What is the road transport control document and what must it show?
The control document is the mandatory supporting document proving that the performance of a road freight transport service, and contains key information such as:
- Identification of the contractual shipper (who contracts the transport service).
- Identification of the actual carrier performing the service.
- Origin and destination of the transport service.
- Description of goods transported.
- Expected dates and time of performance of the service.
- Reference or identification of the vehicle (registration plate).
- Identification of the driver.
- Price or reference to the contract of carriage. Remarks or instructions relating to the service.
Until now, this document could be managed in paper format, which caused recurring issues: loss of documents, manual errors, lack of traceability and difficulties in inspections. With Act 9/2025, digital format will be a mandatory requirement from 5 October 2026, with no single technical format mandated by the regulation, which requires them to ensure legal validity and be inspection-ready.
Who is affected by the mandatory digital control document?
The mandatory nature of the digital control document established by the Sustainable Mobility Act is not only limited to the carrier, but has an impact on all actors involved in the road freight transport chain.
Specifically, it affects transport companies, both self-employed and large fleets; logistics operators and freight forwarders who act as intermediaries or transport organisers; consignors or shippers, who are responsible for the commercial data and the goods; as well as companies with their own fleet that perform freight transport as a secondary activity.
In addition, this requirement is particularly relevant for transport cooperatives and associations, which bring together multiple carriers under a single operational framework, and for public administrations and companies participating in tenders, where regulatory compliance and traceability are critical requirements.
Who is responsible for issuing and retaining the document?
Responsibility lies with both the contractual consignor, who engages the service, and the carrier, holding the authorisation, who must ensure that it is properly issued, kept for at least one year, and inspection-ready while on the road.
Even when data is provided by the consignor or logistics operator, the carrier bears ultimate responsibility for ensuring the document exists and is accurate.
In practice, this means having reliable digital systems, accessible from mobile devices and capable of proving who issued the document, when and with what precise content.
Who is responsible for the DATA contained in the document?
Responsibility lies with the actors involved:
- Consignor / Shipper, is responsible for the accuracy of the commercial data and the goods:
- Identity of the consignor/shipper.
- Description of the goods.
- Place of loading.
- Agreed conditions of carriage (price, or contract reference, instructions, etc.).
If these data are false or incorrect, the consignor is responsible, even if they appear on a document issued by the carrier.
- Carrier, who is responsible for the transport service data:
- Identity of the carrier.
- Vehicle registration number.
- Identity of the driver.
- Start date and time.
- Place of unloading.
- Existence and correct generation of the digital document.
Inspectors will first address the carrier, as they are the ones who must carry and display the document.
Any intermediaries / transport operators involved in the operation (agencies or logistics operators) are responsible for the accuracy of the data they provide and do not exempt the carrier from their responsibility to issue and carry the document.
In short:
| Obligation to: | Responsibility lies with: |
|---|---|
| Issue the digital document | Carrier |
| Ensure accuracy of freight data | Consignor |
| Ensure accuracy of transport service data | Carrier |
| Carry the document for the duration of the trip | Carrier (essentially the driver) |
| Retain the document | Carrier |
| Provide data if acting as operator | Intermediary |
How does Logalty help to comply with the Mobility Act and the digital control document?
Logalty supports transport companies in all phases of the control document and electronic consignment note (eCMR), thus guaranteeing legal compliance, legal certainty and operational efficiency.
- Document creation and management: the document is generated using eCMR digital platforms, which can be integrated via API with the client’s systems (TMS or ERP), thus avoiding manual tasks and operational errors. When the control document, consignment note or eCMR is signed electronically, this signature must be carried out using either an advanced or qualified electronic signature. Logalty can issue qualified certificates for signing these documents, thus ensuring compliance with this regulatory requirement. We also offer a certified electronic signature service with which the signatory can carry out the signing process using a qualified or advanced signature.
- Identification and signature of the actors involved: Logalty has a solution that allows robust verification of the identity of the driver or other actors involved by reading the chip in their identification document, thereby verifying that the document belongs to them and that it has not been revoked due to loss or theft. During this process, the facial image obtained from the chip itself is displayed so that the consignor can validate that it matches the person presenting the document, ensuring that only duly identified and authorised persons can sign.
- Time stamping: In addition to the signature, eCMR platforms must apply time stamps to certify the exact time of each transport milestone (issuance, pick-up and delivery). Logalty can issue Time Stamp Certificates (TSA).
- Sending certificate and evidence: once the documentation is signed, with Logalty’s certified electronic communication services it is possible to send the document to all parties with reliable proof of sending and delivery.
- Retention and legal archiving: Finally, Logalty is able to retain and archive documents electronically and for the legally required period of time, thus guaranteeing their immediate availability in the event of inspections.
The Sustainable Mobility Act marks a turning point in road transport. The mandatory digital control document requires legal certainty, reliable technology and regulatory compliance.
Ready to comply with the Act and gain efficiency? Contact us for further information.
