There is no DeCA grace period: what to check before the lorry leaves

There is no grace period. From 5 October 2026, the control document (documento de control) for public (hire-or-reward) road freight transport has to be digital, the DeCA (Documento electrónico de Control Administrativo), and Spain’s Ministry of Transport (Ministerio de Transportes y Movilidad Sostenible) has put in writing that the rules provide for no extra period without penalties. In this article you will see where the date comes from, who is liable if the document is missing and what to check before every departure. If you are looking for the full explanation of the obligation, you will find it in DeCA mandatory in 2026.

What the Ministry has said

In its frequently asked questions on the DeCA, the Ministry answers question 3, “Will there be a phase without penalties?” (our translation), with this sentence: “The rules do not provide for any additional phase, beyond 5 October, in which the digitalisation obligation is not penalised”. The same answer appears on the official DeCA page.

The reason it gives is that the transitional period has already happened: “the transitional period is already established in the Sustainable Mobility Law, and the date of the mandatory digitalisation of the DeCA is 5 October 2026”. In other words, the margin for adapting was the months that passed between the law and that date.

Where 5 October comes from

The date is set by Law 9/2025 of 3 December on Sustainable Mobility (Ley 9/2025). Its eighth transitional provision (disposición transitoria octava) says that the control document regulated in Order FOM/2861/2012 (Orden FOM/2861/2012) “must necessarily be digital ten months after the entry into force of this law”.

The law was published in the Official State Gazette (BOE) on 4 December 2025 and entered into force the following day, 5 December 2025. Ten months later is 5 October 2026. In the Ministry’s webinar it is summed up like this: “Transitional period defined in the LMS (10 months)”, LMS being the Sustainable Mobility Law.

What changes is the format, not the obligation. The control document already existed (it is regulated by Order FOM/2861/2012), and the Ministry’s own presentation points this out: “the Administrative Control Document exists before the digitalisation obligation”.

Who is liable if the DeCA does not exist or is not on board

Both parties to the transport. Article 7.1 of Order FOM/2861/2012 says: “The contractual shipper [cargador contractual] and the effective carrier [transportista efectivo] shall be liable for failing to formalise the corresponding control document. The same liability shall be attributed to them where it is not carried on board the vehicle, unless the contractual shipper proves that the document was issued, in which case the latter shall be exempted from liability”.

In the webinar, the Ministry sums it up in two words: if the document does not exist, “both penalised” (slide 9). And in its FAQ (question 8) it clarifies that in the Order “it is not specified who must materially produce the document”. That is why it is advisable to agree with each client or subcontractor on who generates it. If you work in a chain, read who makes the DeCA when transport is subcontracted.

For the data, the split is also in article 7: the contractual shipper answers for points a) to d) of article 6 (the parties, origin and destination, the goods and their weight) and the effective carrier for points e) to g) (the special authorisation, the date and the number plates).

Checklist before every departure

1. The DeCA exists before you set off. Section one (apartado primero) of the technical resolution of 5 June 2026 (Resolución de 5 de junio de 2026) requires the data to be turned into the file “as soon as they are known and always before the effective start of the service”. To guarantee this, the application must record the date and time of creation.
2. The driver has their copy before leaving. Under section seven, the copy is handed over “always before the effective start of the service”, on a mobile phone or printed on paper. Both are valid, as long as the copy contains the QR code. Paper is not prohibited: what has to be digital is the generation of the document.
3. The QR downloads the PDF directly. Section three establishes that “no URL shall be valid that leads to a web page requiring credentials or authentication, or that incorporates download buttons or other elements involving manual interaction”. Test it with a real DeCA: scan the QR with a phone on which you are not logged in and check that the PDF simply downloads. You will find the details in the DeCA’s QR code (in Spanish).
4. The number plates match the vehicle that leaves. For an articulated vehicle, article 6 g) of the Order requires both the tractor unit’s plate and the semi-trailer’s or trailer’s.
5. You know how to make corrections on the road. If something changes during the service, handwritten notes on the printed copy “shall not be taken into account” (section seven): the only valid way to modify the DeCA is the one in section five. Go over the common mistakes when generating the DeCA so you do not make the most frequent ones.

What you do not have to do

• Register with the Ministry or upload your DeCAs to it. Question 6 of the FAQ puts it like this: “There is no need to upload all the DeCAs to any Ministry platform”. The PDFs have to be in a repository, available for the authorities to download in the event of a roadside check.
• Look for a certified application. “No, DeCA software applications do not have to be certified”, the Ministry replies in question 7. The ones that will have to be certified are eFTI platforms, which are something else.
• Sign the DeCA. According to the same FAQ (question 4), a signature is not mandatory.

If you do not have a tool yet, in the same webinar the Ministry presented SIMPLE, a free platform developed by the Ministry, Puertos del Estado and ADIF which, among other functions, generates DeCAs. To see the whole process with any tool, follow how to generate a DeCA step by step (in Spanish).

If you were exempt, you still are

Digitalisation does not widen who is obliged. On parcel services (question 5), the Ministry sums it up like this: “those who did not issue a control document before still do not have to, and those who issued it on paper will now have to issue it electronically”.

Under article 2 of the Order, the following remain excluded: transport that does not require an authorisation (título habilitante), removals, the transport of crashed or broken-down vehicles in special vehicles, and parcel and similar services with a small number of packages that one person can easily handle without any help other than the machines or tools on the vehicle. According to questions 1 and 2, it does not apply either to private own-account transport (transporte privado complementario) or to international transport: only to domestic public transport, that is, national transport and cabotage (cabotaje). The details are in DeCA exemptions (in Spanish).