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Spanish government extends ban on dismissals until September 2026 and strengthens sustainable commuting plans

Spain - 

The Comprehensive Response Plan to the Middle East Crisis provides that companies receiving the direct aid established under Royal Decree-Law 18/2026 may not carry out objective dismissals until September 30, 2026, and that failure to implement a sustainable commuting plan will trigger the obligation to repay the aid received.

Royal Decree-Law 18/2026 of June 29, 2026, adopting certain measures under the Comprehensive Response Plan to the Middle East Crisis, includes a series of social measures aimed at protecting employment and promoting sustainable commuting in the context of the energy crisis arising from the conflict in the Middle East.

Specifically, companies benefiting from the direct aid provided for in the legislation may not carry out dismissals on the grounds of force majeure or for economic, technical, organizational or production-related reasons arising from the circumstances that the measures are intended to address, until September 30, 2026. Any company failing to fulfill this obligation will have to repay all the aid received and the dismissal will be classed as null and void.

In the case of indefinite-term contracts for seasonal work, nor may such grounds be relied upon to justify the end of an activity period or the failure to recall employees to work, until September 30, 2026.

In addition, in the case of companies that meet the requirements set out in article 26.1 of Sustainable Mobility Law 9/2025 of December 3, 2025 (workplaces with more than 200 employees, or more than 100 employees per shift) and are recipients of the direct aid provided for in the legislation, failure to have a sustainable commuting plan in place will trigger the obligation to repay the aid received.