From mobility plans to boardroom representation: Spain's latest employment law developments

Legislation updates

Key employment provisions of Royal Decree-Law 7/2026 (RDL 7/2026): sustainable mobility plans and restrictions on dismissals

On 22 March, the new RDL 7/2026 entered into force, introducing urgent measures to support sectors most affected by fuel price volatility. 

From an employment perspective, the main developments are as follows.

The requirement to implement sustainable mobility plans has been brought forward by one year. Companies must now have these plans in place by 5 December 2026. These plans must promote active mobility, the use of public transport, low-emission mobility and remote working.

As these plans must be negotiated with workers’ legal representatives, we recommend initiating preparations early to ensure compliance and avoid potential risks. Companies benefiting from any of the support measures provided under RDL 7/2026 may not carry out dismissals, cease operations or reduce headcount on economic, technical, organizational, production-related or force majeure grounds linked to the energy crisis until 30 June 2026.

Updates to working time recording obligations 

The Spanish government is drafting a new Royal Decree introducing additional requirements regarding working-time records. According to the current draft, the system used to record working hours must be fully digital, traceable, tamper-proof and remotely accessible to the Labour Inspectorate. 

The new regulation is expected to be approved in April, so companies should review their existing systems to ensure they meet the forthcoming requirements and avoid potential penalties.

New regulations on the hiring of interns

The Draft Internship Statute introduces new obligations and restrictions on the hiring of interns. The main measures include:

• the number of interns may not exceed 20% of the workforce;
• companies must prepare a specific training plan for each intern; and
• interns may not exceed the maximum number of working hours established under the new framework

In addition, interns will be entitled to the same treatment as employees with regard to travel and subsistence allowances, working-hours limits, rest periods, holidays, public holidays and protection against harassment.

The draft also introduces a stricter penalty requiring that companies review and adapt their work placement programmes to prevent “fake interns”. Non-compliance may lead to fines of up to EUR225,018. Monitoring is expected to be stricter. The Ministry of Youth has launched an anonymous complaints hotline through which interns may report irregularities. These complaints will be forwarded directly to the Labour Inspectorate, increasing the likelihood of inspections.

Other relevant news

Government proposal to grant workers representation on management bodies 

The Ministry of Labour has opened negotiations with CC.OO. and U.G.T. to strengthen workers' participation in both corporate decision-making and ownership structures. Among the proposals under discussion is a system whereby worker representatives would hold between one-third and one-half of the votes on boards of directors, depending on the size of the workforce. 

The proposal also includes the creation of employee investment funds, financed through a levy on corporate profits, to enable employees to acquire shares in their companies. Specifically, the draft framework envisages mandatory employee ownership of 2% of the capital in companies with more than 25 employees, increasing to up to 10% in companies with more than 1,000 employees.

Recent case law

A worker’s temporary incapacity cannot affect their right to receive a bonus

A recent Supreme Court ruling confirms that, although calculating a bonus in proportion to the time actually worked (and reducing annual targets accordingly) is not discriminatory, companies may not exclude periods of temporary incapacity from the minimum time required to qualify for the bonus.

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