Labour Measures - Royal Decree-Law 25/2026

Affected companies and dismissals (Article 36.1)

Companies receiving direct aid under this Royal Decree-Law are prohibited from making employees redundant until 31 December 2026 on grounds of force majeure or for economic, technical, organisational or production-related reasons arising from the crisis in the Middle East.

Failure to comply entails repayment of the aid received and the dismissal being declared null and void.

Permanent intermittent employees and cooperatives (Articles 36.2 and 36.3)

For permanent intermittent employment contracts, the same grounds may not be used to justify either the end of the period of activity or the failure to call employees back to work until 31 December 2026.

In cooperatives, until 31 December 2026, general assemblies are prohibited from permanently reducing jobs or changing the proportion of professional qualifications on economic, technical, organisational or production-related grounds, or on grounds of force majeure, by exercising the powers provided for in Article 85.1 of Law 27/1999.

Mobility plans and retention of aid (Article 37 and Articles 26.1 and 26.2 of Law 9/2025)

Companies receiving aid that have workplaces with more than 200 employees, or more than 100 employees per shift, must review their obligation to have a sustainable commuting plan in place. Failure to comply with this obligation entails repayment of the aid received.

Law 9/2025 of 3 December on Sustainable Mobility (published in the Official State Gazette (BOE) on 4 December 2025), as currently in force, establishes a deadline of twelve months from its entry into force: 5 December 2026. The plan must be negotiated with the legal representatives of the employees.

Temporal application (Ninth Final Provision)

The labour measures apply from 1 October 2026, with no specific retroactive effect. The restrictions set out in Article 36 expire on 31 December 2026.