Comparison
DeCA vs CMR: how they differ and when one replaces the other
Updated on September 29, 2026 · 6 min read
Short answer
- The DeCA is an administrative document: it exists so the Inspectorate can control the transport.
- The CMR is a consignment note: it proves the international transport contract and the condition of the goods between the parties.
- The DeCA covers domestic transport; the CMR covers international road transport.
- A CMR can serve as a control document if it contains all the data in article 6, under article 2.2.
- The DeCA doesn't need an electronic signature; the eCMR does need integrity guarantees to have evidentiary value.
They get confused because they end up in the same folder in the truck, and because both carry the shipment's data. But they answer different questions: the DeCA answers "can the Administration control this transport?" and the CMR answers "what was agreed, and what condition were the goods in?". Almost all the practical differences follow from that.
Differences at a glance
| DeCA | CMR | |
|---|---|---|
| Nature | Administrative control document | Consignment note: proof of the contract |
| Scope | Domestic transport in Spain | International road transport |
| Regulation | Orden FOM/2861/2012 and Resolución de 5-6-2026 | 1956 CMR Convention and its e-protocol |
| Who it serves | The Road Transport Inspectorate | The other party to the contract, in a claim |
| Minimum content | The eight letters of article 6 | The mentions in article 6 of the CMR Convention |
| Signature | No electronic signature required | eCMR requires integrity guarantees |
| Retention | At least one year (art. 9) | According to the limitation periods for the claim |
When the CMR serves as a control document
Article 2.2 of Orden FOM/2861/2012 expressly allows it, but with a condition worth taking seriously: the consignment note or other supporting documentation compliant with national, EU or international legislation serves as an administrative control document as long as it contains all the data listed in article 6.
All of it. Not most. And that's where a standard CMR falls short more often than people think: letter e), the special traffic authorisation, isn't a typical CMR mention, and letter g) requires the semi-trailer's registration in addition to the tractor's, something many formats record incompletely.
And the other way round: does the DeCA work as a CMR?
No, and that's not a limitation of the format but of the function. The CMR proves the international transport contract and the apparent condition of the goods at loading and delivery, with reservations and signatures from the parties. The DeCA isn't designed for that: it's an administrative control document, and Orden FOM/2861/2012 itself describes it that way in article 3.1.
International transport doesn't carry a DeCA
The obligation from 5 October 2026 refers to domestic public transport. If you do international transport, your document is the CMR, under the Convention's rules. What can happen is the opposite: a domestic leg of your transport may fall within the DeCA's scope.
And the eCMR
The eCMR is the CMR in electronic format, regulated by the additional protocol to the Convention. It serves a different purpose to the DeCA and has stricter requirements, because it has to support a commercial claim: it needs integrity guarantees and party identification that the DeCA doesn't require. That's why eCMR solutions cost considerably more and are aimed at companies with an ERP or TMS already in place.
If your need is meeting the Inspectorate's requirements from October 2026 and you do domestic transport, the eCMR is an oversized product for your problem.
Frequently asked questions
Does the CMR replace the DeCA?
It can. Article 2.2 of Orden FOM/2861/2012 admits the consignment note as a control document as long as it contains all the data in article 6. If any is missing, it doesn't replace it.
What's the difference between the DeCA and the CMR?
The DeCA is an administrative control document for domestic transport, required by the Inspectorate. The CMR is the international consignment note and proves the contract and the condition of the goods between the parties.
Do I need a DeCA if I do international transport?
The obligation from 5 October 2026 refers to domestic public transport. For international transport the applicable document is the CMR under the Convention.
Does the DeCA work as a consignment note?
No. The DeCA has an administrative nature under article 3.1 and isn't designed to prove the contract or the condition of the goods between the parties, which is the consignment note's function.