Ban on redundancies and changes to Mobility Plans: Guide to Royal Decree-Law 7/2026 – Crisis in the Middle East

1. The Royal Decree-Law. The rationale behind the changes.

The explanatory memorandum to the Decree-Law explains that the purpose of adopting these urgent measures is to address the economic and social consequences arising from the crisis in the Middle East. The legislation justifies the changes on the basis of, amongst other things, the international instability resulting from the conflicts, and refers to the foreseeable rise in energy costs for businesses, particularly in relation to transport, which will lead to increased mobility costs for workers.

Here at Belzuz Abogados, S.L.P., and the team of expert lawyers comprising our employment law team, we outline the main labour measures adopted by this legislation.

2. Change in the obligation to draw up a Sustainable Mobility Plan.

Sustainable mobility plans, which are mandatory for certain companies (see previous post) by the department at Belzuz Abogados, S.L.P.), must be implemented within 12 months, that is to say, generally speaking, by 6 December 2026, taking into account Recital 22 of Law 9/2025.

3. What does the ban on redundancies under RDL 7/2026 entail?

It is stipulated that companies receiving the aid provided for in the regulation may not, until 30 June 2026, carry out redundancies or cease operations, nor, in the case of cooperatives, adopt resolutions at their general meetings that entail a definitive reduction in the number of jobs or a change in the proportion of qualifications, where such measures are justified on grounds of force majeure or on economic, technical, organisational or production grounds arising from the situation regulated by that regulation.

With regard to fixed-term seasonal contracts, the aforementioned grounds shall also not justify the termination of the period of activity or the failure to call upon the worker, until 30 June 2026.

The significance of this prohibition is that the law now does specify the legal consequences of carrying out such dismissals. Article 62 of the Act states that failure to comply with this obligation will result in the repayment of the aid received and the classification of THE DISMISSAL AS NULL AND VOID.

It is worth noting that whilst the legal consequences of dismissal are regulated, the legal consequences of the end of the period of activity or the failure to call up permanent seasonal workers are not explained.

4. The aid in question.

The aid package regulated by the legislation is extensive. In the professional sphere, the following stand out:

1. a) aid intended for professionals in the agricultural sector (to cover the cost of diesel consumed by them, Art. 46),
2. b) aid for professionals in the maritime sector (Art. 61) and
3. c) aid for road transport professionals, amongst others.

In the case of the latter (which are very numerous), the measures consist of extraordinary and temporary aid to cover the cost of diesel consumed by vehicle owners:

• who are entitled to a partial refund of the Hydrocarbons Tax on diesel for professional use (Article 55).
• who, in respect of certain of their vehicles, are not eligible for the partial refund of the Hydrocarbons Tax on diesel for professional use provided for in Article 52 bis of the Excise Duties Act.

We have attached a useful link for further information on these measures.

5. Conclusion. Acceleration of the drafting of mobility plans and bans

All companies with workplaces employing more than 200 workers or 100 per shift, where the workplace is the centre of activity (Article 26 of Law 9/2025), must accelerate the drafting of sustainable commuting plans.

And in all other companies, before proceeding with a dismissal, a failure to call an employee to work, or a cessation of work activities, it must be verified whether they are benefiting from the aid indicated by the aforementioned regulation.

At Belzuz Abogados, S.L.P., as expert employment lawyers with extensive experience in providing comprehensive legal advice, we are aware of the complexity involved in interpreting this law, which, in addition to the financial support, regulates a restriction on termination for objective reasons; we therefore recommend a professional legal analysis for those companies that may be affected by this measure. Employment Law Department at Belzuz Abogados, S.L.P.

Frequently Asked Questions (FAQ)

1. Which companies may be affected by the ban on dismissals provided for in Royal Decree-Law 7/2026?

The ban affects companies receiving the financial aid regulated by the decree-law when they seek to justify dismissals on grounds of force majeure or on economic, technical, organisational or production-related grounds. Legal advisers must analyse whether the invalidity also extends to the failure to call upon and the cessation of activity of permanent seasonal employees and to persons affected by job reduction agreements in cooperative societies.

2. What is the main legal consequence if a company breaches this restriction?

As set out in the text itself, the consequence expressly provided for by the regulation is twofold in cases of dismissal: on the one hand, the repayment of the aid received and, on the other, the dismissal being deemed null and void. In other cases, the regulation does not specify this, hence the need for analysis by a qualified legal adviser.

3. What impact does this Law have on sustainable commuting plans?

The Royal Decree-Law emphasises the need to accelerate certain corporate obligations relating to sustainable commuting plans by reducing the initial deadline from 24 months to just 12.