Spain's road transport control document goes digital

What the control document is

Spain's Land Transport Act (LOTT) requires vehicles to carry, during the service, the control documents set out in regulations. For public road haulage, that document is governed by Order FOM/2861/2012: an administrative document issued for each shipment, which travels with the goods.

It is a document for the authorities, not for the parties to the contract. It lets roadside inspectors know who contracted the transport, who is performing it and what is being carried. In a continuous transport contract a general document is not enough: one is needed per shipment.

Who issues it and who is responsible

The order splits the obligation between two roles that should not be confused with the contractual ones:

• The contractual shipper: whoever contracts directly with the actual carrier. It can be the real shipper, but also another haulier, a cooperative, an agency, a freight forwarder, a distributor or a logistics operator.
• The actual carrier: the holder of the licence under which the transport is physically carried out.

Both are responsible for the document existing and being on board, although the shipper is exempt if it proves it issued it. As for the data, the shipper is responsible for the shipment details and the carrier for the vehicle details.

The minimum data

The order leaves the format and name of the document free, but requires eight items of data:

Two copies are issued, one for the shipper and one for the carrier, and both must be kept for at least one year for inspection, on any medium that keeps the data complete and legible.

Where the digital requirement comes from

Spain's Sustainable Mobility Act, Law 9/2025, came into force on 5 December 2025. Its eighth transitional provision states that the control document under Order FOM/2861/2012 must necessarily be digital ten months after that date. That takes us to 5 October 2026.

What that digital document must look like is set out in the Resolution of 5 June 2026 of the Directorate-General for Road and Rail Transport, which replaces the one of 22 May 2023. According to its preamble, it applies to domestic transport, including cabotage in Spain. International transport keeps using the documents of the conventions, such as the CMR consignment note.

What the digital document must look like

The application that generates it

• It records at least the data required by the order.
• It generates the file before the service starts and records the date and time of creation and of each change.
• It stores the files in a repository from which inspectors can download them. Any domain is valid, with no prior notice to the authorities.
• It gives each file a unique web address.

The file

• A PDF of up to 5 MB, with natively generated text: a scanned document is not valid.
• Creation and modification date and time in the metadata.
• A QR code pointing to the file's unique address. It can be inside the PDF or delivered separately.

The web address

• Served over HTTPS with TLS 1.2 or higher.
• With direct download of the PDF: no sign-in and no intermediate buttons.
• Valid at least until the service ends. It may be disabled seven calendar days after it ends.

Changes during the trip

If something changes en route, for instance the licence plate because the vehicle is replaced, the resolution allows two approaches:

1. Edit the same PDF, recording the reason and the cancelled data. The address and QR code stay the same.
2. Generate a new PDF, with a new address and QR code, and keep the original.

Either way there must be a record of what it said before. Handwritten notes on a printed copy are not taken into account.

What the driver carries and what happens at an inspection

The driver carries a copy on a phone or on paper, always with the QR code. At an inspection they can show the document or just the code, and the officer downloads the PDF from the web address.

Retention changes shape too: the contractual shipper and the actual carrier must keep the files for at least one year. If only one of them generates them, the other must be able to download them during that year.

The LOTT classifies as a serious offence the absence of control documentation, failing to fill it in or missing essential data, as well as failing to keep it, with a fine of 401 to 600 euros. Driving without the required formal documentation, when it isn't serious, is a minor offence with a fine of 201 to 300 euros.

Consignment note, CMR, eCMR and eFTI

The control document coexists with other documents that look similar but follow a different logic:

The order allows the consignment note to act as the control document if it carries all the required data. The resolution goes further: the format of another document, such as the consignment note, the ADR document or the waste identification document, is valid as long as it includes the minimum data and expressly identifies the contractual shipper and the actual carrier. And if that data is handled through a platform compliant with the eFTI Regulation, the document does not need to be presented in the form set by the resolution.

How to prepare

• Build the document from the data you already have in the transport order, so it isn't typed twice.
• Agree with your carrier or shipper who generates it and how the other party accesses it during the one-year retention period.
• Check that your software records the date and time of every change and keeps the previous version.
• Make sure the QR address downloads the PDF directly, without asking for a user name.