ES · Expiry & renewal tracking
Submit the safety adviser's annual report in time
Spanish companies required to have a dangerous goods safety adviser submit the adviser's annual report to the transport authority of their tax domicile's region during the first quarter of the following year, online only (Article 28.b of Royal Decree 97/2014; Order FOM/606/2018). A copy is kept for five years.
Companies required to have a safety adviser (consejero de seguridad) must submit the annual report during the first quarter of the following year to the transport authority of the autonomous community, or of Ceuta and Melilla, where their tax domicile is, and keep a copy for five years (Article 28.b of Royal Decree 97/2014). If the company ceases trading, it submits the report regardless of those deadlines.
The report is drafted by the safety advisers with a valid certificate assigned to the company for all or part of the year, and submitted by the company (Order FOM/606/2018, section three). Submission is online only (section two) and the content follows the order's annex (section four). Companies that had no dangerous goods activities that year, or only had them under ADR exemptions that do not require an adviser, are not required to submit one (section one).
If an adviser leaves the company, they issue a partial annual report for the period they were in post, using data the company must provide; the incoming adviser takes that data into account when drafting the annual report (Article 27.c and d). Before an adviser starts work, the company notifies the competent body of the appointment and areas using the form in annex 3, and of any later changes (Article 28.a).
At a glance
| Who submits it | The company required to have a safety adviser (Article 28.b RD 97/2014) |
|---|---|
| Who drafts it | The adviser with a valid certificate assigned to the company (Order FOM/606/2018, section three) |
| Deadline | First quarter of the following year (Article 28.b) |
| To whom | Transport authority of the autonomous community of the tax domicile (Article 28.b) |
| How | Online only (Order FOM/606/2018, section two) |
| Retention | Copy kept for five years (Article 28.b) |
| No activity or only exempt activity | No report required (Order FOM/606/2018, section one) |
Who is responsible?
The company submits the report and gives its advisers the information and resources they need (Article 28.b and d RD 97/2014). The adviser drafts it (Order FOM/606/2018, section three). The person submitting it must have sufficient authority to represent the company; this is deemed proven by the prior appointment of the adviser and its official notification (section three).
If the deadline passes
Failing to submit the annual report is a serious offence (Article 141.5.16 LOTT). Submitting it late, leaving out required data or not keeping it for the required period are minor offences (Article 142.7.9, 7.6 and 7.8 LOTT). Liability lies with the company required to have a safety adviser (Articles 141.5.g and 142.7.c).
Change of adviser during the year
If the adviser leaves, whether on their own initiative, the company's, or because their certificate expired, they must issue a partial report for the period worked (Article 27.c RD 97/2014). Add a second record for the expiry date of the adviser's certificate.
Tracking it with ExpirySuite
- Add one record per company or site dated 31 March, the end of the first quarter.
- Email reminders arrive 60, 30, 14, 7 and 1 day before and on the day itself. That gives the adviser time to gather the year's data and submit the report.
- The adviser can upload the submission receipt through a secure link that is valid for 14 days and needs no account.
- Assign the adviser or the office manager as responsible person; emails arrive in each recipient's language. If a date passes, managers get further reminders 3, 7 and 14 days later.
Frequently asked questions
- When is the Spanish safety adviser's annual report due?
- During the first quarter of the year after the one it covers (Article 28.b RD 97/2014).
- Where is it submitted?
- To the transport authority of the autonomous community, or of Ceuta and Melilla, where the company's tax domicile is, online only (Article 28.b; Order FOM/606/2018, section two).
- Is a report needed if there was no dangerous goods activity?
- No. Companies with no dangerous goods activity that year, or that only operated under ADR exemptions not requiring an adviser, are not required to submit one (Order FOM/606/2018, section one).
- How long must it be kept?
- The company keeps a copy for five years (Article 28.b RD 97/2014).
Sources
- Real Decreto 97/2014, operaciones de transporte de mercancías peligrosas por carretera, artículos 24 a 29 (BOE, texto consolidado)
- Orden FOM/606/2018, contenido del informe anual para el transporte de mercancías peligrosas por carretera (BOE, texto consolidado)
- Ley 16/1987, de Ordenación de los Transportes Terrestres (LOTT), artículos 141.5 y 142.7 (BOE, texto consolidado)
Last checked: Oct 1, 2026 · This page summarises official sources for general information and is not legal advice. Check the linked sources for current rules and fees.
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