Spain's electronic DeCA: what the ADR document lacks

By the MYDG.SHOP Dangerous Goods team — certified DGSAs

On 5 October 2026 the administrative control document — the documento de control administrativo, universally called the DeCA — stops being allowed on paper for the public carriage of goods by road within Spain. The question landing on every safety adviser's desk right now is the same one: «I already issue an ADR transport document. Does it count as the DeCA, so I can drop one piece of paperwork?»

The short answer is yes, and it is written into the rule. The useful answer is that an ADR transport document, exactly as 5.4.1.1.1 produces it, is missing five of the eight items the DeCA requires — and that a rule inside ADR itself constrains where you are allowed to add them. This article makes that comparison item by item, quoting both texts.

What changes on 5 October 2026

The eighth transitional provision of Ley 9/2025, of 3 December, on Sustainable Mobility requires the administrative control document governed by Orden FOM/2861/2012 to be necessarily digital ten months after the law enters into force. The law was published in the Spanish official gazette on 4 December 2025 and entered into force on 5 December 2025, so the ten months expire on 5 October 2026.

The how is set by the Resolution of 5 June 2026 of the Directorate-General for Road and Rail Transport (BOE-A-2026-12784, official gazette no. 143 of 12 June), which lays down the characteristics required of the systems and of the electronic control documents, and repeals the earlier Resolution of 22 May 2023.

Scope — read this before going further. The Resolution applies to domestic carriage, with origin and destination in Spanish territory, and to cabotage operations. International carriage that merely crosses part of Spain is outside it: those movements use the control documents of the conventions Spain is party to. A Badajoz-to-Lisbon ADR consignment is unaffected. Badajoz to Bilbao is not.

What paragraph Eight says

Paragraph Eight of the Resolution expressly allows another transport document to be reused as the DeCA, and it names ADR outright:

«Se admite la posibilidad de utilizar cualquier formato previsto para otros documentos de transporte, como pueden ser los definidos para cartas de porte, el documento de transporte según el Acuerdo sobre Transporte Internacional de Mercancías Peligrosas por Carretera (ADR)…»
Our rendering: «It is permitted to use any format provided for other transport documents, such as those defined for consignment notes, the transport document under the Agreement concerning the International Carriage of Dangerous Goods by Road (ADR)…»

The permission comes with a condition, and the condition decides everything: the document must carry all the data listed in Article 6 of Orden FOM/2861/2012, clearly distinguishing the contracting shipper (cargador contractual) from the actual carrier (transportista efectivo).

In other words: it is not that your ADR document now counts as a DeCA. It is that your ADR document can carry the load if you add what it lacks. And it lacks a fair amount.

The comparison, item by item

On the left, the eight essential items Article 6 of Orden FOM/2861/2012 requires — in the wording currently in force: item (e) was added by Royal Decree 70/2019, which is why there are eight letters and not the seven most summaries still quote. On the right, what the ADR transport document of 5.4.1.1.1 actually gives you.

Of eight items, one is fully covered, two are half covered and five have to be added. None of them is hard: they all already sit in the system of whoever raises the consignment. What you cannot do is assume the ADR document you have always issued will pass an October roadside check untouched.

The underlying trap: consignor is not the contracting shipper

The condition in paragraph Eight — a clear distinction between cargador contractual and transportista efectivo — is not a formality. The two rulebooks use different vocabularies of participants.

ADR allocates obligations among consignor, carrier, consignee, loader, packer, filler and unloader in Chapter 1.4, and its "loader" is whoever physically loads the packages onto the vehicle. Spanish transport-ordering law speaks instead of the contracting shipper — the party who contracts the carriage in its own name — and the actual carrier, the one who performs it. These are different axes: the same consignment can have an ADR consignor who is not the contracting shipper, and an ADR loader who is neither.

Filling in the ADR "consignor" box and assuming the contracting shipper is thereby identified is the mistake we expect to see most often in the first rounds of enforcement.

Who answers for each item — Article 7

The Orden does not stop at listing the eight items; it says who is liable for each. Article 7, in the wording given by Orden TRM/282/2026 of 25 March (which corrected cross-references left wrong since 2019), allocates it in two blocks: the contracting shipper answers for items (a) to (d) — including the identification of the actual carrier — and the actual carrier for items (e) to (g): special permit, date and registration plates. Each answers for the observations it adds under (h). Both are liable for not issuing the document or not carrying it on board, and the contracting shipper is exempt from the latter if it proves the document was issued. Delegating the issuing of the file does not move the liability.

Two consequences follow. First, if your regular carrier subcontracts, you must know who actually puts the truck on the road: the actual carrier is the holder of the licence under which the carriage is materially performed, and its name and tax number are your item (b). Second, the contracting shipper is whoever contracts directly with that actual carrier (Article 4): when a factory hires carrier Pérez and Pérez subcontracts the haul to Gómez, the actual carrier is Gómez and the contracting shipper is Pérez — the factory stays the ADR consignor and the place of origin, but it is not the contracting shipper on the DeCA.

The ADR rule that dictates where you may add the data

Adding fields to an ADR transport document is allowed — but not anywhere. 5.4.1.1.1 itself sets the limit:

"The location and order in which the elements of information required appear in the transport document is left optional, except that (a), (b), (c), (d) and (k) shall be shown in the order listed above (i.e. (a), (b), (c), (d), (k)) with no information interspersed, except as provided in ADR."

In practice: the dangerous goods description — "UN 1098 ALLYL ALCOHOL, 6.1 (3), I, (C/D)" — is a closed block. The contracting shipper's tax number, the registration plates and the date go outside that sequence, not between the packing group and the tunnel restriction code. A badly designed form that interleaves fields breaks 5.4.1.1.1 while trying to satisfy the Spanish Resolution.

What the paper version never demanded and the file does

Reusing the ADR format does not exempt you from the technical requirements of the electronic document. The ones that change day-to-day practice:

• Natively digital PDF, 5 MB maximum. Scanning a signed paper ADR document will not do: the file has to be born digital, carrying creation and modification timestamps as metadata (paragraph Two).
• An embedded QR code pointing to a unique web address, and also available as a standalone file.
• A URL over HTTPS with TLS 1.2 or higher that downloads the PDF directly. Pages behind credentials, or with a button to click, are not acceptable (paragraph Three). It may be switched off 7 calendar days after the service ends.
• A copy to the driver before the service effectively begins, either electronically on a mobile device or printed — both carrying the QR code. At a check the driver presents the DeCA with its QR code, or the QR code alone (paragraph Seven).
• Handwritten notes on the printed copy are not considered valid. If something changes en route, you either amend the file or generate a new one, stating the reason for the change, and hand it to the driver again (paragraphs Five and Seven).
• Retention of at least one year, by both the contracting shipper and the actual carrier. If one of them generated it, the other must be able to download it throughout that year (paragraph Two).
• Advanced electronic signature (AdES) as a minimum, under Regulation (EU) 910/2014, where a signature is needed for contractual purposes (paragraph Four).

And one obvious point worth saying out loud: none of this replaces the instructions in writing of 5.4.3, or anything else in 8.1.2. The DeCA is a transport-regulation document, not a safety one.

The eFTI door, and why it is not a shortcut for October

Paragraph Nine opens a second route: where the Article 6 data is handled under the scheme of Regulation (EU) 2020/1056 — the eFTI Regulation on electronic freight transport information — it will not be necessary to present the DeCA in the form described in the Resolution.

This is the first time a Spanish instrument puts the ADR document and eFTI in the same text, and it points the direction of travel: the eFTI data subset covering inland carriage of dangerous goods — EU05a — is Chapter 5.4 of ADR modelled field by field.

That said, be honest about the timing. Member State authorities are only obliged to accept information shared through certified eFTI platforms from 9 July 2027, and the functional requirements for those platforms were set by Implementing Regulation (EU) 2025/2243 of 6 November 2025. For 5 October 2026 the workable route is the one in the Resolution. eFTI belongs in next year's systems plan, not in this autumn's fix.

Foreign carriers: the international leg and the cabotage leg are different documents

The scope point above matters most to fleets from Portugal, France, Poland, Romania, Lithuania or the Netherlands that deliver into Spain. The same truck can be in two different situations within forty-eight hours. Loading in Lisbon or Lyon and unloading in Madrid is international carriage: it is documented with the CMR consignment note, Spanish leg included, and the DeCA does not apply to it. Picking up a load in Madrid for Seville before heading home is cabotage — origin and destination in Spain — and from 5 October that leg needs a DeCA, whatever the country of establishment. Every cabotage leg needs its own; Regulation (EC) 1072/2009 allows up to three within seven days of the international delivery. The CMR note can serve as the DeCA for those legs if it carries the eight items and labels the contracting shipper and the actual carrier expressly — but the file still has to meet the technical requirements of paragraphs Two and Three.

What to do before 5 October

1. Decide whether to reuse the ADR document or issue a separate DeCA. Reusing saves a document and forces a template redesign; issuing separately is simpler and duplicates data. For fleets running many domestic ADR consignments, reuse usually pays.
2. Add the five missing items — contracting shipper's tax number and address, actual carrier's tax number, date, tractor and trailer registrations, and the observations field — outside the (a)–(d)–(k) block of the dangerous goods description.
3. Separate contracting shipper and actual carrier explicitly in the template. Do not infer them from the ADR consignor and consignee boxes.
4. Check that your system produces a native PDF and a QR code, and that the URL downloads the file without asking for credentials. This is where most ERPs will fail in the first weeks. You can run that exact test now with our free DeCA technical checker: paste the URL from the QR and it tells you what the server returns, whether the PDF is natively digital, its size and metadata, and what the QR actually contains.
5. Set archiving to one year and confirm the other party can download it throughout.
6. Confirm the movement really is domestic. International carriage is out of scope, and plenty of fleets run both off the same template.

If you are rebuilding the template anyway, it is a good moment to verify the ADR content itself — that the tunnel restriction code is there, that the packing group matches and that the total quantity is the one 5.4.1.1.1 (f) requires. Our ADR substance lookup gives you the Table A entry each item comes from, and the ADR 1.1.3.6 calculator gives the points calculation where the consignment stays inside the exemption. If you also run orange-plated vehicles in Spain, the routing obligation is a separate matter and we cover it in our article on the RIMP network.

We have put the whole subject on one page — what the DeCA is, who it applies to, the eight items and who answers for each, the technical checker and a twelve-question FAQ covering the cases the ministry's own FAQ leaves open: mydg.shop/pages/deca. If you would rather not redesign the template yourself, the DeCA 2026 Kit contains the combined ADR + DeCA template in Word and Excel, the 14-point checklist, the technical sheet for your IT provider and the manual route for low volumes.

For case-by-case questions — and this rule will generate plenty of them in October — the MYDGADR Agent answers citing the applicable article, and our safety advisers are reachable through contact.

Sources

• Ley 9/2025, of 3 December, on Sustainable Mobility — official gazette no. 291, 4 December 2025; eighth transitional provision. BOE-A-2025-24545
• Resolution of 5 June 2026 of the Directorate-General for Road and Rail Transport — official gazette no. 143, 12 June 2026; paragraphs One to Eleven. BOE-A-2026-12784
• Orden FOM/2861/2012, of 13 December, consolidated text: Article 6 as amended by Royal Decree 70/2019 and Article 7 as amended by Orden TRM/282/2026, of 25 March. BOE-A-2013-154
• ADR 2025, 5.4.1.1.1 — official text, ECE/TRANS/352 Vol. II.
• Regulation (EU) 2020/1056 (eFTI) and Implementing Regulation (EU) 2025/2243 of 6 November 2025.

This article reproduces and cites the rules in force at the date of publication and is intended as decision support, not a substitute for a decision. Determining which documents must accompany a given consignment rests with the undertaking and, where applicable, with its dangerous goods safety adviser. Quotations from Spanish instruments are given in the original; English renderings are ours and unofficial. Always verify the text in force in the BOE.