Contractor coordination in Spain (CAE) in 2026: Royal Decree 171/2004 obligations, what the draft OHS law reform proposes and how to digitalise it
The coordination of business activities, known in Spain as CAE, covers situations in which workers from two or more companies operate at the same workplace, and extends cooperation, information and instruction duties to concurrent self-employed workers. It is governed by Article 24 of Law 31/1995 and developed by Royal Decree 171/2004, and it is one of the areas most closely reviewed by the Inspectorate in construction, industry and maintenance. In 2026 it gains further relevance: the draft reform of Spain’s Occupational Risk Prevention Law, not yet in force, proposes strengthening oversight of contracted self-employed workers and the on-site preventive resource.
What contractor coordination is and when it applies
It applies whenever companies concur at a workplace: contractors, subcontractors, maintenance, logistics, cleaning or security companies, or self-employed workers. Royal Decree 171/2004 distinguishes three positions with different obligations:
- Concurrent companies: must inform each other of the risks they generate and establish means of coordination.
- Site owner (empresa titular): in addition, informs about the risks of the site, the prevention and emergency measures, and gives instructions.
- Principal employer (when contracting its own core activity): supervises compliance with regulations by contractors and subcontractors and requires proof of the risk assessment, planning, and training and information of workers.
The joint and several liability of the principal employer for its contractors’ preventive infringements is the reason CAE generates so much documentation.
Means of coordination and contractor documentation
The means of coordination provided include the exchange of information, periodic meetings, instructions, the presence of preventive resources and the appointment of coordination officers. In practice, management concentrates on contractor documentation, which should be limited to what is necessary and relevant in view of each company’s role and the concurrent risks. Where there is a principal employer, it must obtain the written evidence required by Article 10 of Royal Decree 171/2004: the risk assessment and preventive planning for the contracted work or service, compliance with worker information and training duties, and verification of the means of coordination. Other documents (medical fitness, PPE delivery, equipment authorisations, insurance) should be requested only where a specific rule or the particular risk justifies them.
What the draft reform of Spain’s Occupational Risk Prevention Law proposes
Concurrent self-employed workers are already subject to cooperation, information and instruction duties under Royal Decree 171/2004. The draft approved on 28 April 2026, which is not in force, would strengthen oversight of self-employed workers contracted for the company’s own activity and, where a different activity is classified by regulation as hazardous and carried out at the contracting company’s workplace, would require OHS compliance to be checked. It would also require the preventive resource to remain present and exclusively dedicated while the relevant operation or process is under way. Details in our guide to the OHS law reform.
What the Labour Inspectorate checks on contractor coordination
- Existence of documented means of coordination appropriate to the risk.
- Information delivered and received between companies, with acknowledgement.
- Proof of contractors’ assessment, planning, training and information.
- Effective presence of the preventive resource when required.
- Access control, where adopted as an organisational measure: nobody works on site without the legally required documentation relevant to the activity.
CAE platforms and CAE software: how to digitalise coordination
CAE platforms were born to solve a specific problem: uploading the same documentation repeatedly to each client and manually validating thousands of documents. Modern CAE software should offer a single upload of documentation per contractor and worker, validation with rules by document type and expiry, site access control (whitelist of authorised people and equipment), information exchange with acknowledgement of receipt, self-employed worker management and a compliance dashboard by site and contractor.
Sabentis’s contractor management within its organisational management and planning modules integrates CAE with the rest of the management system: the site’s risk assessment, planning, preventive resources and safety inspections, so that contractor documentation does not live in a silo. Read more in the risk that multiplies when companies share a site and why summer stress-tests your control of who works on your site.
CAE checklist 2026
- Identify at which sites there is concurrence and the company’s position (concurrent, owner, principal).
- Define the CAE procedure: information to deliver, documentation to require, means of coordination.
- Inventory contractors, subcontractors and self-employed workers, with activity and risk level.
- Where access control is adopted as an organisational measure, verify before access the legally required documentation relevant to the activity.
- Appoint preventive resources with real presence in the activities that require them.
- Review the procedure with the draft OHS law reform in mind: oversight of contracted self-employed workers and the preventive resource.
Frequently asked questions
Is a CAE platform mandatory?
No. What is mandatory is to establish effective coordination and to be able to evidence it; a platform is one management option where volume or complexity justifies it, and it can reduce repeated document uploads.
Who is liable if a contractor fails to comply?
The contractor and, jointly and severally, the principal employer when the contracted activity is its own core activity and takes place at its site.
Does CAE apply to self-employed workers today?
Yes. Concurrent self-employed workers are already subject to cooperation, information and instruction duties under Royal Decree 171/2004; the draft, not in force, would strengthen oversight of self-employed workers contracted for the company’s own activity or for activities classified as hazardous at the contracting company’s workplace.
