Electronic consignment note (e-CMR), Ley 9/2025 and the digitalisation of special transport: how we apply AI to regulatory compliance at PASTOR

On 5 October 2026, paper stops being a valid administrative control document for public road freight transport in Spain. Ley 9/2025 of 3 December on Sustainable Mobility, published in the BOE on 4 December 2025, sets the date with a ten-month transition from entry into force. Spain becomes the first EU Member State to mandate a digital control document, ahead of Regulation (EU) 2020/1056 (eFTI), applicable since 21 August 2024, with phased deployment through 2027 and a 2029 review of whether to make electronic issuance mandatory for companies.

October 2026 is the starting line of a longer transformation, not the finish line. The transformation began with Spain's ratification of the Additional Protocol to the CMR Convention on the electronic consignment note in 2011, and most EU Member States are today party to that same protocol. Operationally, the format of the control document matters less than what comes next: the possibility, and the pressure, to digitalise the rest of the regulatory-compliance file in special transport. The sector rarely says it out loud, but the regulatory complexity of special transport with indivisible cargo and dangerous goods has grown beyond what one person's working memory can hold. At PASTOR, we have built the internal tool this operation now demands.

e-CMR, Ley 9/2025 and the digital control document: what changes on 5 October 2026

Three documents are worth distinguishing, since everyday conversation tends to confuse them:

• The administrative control document is the one regulated by Orden FOM/2861/2012 of 13 December, in development of article 222 of the ROTT. It identifies the effective carrier, the contractual shipper, the cargo, origin and destination, date and number plates, and must accompany every shipment. This is the document that Ley 9/2025, specifically its Eighth Transitional Provision, requires to be issued in electronic format only from 5 October 2026.
• The electronic consignment note (e-CMR) is the international consignment note regulated by the Additional Protocol to the CMR Convention, done in Geneva on 20 February 2008. Spain deposited its Instrument of Accession on 11 May 2011; the Protocol entered into force for Spain on 9 August 2011. The e-CMR has been valid in Spain since then, on a voluntary basis, for international operations. Most EU Member States are today party to the Protocol. What Ley 9/2025 and European eFTI change is not the legal validity of the e-CMR, but its move from option to standard practice under administrative pressure and interoperability requirements.
• The national consignment note is the one regulated by Ley 15/2009 on the inland freight transport contract (LCTTM), complemented by Orden FOM/1882/2012. It is not directly affected by Ley 9/2025, but mandatory digitalisation of the control document pulls the sector towards full digitalisation of the commercial file.

The substantive change from 5 October 2026 is straightforward. The paper control document is no longer valid. Issuance and retention must be digital, with a minimum one-year retention period and integrity and legibility guaranteed. The signature must be advanced electronic under Regulation (EU) 910/2014 (eIDAS). The document must be available for inspection by the DGT, the Agrupación de Tráfico de la Guardia Civil, the Mossos d'Esquadra and the regional or local police, immediately, via QR code or web service.

Legal responsibility for formalising the document is split between the effective carrier and the contractual shipper. Failure to hold the document in a valid format is classified as a serious infringement under arts. 138–146 of the LOTT (as developed by the ROTT), with fines. When the conduct falls within Annex I of the ROTT, or when the Repeat-Offender Index (IRI) threshold set by regulation is reached, the company's good repute is also at risk.

At European level, the framework is Regulation (EU) 2020/1056 on electronic freight transport information (eFTI). Adopted on 15 July 2020 and applicable since 21 August 2024 for its main provisions, eFTI deploys progressively. Throughout 2027, every authority across the Union will have to accept electronic information submitted by companies through certified eFTI platforms. In 2029, the European Commission will review whether to make electronic issuance mandatory for companies, not just acceptance by authorities. Spain is not waiting for 2029. It moves ahead with Ley 9/2025.

What the digitalisation of the control document does not change

For an ordinary transport operation, digitalising the control document closes the loop: issuance, signature, transit, delivery, retention, all electronic. For a special-transport operation, the control document is one piece of a file, and not even the most complex piece. The rest stays largely paper mixed with digital.

What special transport keeps processing beyond the control document:

• The Complementary Circulation Authorisation (ACC), in generic, specific or exceptional category according to the parameters of the combination, processed by the DGT when the itinerary is inter-regional or by the SCT when it runs entirely within Catalonia. The electronic offices of both administrations now allow digital processing; in practice, many files still rely on supporting documentation in mixed format.
• The feasibility and road-safety study, endorsed by a chartered engineer, required when rear overhang exceeds 3 metres or when the combination parameters trigger a specific procedure. As standard practice, the professional endorsement is still issued manually.
• ADR documentation for dangerous goods: shipper's declaration, labelling, written emergency instructions, UN38.3 certificates for lithium batteries, specific driver training. Some Union States already operate in electronic format via eFTI; Spanish alignment is advancing progressively.
• Specific accreditations to circulate inside restricted areas: the Special Authorisation of the Centro de Servicios al Transporte at the Port of Barcelona, accreditations for industrial plants with their own access control, municipal authorisations for night circulation in urban areas.
• Coordination with traffic authorities: application for accompaniment by the Agrupación de Tráfico de la Guardia Civil or the Mossos d'Esquadra with a minimum of 72 hours' notice, communication with the Guàrdia Urbana for critical urban stretches, alignment with municipal services when scheduled traffic closure applies.

Transport digitalisation advances in layers. The administrative control document is the first mandatory layer, but a special-transport operation's file comprises six or seven more documents, with different administrative owners, different processing lead times and different levels of digitalisation. By October 2026, a special-transport operation will still mix paper and electronic formats, depending on the component. The operator who only meets the control-document obligation has solved one piece. The problem is bigger.

The real complexity of the gestor de transporte

The person responsible for closing the file and signing is the gestor de transporte, regulated by arts. 111 and 112 of the ROTT and by Real Decreto 70/2019. At PASTOR, this is a full-time role. The gestor is legally responsible for the regulatory compliance of every operation the company performs. In special transport with indivisible cargo and dangerous goods, the gestor must simultaneously master eight distinct, interconnected technical disciplines:

1. Access to the profession and corporate regime. LOTT (Ley 16/1987 on the Organisation of Land Transport), ROTT (RD 1211/1990), RD 70/2019. Requirements of good repute, professional competence and financial capacity to exercise the activity.
2. Technical vehicle regime. RGV (RD 2822/1998), with particular attention to Anexo IX, which regulates special vehicles: maximum dimensions, masses, configurations, specific ITV card.
3. Circulation regime. RGC (RD 1428/2003), with particular attention to Anexo III, which regulates the circulation conditions of special transport: private pilot vehicle for width above 3 metres or length above 20.55 metres; accompaniment by authority officers for width above 5 metres.
4. Specific special-transport regime. Instrucción 16/V-90 de la DGT of 17 March 2016, regulating the procedure for granting the ACC; feasibility study endorsed by a chartered engineer; generic, specific and exceptional categories according to the parameters of the combination; DGT jurisdiction versus SCT jurisdiction.
5. Dangerous goods. ADR 2025 (European Agreement concerning the International Carriage of Dangerous Goods by Road, revised every two years) and RD 97/2014 (Spanish transposition). UN3090, UN3480, UN3481 and UN3536 for different lithium-battery configurations; UN1202 for diesel; UN1965 for LNG (liquefied natural gas); transport categories; packing instructions; placards-labels; qualified ADR safety adviser.
6. Driving and rest times and tachograph. Regulation (EC) 561/2006 on driving times, rest periods and breaks; Regulation (EU) 165/2014, amended by Regulation (EU) 2020/1054 (Mobility Package), on the digital tachograph and smart tachograph v2; AETR Agreement for operations with third countries.
7. Transport contract and documentation. LCTTM (Ley 15/2009), Orden FOM/1882/2012 (consignment note), Ley 9/2025 (Sustainable Mobility), Orden FOM/2861/2012 (administrative control document), CMR Additional Protocol 2008 (e-CMR), Regulation (EU) 2020/1056 (eFTI).
8. Sectoral and territorial. Regulation of the Servei Català de Trànsit (SCT); regional decree-laws on circulation and energy; Catalonia's Decreto-ley 22/2025, passed after the April 2025 blackout, which reorders the processing of energy projects (batteries included) and affects the BESS equipment logistics flow; municipal ordinances for night circulation, low-emission zones and specific dangerous-goods restrictions in urban areas.

To give a sense of scale: the official professional-competence syllabus for the gestor de transporte distributes across eight modules around seventy principal regulatory texts — organic laws, ordinary laws, royal decrees, ministerial orders, European regulations and international conventions. That is the baseline applicable to any operator of goods transport. For an operator of special transport with indivisible cargo, dangerous goods and Catalan operations, the base corpus expands with additional specific regulation: RD 198/2010 on special vehicles, the full ADR with its biennial revisions, recent Catalan decree-laws, ministerial orders for ongoing updates. Several hundred articles directly relevant to daily operation. The ADR is revised every two years. European regulations are amended periodically. Catalan regulation has added decree-laws at a rate of several a year since the April 2025 blackout. Ley 9/2025, passed in December 2025, introduces changes that come into force on various dates up to 2027.

Stated plainly: no professional, however experienced, can simultaneously hold the current version of all this regulatory corpus in their head. Human working memory does not work that way. And in special transport, a documentation error can invalidate an ACC, trigger a serious sanction for an ADR document with the wrong UN number, or expose the shipper to civil and criminal liability the contract did not cover.

The concrete costs of error:

• Wrongly categorised ACC: administrative rejection, weeks of delay, full repetition of the procedure, with lead times of up to three months for exceptional authorisations.
• ADR document with the wrong UN number: vehicle immobilisation at a regional border or at a roadside check, sanction for serious infringement, possible temporary withdrawal of authorisation.
• Feasibility study without current endorsement: invalidation of the operation, sanction to the gestor and to the company.
• Driver without current ADR Class 9 training: very serious infringement, vehicle immobilisation, sanction that can affect the company's good repute.
• Repeated sanctions reaching the Repeat-Offender Index threshold: loss of good repute and, with it, risk to the transport authorisation under the regime in arts. 116–120 of the ROTT (RD 70/2019).

This is not a theoretical compliance problem. It is the daily operational risk of any special-transport operator.

How we apply AI to regulatory compliance at PASTOR

At PASTOR, we decided some time ago that regulatory compliance in special transport had grown beyond what human working memory can sustain safely. The problem is not capability but the volume and speed of change of the applicable corpus. We chose to build an internal tool that supports documentary verification without replacing the gestor's judgement.

What PASTOR's internal assistant does:

• It has the complete corpus of the eight disciplines loaded: current legal texts, updates, recent amendments, relevant case law, administrative criteria published by the DGT and the SCT.
• It answers specific queries from the gestor de transporte. Faced with a question of the type "what is the current wording of Anexo IX del RGV applicable to a hydraulic modular combination with rear overhang above 3 metres", the assistant returns the article, the date of the last amendment, the applicable complementary provisions and the known administrative interpretations.
• It cross-references between disciplines. A BESS operation imported through the Port of Barcelona triggers queries in four distinct disciplines (special-transport regime, dangerous goods, control document, port and Catalan regulation), and the assistant articulates them in a single structured report.
• It flags inconsistencies in the file. If the combination length figure in the feasibility study does not match the figure in the ACC application, the assistant flags it before the file goes out.
• It flags what has changed. The ADR 2025 revision introduces modifications relative to ADR 2023; the assistant identifies them when the gestor consults a provision that has been updated.

What the assistant does not do:

• It does not decide. When a provision admits several interpretive readings, the assistant offers them with their grounds (administrative doctrine, case-law criteria, literal wording) and leaves the choice to the gestor de transporte.
• It does not sign. The eIDAS-compliant advanced electronic signature on the control document, the feasibility study, the ACC application and any communication with the administration is placed by the gestor de transporte. Their signature, their legal responsibility, their name on the file.
• It does not act outside the regulatory-consultation scope. It does not generate the ACC application on the DGT or SCT site. It does not send documentation to the client. It does not communicate with authorities. It is a consultation and verification tool, not an action tool.

Three examples of daily use:

DGT/SCT crossover. A special transport leaving the Port of Barcelona bound for Cuenca needs SCT authorisation on the Catalan stretch and DGT authorisation on the rest. The gestor consults the assistant on each authority's documentary requirements, the minimum notice periods (in the post-Decreto-ley 22/2025 context for operations with energy-sector equipment), the jurisdictional change points and the documentation that must travel with the file on each stretch. The assistant returns the information in structured form; the gestor articulates the two applications and signs.

Recent regulatory change. A regional decree-law modifies the sectoral regime applicable to a cargo category. The assistant identifies PASTOR operations under way or under negotiation that may be affected and asks the gestor to review them operation by operation. The gestor decides which are actually affected, which procedures need updating and what to communicate to the affected shippers.

New cargo class. PASTOR is about to operate a UN3536-classified BESS container for the first time. The gestor consults the complete requirements: driver's Class 9 certificate, shipper's declaration with official designation, updated lithium-battery labelling, written emergency instructions adapted to the product, tunnel restrictions with specific ADR codes, security plan under Chapter 1.10 of the ADR where applicable. The assistant returns it structured; the gestor articulates the operating procedure and signs it.

Why this matters to the shipper:

• Lower probability of administrative invalidation of contracted operations, because the file goes out complete the first time.
• More predictable lead times, because the application–correction–resubmission cycle shrinks.
• Solid documentary traceability under inspection, because every decision has its regulatory basis recorded.
• Consistency between similar operations, because regulatory interpretation does not depend on which professional in the team prepares each specific file.

The signature is still human. The memory is not.

What AI does not resolve in special transport

Regulatory consultation is one domain where a computational tool outperforms human memory alone. The physical side of transport is not that domain.

Still human and mechanical:

• The driver with ADR Class 9 licence and specific special-transport training who drives the tractor unit with the modular combination behind.
• The operations team that decides the hydraulic modular configuration, the number of axle lines, the mass distribution, the conventional or extendable low bed, the procurement of SPMT when needed for final manoeuvres in urban works.
• The crane that unloads the BESS container or the transformer on the plot.
• The pilot vehicle that escorts the combination in urban areas, and the officer of the Agrupación de Tráfico de la Guardia Civil or the Mossos d'Esquadra accompanying when the parameters require it.
• The chartered engineer who signs the feasibility study after physically driving the proposed itinerary and photographically documenting the critical points.

Operational judgement in the field is still human:

• The driver who decides in real time whether a curve has clearance for the combination in transport position, or whether to wait for the municipal works narrowing the passage to finish.
• The operator who assesses axle-mass distribution when the plot ground has an undocumented irregularity and reorganises the modular's position on the spot.
• The PASTOR site manager who tells the shipper that the planned unloading window slips by four hours because the contractor's crane has broken down and the replacement is arriving later.

The relationship with the shipper is still human:

• The conversation with the client's logistics director when the schedule needs adjusting.
• The negotiation of the deadline when the other party's administrative file has slipped.
• Managing the exception when something does not match the forecast and a commercial decision has to be taken in an hour.

In special transport, the computational tool does better with what is repetitive, exhaustive and regulatory. It does not handle, and we do not intend it to handle, what requires physical judgement, commercial judgement or civil liability. That boundary, at PASTOR, is clear.

Beyond the control document: the special-transport digitalisation roadmap 2026–2028

What is coming in the next few years:

• 5 October 2026: mandatory electronic administrative control document in Spain. First EU Member State to legislate the obligation.
• Throughout 2027: full applicability of the European eFTI framework. Member State authorities will have to accept regulatory information submitted by companies through certified eFTI platforms. Alongside this, mandatory extension to the digital waybill and to real-time systems for schedules and incidents, contemplated in other provisions of Ley 9/2025, is expected.
• 2029: the European Commission will evaluate whether to extend the obligation to electronic issuance by all companies, not just to acceptance by authorities. If the evaluation is favourable, paper disappears from the eFTI framework.

Alongside this European calendar, national and regional administrations are digitalising their electronic offices for processing ACCs, endorsed studies, ADR declarations and communications with traffic authorities. Ports are digitalising their Port Community Systems: the Port of Barcelona has progressively integrated with the TMS of its regular carriers.

The special-transport operator that reaches 2028 with a fully digital flow (control document, ACC, endorsed studies, ADR declarations, communications with authorities, port-system integration, real-time traceability for the shipper) will be the reference operator for industrial companies. The one that gets there with paper still mixed in will be left with the shrinking pool of operations that can still be processed that way.

How we approach this at PASTOR

Sixty years of family tradition in special transport from Catalonia, plus the internal digital infrastructure that supports the operation. That is the honest version of PASTOR in 2026: not nostalgic operators resisting digitalisation, not newcomers who have just discovered AI. Special-transport operators with sixty years of practice who recognise when an internal tool adds value without displacing responsibility.

What is already operational:

• Digital control document with eIDAS-compliant advanced electronic signature, ready for the 5 October 2026 obligation and in voluntary use before that date.
• e-CMR for international operations, valid in Spain since 2011 via the CMR Additional Protocol and integrated into the daily operational flow.
• Internal regulatory-consultation assistant for the gestor de transporte, described in this article.
• Integration with the shipper's systems via TMS or ERP when the shipper requests it.
• Operational traceability for every operation: dispatch record, route milestones, unloading, delivery signature.

What we are still building out:

• Complete digitalisation of the ACC file, in coordination with administrations that already allow fully electronic processing.
• Progressive integration with the Port of Barcelona's port system in its latest version.

What we do not automate, and do not plan to:

• The gestor de transporte's signature on legal documentation. It is manual, personal and traceable to a specific person with a name, professional qualification and legal responsibility.
• The operational decision at the head of each project. It is taken by the operations team (engineers, gestor, technical director), not by the system.
• The shipper relationship. It is a human interlocutor, not a self-service portal.

When 5 October 2026 arrives, the digital control document is already integrated into the flow. When the shipper needs to verify the regulatory compliance of an operation, the file goes out complete the first time, with the legal grounds of every decision recorded. When a new cargo class or regulatory change appears, the team identifies it before it reaches the shipper's schedule. The shipper holds a single point of contact: ours.