Companies must submit electronic certificates via Certific@2 for wildfire unemployment benefits

The State Public Employment Service (SEPE) has issued a resolution on July 30, 2026, regulating the procedures for recognizing unemployment benefits established under Royal Decree-Law 20/2026. This new regulation provides the operational framework for managing extraordinary benefits for workers whose contracts are suspended or whose services are impossible to perform due to forest fires that have triggered civil protection measures.

What changes

The primary change introduced by this resolution is the mandatory digitalization and standardization of the communication process between employers and the employment administration. To ensure that workers can access the extraordinary benefits for extreme emergencies, the burden of proof regarding the legal situation of unemployment lies with the employer through specific electronic channels.

According to Article 2.1, companies are strictly required to submit a company certificate (certificado de empresa) exclusively through the Certific@2 application. This application is the authorized electronic medium for communicating labor activity data and contract statuses. The certificate must explicitly state the cause of suspension using the specific code "suspension of contract" (17).

Furthermore, the resolution establishes strict parameters for the duration of these suspensions. The period of suspension communicated by the company must not exceed a maximum of four months (Art. 2.1). In the event that the suspension period needs to be extended—provided it remains within the legal limits—the company is legally obligated to submit a new electronic certificate to reflect the updated dates (Art. 2.2).

Context

This resolution is a procedural development of Royal Decree-Law 20/2026, which was enacted to provide urgent social and labor protection in response to the increasing frequency and severity of forest fires in Spain. The legal framework seeks to mitigate the economic impact on workers in sectors highly vulnerable to environmental disasters, such as agriculture and forestry, by creating a specific "extraordinary benefit for extreme emergencies." This mechanism integrates with the existing Social Security in Spain (Seguridad Social) framework, specifically following the guidelines of the Consolidated Text of the General Law of Social Security. By regulating the specificities of the Certific@2 submission, the SEPE aims to prevent administrative delays that could leave workers without income during critical periods of environmental crisis. This regulation ensures that the extraordinary nature of the benefit is matched by an equally agile and digitalized administrative response.

Who is affected and how

SMEs and Large Companies
Any company, regardless of its size, that employs workers whose contracts are suspended due to forest fires is directly affected. The obligation is not merely to report the suspension, but to do so using the correct technical parameters. Failure to use the Certific@2 application or failing to use the specific code "17" could result in the rejection of the worker's benefit application. Companies must also manage the administrative task of re-submitting certificates if the suspension period is modified (Art. 2.2).

Individual Workers and Cooperative Members
The regulation protects employees and members of cooperatives (socias trabajadoras or socias de trabajo) who find themselves unable to perform their duties due to wildfire-related civil protection measures. These individuals are the beneficiaries of the extraordinary benefit. To access it, they must submit a formal application using the official model or the individual pre-application form available on the SEPE electronic office (Art. 3.1). The ease of access depends entirely on the employer's correct initial filing.

Agricultural and Forestry Sectors
While not a legal entity, these sectors are the most significantly impacted by the scope of this regulation. The necessity of these measures highlights the systemic risk that environmental factors pose to labor stability in these industries. Companies in these sectors must ensure their HR and payroll departments are prepared to react swiftly to wildfire declarations to meet the reporting requirements.

What to do and when

To ensure compliance and the protection of workers' rights, the following actions must be taken following the occurrence of a wildfire-related suspension:

• For Employers: Immediately upon the suspension of contracts, submit the company certificate via the Certific@2 application. Ensure the cause is marked as "suspension of contract" (17) and clearly define the start and end dates, keeping the total duration under four months (Art. 2.1).
• For Employers (Extensions): If the situation evolves and the suspension must be prolonged, a new certificate must be transmitted through the same electronic channel (Art. 2.2).
• For Workers: Once the company has submitted the certificate, proceed to the SEPE electronic office (sede.sepe.gob.es). Use the individual pre-application form or the official model (Annex I) to request the extraordinary benefit. You will need to provide the employer's name, their Social Security contribution account code, and their tax identification number (Art. 3.1).

Given the technical nature of the Certific@2 system and the specific requirements of Royal Decree-Law 20/2026, we recommend that companies consult with the professional team at BMC to ensure all electronic communications are executed correctly and to avoid potential liabilities or delays in worker benefits. For specific cases involving complex contract structures, a detailed assessment is advised.