Mandatory digital control document: what is it and how to digitize it?

The mandatory digital control document is already a reality in Spain. Specifically, it will be in September 2026 when the entire transport sector will have to operate with this document, the only mandatory document, in electronic format.

The approval of the Sustainable Mobility Law in November 2025 has led to the mandatory digitalization of the control document, as stated in the 8th transitory provision.

But what is the control document and how can it be digitized with full legal and regulatory guarantees? We look at it in this post.

What is the mandatory digital control document?

There are several documents used in freight forwarding. Not all of them are mandatory and not all are governed by the same nature and regulations.

However, for practical purposes, all of them include or can include all the necessary information to support an operation. Therefore, when we at FIELDEAS talk about digitizing transport documents, we talk about the SeamLess eCMR module.

As we saw in the post eCMR, consignment note, control document, delivery note, are they the same, we find four different documents: control document, national consignment note, CMR consignment note, delivery note.

In Spain, in national transport, the only mandatory document is the control document, while in international transport the obligatory document is the consignment note or CMR, although the dynamics of the sector include others such as the delivery note.

Administrative control document

The administrative control document is regulated by Order FOM/2861/2012.

According to Article 3, “the control document is a document of an administrative nature, which must be carried on board the vehicle and accompany the goods during transport”.

It also establishes that, in the case of continuous transport contracts, a control document must be issued for each shipment carried out under the contract.

Article 4 states that the parties responsible for formalizing this document are the actual carrier and the contractual shipper, which implies the obligation to issue two copies of the document.

In addition, the Sustainable Mobility Law establishes that, as of September 2026, it will be mandatory to use the electronic version of the control document.

Purpose

The purpose of the control document is:

• Proof of the existence of a contract of carriage.
• Allow the Administration to verify the traceability and legality of the service.
• To be an instrument of inspection to prevent unfair competition.

Required fields

Likewise, Order FOM/2861/2012 establishes mandatory fields that the document must contain:

• Identification of the contractual shipper and the actual carrier.
• Description of goods.
• Place of origin and destination.
• Price of the transport or reference to the contract.
• Expected execution date.
• Vehicle registration number.
• Driver identification.
• Observations of the service.

How to digitize the mandatory digital control document

We already know what the control document is and that in the short term it will be mandatory to digitize it, but under what guidelines?

In fact, the digitalization of transport documentation has been supported for years, although it was the modification of the ROTT in June 2023 that established the requirements that guarantee its viability:

Characteristics of the mandatory digital control document

The control documentation required in accordance with the provisions of article 222.2 of the Regulations of the Land Transport Law, may only be completed by electronic means when the supports and computer applications used for this purpose meet the following characteristics:

• The data entered must be accessible to any person authorized to do so.
• Data storage and document delivery must be guaranteed.
• In those cases in which the regulations applicable to each control document establish the need for the signature of one or all of the intervening parties, such signatures shall be required:

a). Be linked only to the signatory.

b). Allow identification of the signatory.

c). Have been created using means that the signatory can maintain under his exclusive control.

d). Be linked to the data to which it refers so that any subsequent modification of the data can be detected.

Control and verification of the electronic control document

One of the main concerns of the industry is whether the digital document will be accepted by road transport surveillance forces.

This aspect is also included in the modification of the ROTT, and establishes two systems to verify the data:

• Code in numerical format, which allows agents to access a pdf with the control document.
• Reading of a QR code, containing the URL where the document is saved in pdf format.

Technological solution for digitizing the control document: SeamLess eCMR

The document digitalization module SeamLess eCMR from FIELDEAS Track and Trace ensures that any company in the transport sector can generate, manage and preserve the control document with full legal validity and maximum operational efficiency.

This solution is designed to strictly comply with the requirements established by Order FOM/2861/2012, the ROTT, the eCMR Convention and the eFTI Regulation, so that the entire document process, from creation to roadside inspection, is carried out with full legal and regulatory guarantees.

SeamLess eCMR automates the collection of mandatory data, avoids omissions or errors and allows the control document to be integrated into the digital workflow of shippers, carriers and logistics operators.

In addition, it incorporates advanced electronic signature systems that meet the criteria of identification, linkage to the signer and document integrity.

Furthermore, thanks to its verification, secure storage and immediate accessibility functionalities, the SeamLesseCMR ensures that the control document is always available and traceable.

This makes the process a legal, secure, efficient and sustainable mechanism, ensuring that any company adopting this solution will be fully prepared for the mandatory digital control document in September 2026.