yes, international transport no

The preamble of the Resolution explains that control documents (documentos de control) are mandatory for domestic transport, which article 65 of the Land Transport Act (Ley de Ordenación de los Transportes Terrestres) defines as transport with “its origin and destination within the territory of the Spanish State, running as a general rule entirely within it” (our translation). The same definition adds that, “by reason of their routes and under multimodal transport arrangements”, such transport may cross waters or airspace not under Spanish sovereignty.

And it concludes: “cabotage operations within the territory of the Spanish State are included in this obligation, while international transport operations running partly through Spanish territory fall outside it, since they will use the control documents established in the conventions signed by Spain”.

Applied to a Portuguese lorry leaving Porto:

• Porto–Madrid: international transport. No DeCA.
• Madrid–Seville, loading in Madrid after unloading: origin and destination in Spain, cabotage. DeCA required.
• Seville–Lisbon: international again. No DeCA.

The rest of the scope does not change because you are foreign: the DeCA is only for public (hire-or-reward) transport (slide 6 of the Ministry’s webinar), and Order FOM/2861/2012 (Orden FOM/2861/2012) makes no distinction by nationality when it sets out its exemptions (in Spanish).

Who is who when the lorry is foreign

Article 4 of Order FOM/2861/2012 defines the effective carrier (transportista efectivo) as the “holder of the authorisation under which the transport is materially carried out”. If the Madrid–Seville trip is made by your lorry under your authorisation, you are the effective carrier. The contractual shipper (cargador contractual) is whoever contracts you directly: your customer, whether that is the actual shipper, an agency, a freight forwarder or another carrier subcontracting the job to you.

Both are obliged to formalise the DeCA, and the Order does not say which of the two must physically produce it (question 8 of the Ministry’s FAQ). Whoever contracts you can generate it, or you can, but agree on it with them before the trip: under article 7.1 of the Order, both are liable if it is not formalised. If there are intermediaries involved, see who makes the DeCA when transport is subcontracted.

Can a CMR serve as a DeCA?

Its format can. The Ministry’s question 13 distinguishes between a document’s format (“the fields and their visual layout”) and its legal nature, and explains it with domestic transport: “in a national transport operation the CMR format may be used if it is more convenient, but that does not mean the service is being performed under the CMR Convention, since it does not apply to national transport”.

Section eight (apartado octavo) of the Resolution accepts any format from other transport documents, on two conditions: that all the data of article 6 of the Order is included, and that the contractual shipper and the effective carrier appear “expressly and distinctly”. That is why filling in the usual CMR boxes is not enough: the document has to state who each of those two parties is.

The document must also comply with the Resolution: a PDF generated natively in digital form, never a scanned paper document, with a QR code that leads to its direct download. A CMR filled in by hand will not do as a DeCA. The full requirements are in DeCA requirements, and the comparison between the two documents in DeCA vs CMR (in Spanish).

For the international part of your trips, question 1 makes it clear: “No, the eCMR is not mandatory”.

What you do not have to do

• Register with the Ministry. The DeCA is not a Ministry application and the documents do not have to be uploaded to any Ministry platform (question 6). What is needed is for the PDF to be in a repository from which the authorities can download it during a roadside check.
• Notify your web domain. The repository can be on any domain without prior notification (section one, point 3).
• Use a certified application. According to question 7, DeCA applications do not need to be certified.

If you do not want to subscribe to an application, the Ministry, Puertos del Estado and ADIF have developed SIMPLE, a free platform which, among other functions, generates DeCAs (slide 27 of the webinar).

What your driver carries

Before the service starts, the driver must receive a copy of the DeCA, on their phone or printed on paper, and in both cases with the QR code (section seven). When staff of the Land Transport Inspection Services (Servicios de Inspección del Transporte Terrestre) or road transport enforcement officers (agentes de las fuerzas de vigilancia del transporte en carretera) ask for the document, the driver shows the DeCA with the QR code or, failing that, just the QR code. Handwritten corrections on the printed copy do not count. We explain how the check continues in the DeCA roadside inspection.

What these rules do not say

There are questions that the Order and the Resolution do not settle, and it is best not to take anything for granted:

• Language. Neither the Order nor the Resolution sets the language of the DeCA. The Resolution speaks of “legible written characters” (section two).
• Tax identification. Article 6 asks for the effective carrier’s “NIF” (Spanish tax identification number), but does not explain how to identify a company without a Spanish NIF.
• Cabotage rules. The Order and the Resolution regulate the control document, not the conditions for carrying out cabotage, which depend on other rules we do not cover here.

If you want the general context of the document, start with what the DeCA is.

DeCAya for companies from outside Spain

The DeCAya app is available in Spanish, Portuguese, French, English and German and, unless you choose another one, it opens in your device’s language. For a non-Spanish company, the form accepts its tax number with the country code in front, for example PT123456789.