Business law
Published on October 2nd, 2026
In my view, filling in the information-document template that Spain's State Public Employment Service (SEPE) has just published, exactly as it stands, is not enough to comply with the Royal Decree. The form asks for less than the law in four sections and has no space to show that the employee received it, which is what the employer will have to prove the day someone asks. The template answers to the first additional provision of Royal Decree 723/2026, which from October 5th requires employers in Spain to inform employees in writing before the relationship begins.
Status as of October 2nd, 2026. The template is already on the SEPE page on contract types, as a fillable PDF, in Spanish and in the other co-official languages of Spain. There is no English version, so the quotations below are my own translation of the Spanish. I read the Spanish and Catalan versions in full and compared them with the Royal Decree as published in the BOE (Spain's Official State Gazette). If the SEPE changes the document, this note will need review.
The first additional provision gave the SEPE the job of producing the template. Its second paragraph adds that publishing it does not condition the enforceability of the information obligations. Nothing else I found in the Royal Decree obliges anyone to use it or treats the duty as fulfilled for whoever does. Article 6.1 only asks for one or more written documents containing all the required data, so the form helps but the content of article 3.2 is what counts.
It runs to seven fillable pages that follow the order of article 3.2. The sections that article 3.3 lets an employer settle by reference to the law or the collective agreement carry an asterisk, exactly those and no others, with a reminder that the reference must be precise enough to identify the provision that applies. For a small company this is the most useful part, since it shows where a cross-reference is allowed without inviting one where it is not, as with the cause of a fixed-term contract, the identification of the collective agreement or the equality block.
Training is the clearest case. The Royal Decree asks the employer to inform the employee of the right to training provided by the company, with no condition attached (article 3.2.i). The template instead asks about the training to be provided "in the event that it is mandatory for performing the job", my translation of "en el supuesto de que sea obligatoria para el desempeño del puesto de trabajo". An employer who answers "not applicable" on the ground that no training is mandatory in the company will have left out what the rule does ask for.
Algorithmic or automated decision systems raise the same problem. Article 3.2.k) requires the employer to say that such systems exist and, if they set or change working conditions, to describe their parameters, criteria and operating rules. The heading in the template mentions only their existence and leaves a single box, where a yes or a no covers a small part of what is required.
With the collective agreement the gap is in the data. Article 3.2.o) calls for each agreement to be identified by its code, its date of publication in the official gazette, its period of validity and, where relevant, its ultra-activity (the continued application of an agreement after it has formally expired). The template asks only which agreement applies, so writing "the offices and law firms agreement" is not enough. It cannot be resolved by cross-reference either, because article 3.3 leaves this section out.
Social Security is where the difference weighs least. Article 3.2.p) adds to the collaboration system the managing or collaborating body the company has chosen, the voluntary improvements to Social Security benefits and any pension plans and funds promoted for the staff. The box stops at the system. As article 3.3 allows a cross-reference here, the gap shows mainly when the company has improvements or plans of its own, which have to be recorded even though the box does not ask for them.
Article 6.2 requires the company to keep proof that the information was sent or received. The form ends with the place, the date and the signature of the company's representative, with no room for the employee's acknowledgment. A document signed only by whoever hands it over shows what the company said and not what the other side received, so it needs a receipt line or an acknowledgment collected by another means that leaves a record.
Nor does the form have any section for recording a change in conditions, although the first additional provision refers to article 5. Each change will have to be documented separately, with the same requirement of proof and at the latest on the day the change takes effect (article 7.3). The template itself says that the completed pages "must" be signed in the left margin "for greater legal certainty" (in Spanish, "para mayor seguridad jurídica"). The Royal Decree does not demand it, but it costs nothing and helps as evidence.
I start from the SEPE template as a skeleton, which orders the content well and flags the cross-references correctly. I fill in the collective agreement, the Social Security body, the training and the automated systems the company actually uses, then I add the receipt line. The employee receives it before starting work, with the acknowledgment in the personnel file from that same day.
How I work on these matters is described in the business area. What changes with the Royal Decree and what does not I set out in the note on Royal Decree 723/2026. What has to be handed over, section by section, is in the guide to the mandatory information when hiring.
Editorial responsibility: Carles Jiménez, attorney-at-law (Barcelona Bar No. 34.946). This note was prepared with the assistance of artificial-intelligence tools and reviewed and approved by the author before publication.
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