DeCA, consignment note and eCMR: three documents, three jobs
They get mixed up a lot, and the mix-up has consequences: some believe 5 October 2026 makes the eCMR mandatory in Spain, others believe the usual consignment note already covers them. This page explains what each document does, which one Spanish law requires and when one can do the job of another. Every statement carries its source. The general guide is Cabotage in Spain: the DeCA goes digital on 5 October 2026; if you handle paperwork for many carriers, see DeCA for gestorías.
Lectores en español: esta página en español.
Three documents, three jobs
Consignment note / CMR
The document of the contract between the parties: who orders the transport, who performs it, what is carried and on what terms. For international carriage it is the consignment note of the CMR Convention.
eCMR
The CMR consignment note in electronic form, under the Additional Protocol to the CMR Convention. Still the contract document, only digital. In Spain it is not mandatory, according to the Ministry's FAQ.
DeCA
The administrative control document: what the authority wants to be able to see at a check. From 5 October 2026 it must be digital for interior transport, cabotage included. It is not required for international carriage.
The Documento electrónico de Control Administrativo (DeCA) is not a contract. It is the control document of Orden FOM/2861/2012 in electronic form: it travels with each consignment of public road freight inside Spain so that inspectors can check the service data (Orden, article 1; Ministry DeCA FAQ). International transport is outside it: those journeys travel on the control documents of the conventions Spain has signed, such as the CMR (Real Decreto 1211/1990, ROTT, article 222.1). Cabotage inside Spain, on the other hand, does need a DeCA: the Resolución of 5 June 2026 says so in its preamble.
Comparison
The consignment-note and eCMR columns describe those documents only as far as the DeCA rules and the Ministry FAQ speak about them. Their own contract-law rules are not covered here.
On small screens the table scrolls sideways.
| Consignment note / CMR | eCMR | DeCA | |
|---|---|---|---|
| Purpose | Documents the contract of carriage between the parties. | The same as the CMR consignment note, in electronic form. | Administrative control: lets inspectors check the service data. |
| Who issues it | The parties to the contract (whoever orders the transport and whoever performs it). | The parties to the contract, on an electronic platform. | The contractual shipper and the actual carrier formalise it; both are liable for it being on board (Orden, articles 4 and 7). |
| Mandatory? | It is the contract document. For international carriage, the control document is the one of the applicable convention (ROTT, article 222.1). | No, in Spain (Ministry DeCA FAQ). | Yes, for interior transport. Digital from 5 October 2026, with no grace phase (Ley 9/2025, eighth transitional provision). |
| Scope | Consignment note: domestic transport. CMR: international carriage. | International carriage between countries applying the eCMR Protocol. | Interior transport: domestic and cabotage inside Spain. Not required for international carriage. |
| Format | Paper or electronic; the DeCA rules do not govern its format. | Electronic, under the eCMR Protocol. | Native PDF of at most 5 MB, with a QR to an HTTPS direct-download URL with no credentials. A scan is not a DeCA (Resolución, sections Segundo and Tercero). |
| Kept for | Not set by the DeCA rules. | Not set by the DeCA rules. | At least one year, by both the contractual shipper and the actual carrier (Resolución, section Segundo.4). |
| What the inspector sees | On the international leg, the convention document the driver carries. | Whatever the eCMR platform shows; in Spain it cannot be demanded as the control document. | The PDF on a phone or a printed copy with the QR; the officer scans the QR and downloads the PDF (Resolución, section Séptimo). |
Can the consignment note or the CMR serve as the DeCA?
Yes, on conditions. Article 5 of Orden FOM/2861/2012 says the control document is free-form, and the Ministry accepts any layout designed for other transport documents — consignment notes, the ADR document, the waste identification document, SANDACH — provided it:
- contains every article 6 item, including the contractual shipper's NIF and the actual carrier's NIF;
- identifies the contractual shipper and the actual carrier expressly and separately; and
- meets the technical requirements of the Resolución of 5 June 2026: native PDF, QR and direct-download URL.
Two warnings. Using the CMR layout for a domestic haul does not mean the CMR Convention applies. And a scanned consignment note, however complete, is not a DeCA: the Resolución declares scans and images invalid (section Segundo.2). The scan can be the source the data is read from; the DeCA is generated as a native PDF from that data.
Dangerous goods: ADR document and DeCA
These are two separate obligations: the transport document of chapter 5.4 of the ADR and the administrative control document of Orden FOM/2861/2012, which must be electronic. They may travel as two separate documents or combined in one PDF. If combined, the document must contain every article 6 item, identify the contractual shipper and the actual carrier separately, meet the Resolución of 5 June 2026 (section Octavo) and needs no signature (Ministry DeCA FAQ).
Frequently asked questions
What is the DeCA?
The DeCA (Documento electrónico de Control Administrativo) is Spain's long-standing road-freight control document — the one in Orden FOM/2861/2012 — in electronic form. It travels with each consignment of public road freight inside Spain so inspectors can check the service data. It is not a contract: the consignment note and the CMR remain separate documents. (Orden FOM/2861/2012, article 1; Ministry DeCA FAQ.)
I run international transport. Do I need a DeCA or an eCMR from October?
Neither, for the international leg. International transport uses the documents of the conventions Spain has signed (the CMR). The eCMR is not mandatory. (ROTT, article 222; Ministry DeCA FAQ.)
And cabotage inside Spain?
Yes, cabotage needs a DeCA. A leg loaded and unloaded inside Spain by a company from another State is interior transport for this purpose. It is judged leg by leg: the same truck can run Lyon–Zaragoza under CMR and Zaragoza–Seville under a DeCA in the same week. (ROTT, article 222; Resolución of 5 June 2026, preamble; Ministry DeCA FAQ.)
I already use a consignment note, eCMR or ADR document. Can it serve as the DeCA?
The format can, provided it contains every article 6 item with the contractual shipper and actual carrier identified separately, and meets the technical requirements (native PDF, QR, URL). Using the CMR layout for a domestic haul does not make it a CMR transport. For dangerous goods, the ADR document and the DeCA may sit in one electronic PDF. (Orden FOM/2861/2012, article 5; Resolución of 5 June 2026, section Octavo; Ministry DeCA FAQ.)
Does the DeCA change what goes in the document?
No. The format changes, the content does not. The eight items in article 6 of Orden FOM/2861/2012 stay: contractual shipper (name, NIF, address), actual carrier (name, NIF), origin and destination, nature and weight of the goods, special circulation permit where applicable, date, registration plate (tractor and semi-trailer for an articulated unit) and any remarks a party asks to record. (Orden FOM/2861/2012, article 6; Ministry DeCA FAQ.)
What must the DeCA file look like?
A native PDF of at most 5 MB, generated from structured data (scanning or photographing paper is not valid), with creation and modification timestamps in the metadata and a QR code printed in the PDF itself pointing to the document's unique URL. The URL must be HTTPS, must download the PDF directly, and must not ask for a username, password or any intermediate click. Any domain will do. (Resolución of 5 June 2026, sections Primero.3, Segundo.1–3 and Tercero.)
Sources: DeCA FAQ of the Ministry of Transport and Sustainable Mobility (in Spanish); Resolución of 5 June 2026 (BOE-A-2026-12784); Orden FOM/2861/2012 (BOE-A-2013-154), articles 1, 4, 5, 6 and 7; Ley 9/2025 (BOE-A-2025-24545), eighth transitional provision; Real Decreto 1211/1990 (ROTT), article 222. The answers follow the published text; they are not legal advice. Last reviewed: 15/09/2026.
Next step
Mudravia generates the DeCA as a native PDF with a QR from the consignment note you already have, on paper or as a PDF. It prepares the document; it does not submit it to any authority. If you want to see it on a real case, write to us.