January 2026
Gemma Fabregat, Of Counsel at Sagardoy, reviews four recently approved provisions introducing significant changes in employment law.
In addition, she provides an updated overview of the main legislative initiatives, regulatory projects and transposition processes currently under way which may have an impact on employment and Social Security matters throughout 2026, without prejudice to their possible amendment, suspension or lapse during the legislative process.
1. Royal Decree-Law 16/2025, of 23 December
Measures to address situations of social vulnerability and urgent measures in taxation and Social Security
Royal Decree-Law 16/2025 extends and adjusts a broad set of social, employment, Social Security and tax measures in a context of budgetary extension, continuing the legislative sequence initiated in 2022 to address situations of social and economic vulnerability.
From an employment and Social Security perspective, the regulation concentrates its impact on three main areas: pensions and public benefits, Social Security contributions, and urgent employment measures, together with significant additional provisions and legal amendments of a structural nature.
2. Royal Decree 1189/2025, of 26 December
Company-based programmed training and certain subsidies in the field of employment and work-based training
Royal Decree 1189/2025 introduces significant amendments to the regime governing vocational training for employment, with the aim of strengthening control over training contribution rebates applied by companies and regulating new economic allowances linked to participation in training activities.
From a corporate perspective, the key development lies in the new wording of Article 18 of Royal Decree 694/2017. The limits and conditions for applying Social Security contribution rebates are systematised, accounting identification obligations and document retention requirements (for a period of four years) are reinforced, and monitoring and control measures are intensified, which must cover at least 10% of the public funds allocated to training. Any irregularities detected may result in the full or partial repayment of improperly applied rebates, together with late-payment interest, and the corresponding labour inspection action.
3. Order TES/1573/2025, of 31 December
Registration and deposit of collective agreements, collective employment agreements and equality plans
Order TES/1573/2025, of 31 December, updates the content of Annex 2 to Royal Decree 713/2010, of 28 May, on the registration and deposit of collective agreements, collective employment agreements and equality plans (Official State Gazette of 3 January 2026).
Order TES/1573/2025 updates the content of Annex 2 to Royal Decree 713/2010, which regulates the statistical templates that must accompany applications for the registration and deposit of collective agreements, collective employment agreements and equality plans in the REGCON register.
4. Order TES/1582/2025, of 30 December
Vocational training for employment in the labour sphere, in relation to the training offer of the competent authorities and its funding
Order TES/1582/2025, of 30 December, amends Order TMS/368/2019, of 28 March, which implements Royal Decree 694/2017, of 3 July, developing Law 30/2015, of 9 September, regulating the Vocational Training for Employment System within the labour sphere, with regard to the training offer of the competent authorities and its funding, and establishing the regulatory bases for the granting of public subsidies for that purpose (Official State Gazette of 6 January 2026).
Order TES/1582/2025 introduces relevant adjustments to the regulation of vocational training for employment, updating Order TMS/368/2019 within the framework of Law 30/2015 and the recently enacted Employment Act 3/2023.
EMPLOYMENT AND SOCIAL SECURITY LEGISLATIVE MONITORING – 2026
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Directives pending transposition
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National legislative initiatives at an advanced stage
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Annual or regulatory legislative developments
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Institutional initiatives and regulatory policy lines
