With the DCA, digitization reaches the logistics sector by regulatory mandate.

Did you know that the Administrative Control Document (DCA) will soon be 100% digital for road freight transport?

With the latest regulatory changes, the mandatory digitization of the DCA is just around the corner and will transform how logistics companies manage their documents. In this article, we explain in a clear, approachable tone what the DCA is, why it is mandatory, how the regulation is evolving toward its electronic version, and what it means for carriers, executives, managers, and traffic agents in the logistics sector. We’ll also look at the differences with the traditional consignment note and the CMR/eCMR, the benefits of this digitization, and best practices for implementing it correctly. Get ready to say goodbye to paper and welcome the “digital consignment note” as the new standard in your operations.

What is the Administrative Control Document (DCA) and why is it mandatory?

The Administrative Control Document (DCA) is a mandatory document that must accompany every shipment in public road haulage within Spain. Its main purpose is to prove the existence of a transport contract and record the essential details of the shipment, so that the authorities can verify on the road that the service complies with current regulations. In other words, the DCA guarantees the legality and traceability of each shipment, preventing unlawful operations (unauthorized or “off-the-books” transport) and facilitating inspections or procedures in the event of incidents.

The mandatory nature of the DCA is established by Spanish transport legislation (LOTT and related regulations). Specifically, Order FOM/2861/2012 regulates the requirement to document every shipment by means of a DCA. This document must be carried on board the vehicle together with the goods throughout the entire journey. There are some very specific exceptions (for example, removals, local small-parcel deliveries, transport on own account or free of charge, etc.), but in general every professional transport operation needs its DCA. It should be noted that the DCA is administrative in nature, distinct from the private contract, and serves as an instrument of control for the Administration.

How is the DCA different from the consignment note? The consignment note is the document that formalizes the transport contract between shipper, carrier and consignee, whereas the DCA is an administrative control requirement. However, the two can be combined: the consignment note itself (or another equivalent transport document) can serve as the DCA provided it includes all the mandatory data required by Order FOM/2861/2012. These minimum data include, among others: details of the contracting shipper and the actual carrier (name, NIF, address), origin and destination of the shipment, date of transport, description and weight of the goods, vehicle license plate, etc. In short, the DCA has no single predefined format – each company may design it as it sees fit – but it does have mandatory minimum content to ensure its legal validity.

The current state of the regulation: towards a mandatory digital DCA

The digitization of the DCA is already a legal reality on the way. Currently, it is already legal to use the DCA in electronic format, provided that certain technical guarantees of readability, integrity, and inviolability of the document are met. In fact, the Ministry of Transport (MITMA) published a resolution on June 7, 2023 establishing the technical conditions to consider a DCA in electronic form valid. This regulation requires, for example, that the digital document can be transformed into a readable format (e.g., PDF) without altering its content, and that it incorporates mechanisms to ensure its authenticity (electronic signatures, systems that detect any subsequent modification, etc.).

That said, the major regulatory change comes with the new Sustainable Mobility Law (currently in its final approval stage). This law will include the mandatory use of the electronic DCA in the coming years, definitively ending the paper era. Initially, it was planned to require the control document exclusively in electronic format as of September 1, 2024, but its entry into force has been postponed to give more leeway to the sector. According to the latest forecasts, it will be at the beginning of 2026 when the digital DCA becomes mandatory for most transport operations. This is set out in the transitional provision of the Sustainable Mobility Law, which postpones the initially proposed date by ~1.5 years due to the system’s technical complexity and the need for transport companies to adapt.

Moreover, the rollout will be gradual. The regulation (derived from R.D.-law 14/2022 and the forthcoming regulatory development) establishes that from 2026 all B2B goods shipments with a value greater than €150 must be documented with a digital consignment note/DCA, and by 2027 the requirement will generally extend to practically all professional carriers with a commercial contract. In short, in 2026 the e-DCA will be the new rule for most operations (except small low-value shipments or other exemptions), and in 2027 it will already be the universal standard in road freight transport in Spain.

To facilitate this transition, the European Union itself is also pushing in the same direction through the eFTI Regulation (Electronic Freight Transport Information), which entered into force in August 2024 and creates a framework for the mutual recognition of electronic transport documents at the European level. Spain, for its part, has already ratified the eCMR Protocol (electronic consignment note for international CMR), and with the new law it is fully aligned with documentation digitization.

Legal and operational implications for transport and logistics companies

For transport professionals, the arrival of the mandatory digital DCA entails several new challenges and responsibilities. Legally, from the established date (early 2026), failure to have the DCA in electronic format when required will be sanctionable with significant fines and even vehicle immobilization. Currently, the absence of—or deficiencies in—the control document are already considered serious infringements under transport regulations, with penalties ranging from approximately €401 to €1,000 depending on the case. With the electronic version, these penalties will equally apply if the document has not been formalized digitally when mandatory, if any essential data is missing, or if it cannot be shown to inspection officers. In short, companies that do not implement the digital DCA in time risk roadside stops for their trucks, hefty fines, and operational impacts due to regulatory non-compliance.

Operationally, transport and logistics companies will need to adapt their internal processes and IT systems. Issuing the digital DCA will involve using specialized software or platforms to generate the document with the mandatory fields and a valid electronic signature. It will also require training staff (both administrative teams and drivers) in the use of these tools. For example, the actual carrier (driver) will remain responsible for carrying the document, but now in electronic form: they must have a means to display it during the journey (a smartphone, tablet, or device with access to the document). It is essential to ensure that the driver knows how to access the digital DCA even without an internet connection, so it can be presented on the road during an inspection at any time.

Another important implication is the coordination between shippers, logistics operators, and carriers. The regulation establishes that all parties involved in the transport contract are responsible for formalizing the DCA—that is, both the actual carrier and the contractual shipper must ensure that the shipment is properly documented. In practice, this means that shippers and logistics operators must also integrate with the digital systems or platforms where the document is generated, so they can complete or verify the shipment data before departure. Agreements between shippers and carriers should be updated to define who generates the electronic DCA, how it is shared and stored, and to ensure it always travels with the goods (even if only in digital form).

Finally, there are custody and audit considerations: companies must retain control documents in digital format for the period set by law (currently at least 1 year, although keeping them longer is recommended) in order to handle potential delayed inspections or claims. Fortunately, digital solutions make this automatic archiving with backups easier—something that was far more cumbersome on paper.

DCA vs CMR/eCMR: differences in domestic and international transport

It is important to distinguish the scope of application of the DCA from other transport documents such as the traditional consignment note or the international CMR. In domestic transport (within Spain), the DCA – or the consignment note acting in its place – is the mandatory control document under domestic regulations. By contrast, in international road transport between countries that are parties to the CMR Convention, the essential document is the CMR, which formalizes the international carriage contract.

In short, for domestic shipments the Administrative Control Document (paper or digital) is required by Spanish legislation in order to circulate within national territory. For international shipments, the CMR (Convention on the Contract for the International Carriage of Goods by Road, Geneva 1956) acts as the international consignment note and contains the details of the contract between the shipper and the carrier who will cross borders. Spain is a party to that convention, so a valid CMR meets the documentary requirements for international journeys. In fact, Spanish regulations recognize that if a transport operation is already documented with a CMR or another consignment note in accordance with international or EU law, that document also serves as the DCA provided it includes the mandatory data mentioned.

Now, a similar situation applies with digitalization: domestically we talk about a digital DCA or “electronic consignment note”, while for international movements there is the eCMR, which is the electronic version of the CMR. Key differences? In practice, the eCMR serves the same function as the digital DCA in the international sphere, except that it must be accepted by both the country of origin and the country of destination. If Spain requires a digital DCA in 2026, that will mean a truck leaving Spain for another country must carry its documentation electronically; if the destination country also accepts eCMR (more than 30 countries have already ratified the eCMR protocol), then a single electronic document will serve both to comply with Spanish rules (DCA) and international rules (CMR). That is why the term “digital consignment note” is often used generically, covering both the domestic digital DCA and the international eCMR, as applicable to each transport.

In summary, for domestic transport the control document (DCA) is mandatory under Spanish law, while for international transport the CMR (or eCMR if digital) is the primary contract document. With the new law, Spain requires that domestic shipments also be handled electronically, just as is already being done for international ones. The digital consignment note brings both worlds together: a technological solution that enables generating and sharing transport documentation electronically, whether for a local shipment or one that crosses borders.

Benefits of digitizing the DCA for companies in the sector

Adopting the DCA in digital format is not just about complying with the law; it also brings significant operational and financial benefits for transport and logistics companies:

• Streamlining and efficiency: Manual paperwork is eliminated, reducing administrative errors and preventing document loss. A well-implemented electronic document can save up to 70% of the administrative time devoted to document management. Data can be integrated automatically into systems (ERP, TMS), avoiding manual re-entry.
• Improved inspections and traceability: With digital documents it is easier and faster to handle a roadside inspection—for example, by showing a QR code or a digital receipt on a mobile device instead of searching through paper copies. In addition, shipment information can be consulted in real time by authorized parties (company, customer, authorities), providing full transparency and traceability for each shipment.
• Cost savings and sustainability: Although it initially requires investment in technology, in the medium term digitalization saves on printing, stationery, physical storage, and courier costs. There is no longer any need to print three copies per shipment or archive stacks of paper. This not only reduces expenses but also contributes to environmental sustainability, aligning with “paperless” policies and emissions reduction.
• Data integrity and security: A digitally signed DCA guarantees that its content has not been altered—something that is harder to ensure on paper. Likewise, digital platforms typically offer automatic backups and access controls, reducing the risk of loss or deterioration of documents. Documentation remains centralized and accessible for queries or audits, with logs of who created it and when.
• Better customer service and competitiveness: For shippers and end customers, having digital documentation means instantly receiving proof of delivery, having visibility into shipment status, and, overall, enjoying a more modern service. Transport companies that digitalize offer a more agile and professional experience, differentiating themselves from traditional competitors. In such a competitive sector, this technological edge can tip the balance when it comes to retaining demanding customers who value efficiency.

In short, although there may be some initial resistance to change (understandably, many self-employed carriers fear costs or technical complications), the reality is that DCA digitalization will bring significant savings and improvements to day-to-day operations. And with the right tools, its use is straightforward and reliable.

Best practices and technical requirements to correctly implement the digital DCA

Moving from paper to the digital DCA will require following a set of best practices and meeting certain technical requirements so the electronic document has full legal validity. Below is a summary of the key points to keep in mind (derived from Order FOM/2861/2012, its updates, and the forthcoming law):

• Readable, standard format: The electronic document must be generated in a format that reproduces all mandatory content and can be read without issues. The most common choice will be PDF/A (archival PDF format) as it is secure and widely compatible. However, other structured formats (XML, JSON) may also be used, provided they can then be presented in a readable form. The key is that any inspecting officer can view the DCA quickly, either on screen or by printing it, and verify the essential data.
• Recognized electronic signature: To guarantee authenticity, the digital DCA must be electronically signed by the obligated parties (at least by the actual carrier, and optionally by the shipper). The signature must be advanced or qualified, meeting eIDAS criteria: linked exclusively to the signer, enabling identification, under the signer’s sole control, and any subsequent alteration of the document must be detectable. In practice, this means using valid digital certificates (FNMT, DNIe, qualified certificates, or approved e-signature platforms). The electronic signature gives full legal equivalence to the digital document compared to paper signed by hand.
• Integrity and immutability: Beyond the signature, it is good practice for the system to generate a hash or unique code for the document (for example, an alphanumeric identifier or a QR) that is associated with the shipment. This way, any tampering would be evidenced because the hash would no longer match. Many platforms include this function automatically. It is also advisable to record timestamps indicating when the document was created and closed. All these elements ensure the integrity of the e-DCA, a requirement set by the Directorate-General for Road Transport.
• Accessibility and immediate availability: An electronic DCA must be capable of being shown roadside even without connectivity. This implies that, although the document is stored “in the cloud,” the driver should carry some form of local access—for example, a PDF downloaded to their device or a code that works offline. It is recommended that the application or platform used allows downloading readable copies of the DCA to drivers’ devices before starting the trip. Thus, when stopped by an inspector, you will not depend on mobile coverage to present the document.
• Two presentation methods for inspections: The regulations mainly contemplate two systems for officers to verify the digital DCA: (1) Via a numeric code provided to the driver, with which the inspector can access the document on the Ministry’s servers (through MITMA’s electronic office); or (2) via a QR code on the document itself, linking to a repository where the DCA is stored. Each company may choose one method or the other. If using submission to MITMA’s site (the numeric code method), each DCA must be uploaded to the official platform before the trip. If using the QR with own repository method, the company must notify its web domain to the Ministry in advance and ensure the document is hosted on a secure server (HTTPS) accessible via the QR link. In both cases, the goal is for inspectors to obtain a copy or view the DCA’s content instantly by electronic means.
• Complete mandatory fields: Although it may seem obvious, one of the main causes of penalties will remain failing to fill in a required field in the control document. Therefore, when digitizing, it is advisable to define templates that do not allow essential data to be omitted. Systems should guide the user to include all fields required by Order FOM/2861/2012—from the details of the parties involved to the vehicle registration, date, nature and weight of the load, etc.—before issuing the final DCA. Validating this in advance will prevent fines for incomplete documentation.
• Retention and auditability: Implement procedures to securely store each electronic DCA for at least the legally required period. Best practices suggest keeping them for about 3 to 5 years in accessible repositories, to cover not only the minimum obligation (1 year for domestic transport) but also possible litigation or later requests. Likewise, leverage technology to maintain an audit trail: who created the document, who modified it, who signed it, and when. This complete traceability provides legal certainty to all parties and speeds up the resolution of any dispute concerning the shipment.

By following these technical and organizational guidelines, companies can ensure that the implementation of the e-DCA is successful and smooth. In case of doubt, it is always advisable to consult official sources (for example, the updated Order FOM/2861/2012, the LOTT Regulation in its articles 222–223, or MITMA’s guidance) to verify that all specific requirements are met. The transition to the digital DCA is a process, but with the right tools and preparation, the result will be a more robust, legally valid, and efficient document system.

The future of document management: digital solutions for the DCA

The entry into force of the mandatory digital DCA will mark a before and after in the sector. Fortunately, companies are not alone in this transformation: the market already offers specialized digital platforms that make it easier to manage the electronic consignment note and other transport documentation. For example, solutions like Orus Logistics will allow you to generate and send the electronic DCA easily, integrating it with your transport orders and sharing it with all stakeholders in just a couple of clicks. These tools take care of the technical requirements (format, signature, storage, access) so that your company stays compliant with the regulations without technological headaches. Ultimately, going digital will not only be a legal mandate, but also a modernization opportunity: those who adopt the digital DCA early will gain a competitive edge, optimize their processes, and deliver better service in the era of logistics 4.0.

In short, the Administrative Control Document in digital format represents the definitive arrival of regulatory digitization to road transport. All players in the logistics sector – carriers, agencies, shippers, and operators – must prepare for this imminent change. With knowledge of the regulations, planning, and the right tools, the transition will be successful. The “digital consignment note” will cease to be a novelty and become part of logistics’ day-to-day, bringing greater control, safety, and efficiency to a sector that is vital to our economy. The future of transport is already here, and it comes with a QR code instead of a rubber stamp!