Spanish Government extends ban on layoffs until December 2026 and requires the repayment of support if companies do not have mobility plans

Royal Decree-Law 25/2026 of September 29 2026 adopting and extending certain measures within the framework of the Comprehensive Response Plan to the Crisis in the Middle East, updates the social measures we analyzed in connection with royal decree-laws 7/2026 and 18/2026 (see our publications: “The Spanish Government shortens the time period for implementing sustainable mobility to work plans which will end on December 5, 2026, and adopts provisions prohibiting dismissal” and “Spanish government extends ban on dismissals until September 2026 and strengthens sustainable commuting plans”).

The main labor provisions are as follows:

• Ban on layoffs until December 31, 2026: Companies receiving direct support payments under this royal decree-law cannot lay off employees due to force majeure or for economic, technical, organizational, or production-related reasons arising from the crisis. Failure to comply will result in repayment of the support and the layoff being held null and void. This restriction also applies to the end of the period of activity for permanent seasonal workers or the failure to call them for work.
• Sustainable mobility-to-work plans: for companies required to have these plans under article 26.1 of Law 9/2025 on sustainable mobility that are recipients of direct support under the royal decree-law, failure to have a plan in place will result in repayment of the support payments they received. Please note that the deadline for having these plans in place is December 5, 2026.

*This royal decree-law remains to be ratified by the lower house of the Spanish parliament.