ACT: National Inspection Actions 2026

The Labour Conditions Authority (ACT) has announced a series of national inspections to be carried out throughout 2026, targeting areas considered to be priorities:

1. Inadequate contractual ties
2. Private Security
3. Promotion of Equal Pay for Women and Men

With these initiatives, ACT intends to strengthen control over compliance with labour rules, focusing on recurring problems such as false green receipts, undeclared work and unjustified wage differences, in an effort to make the labour market more transparent and balanced.

We explain what each of these actions consists of and what the main legal obligations of employers are, so that they can anticipate risks and avoid administrative offences and sanctions.

1. inadequate contractual relationship

ACT begins 2026 with a nationwide inspection action dedicated to the inadequacy of the contractual relationship, one of the most frequent irregularities in the labour market.

This action, scheduled for the first quarter of the year, aims to strengthen control over the way in which labour relations are qualified by companies.

At stake are, above all, situations of false provision of services, as well as all forms of undeclared or under-reported work, including false internships and situations of false volunteering, even in cases where the service provider acts as a sole proprietor or through a sole proprietorship. ACT will also check the inadequacy of fixed-term contracts, as well as contracts established in the context of temporary work.

Measures to be considered by employers

For employers, this will be a key moment to review internal practices and ensure that existing relationships comply with the law.

In this context, we recommend the following

• Reviewing the contracts entered into - including fixed-term employment contracts, provision of services, temporary work, internships, among others - ensuring that their legal configuration corresponds to the reality of the work provided;
• Signalling situations in which, although the contractual form adopted does not correspond to an employment contract, typical elements of a subordinate employment relationship may be present - for example, the definition of working hours and place of work, the use of the employer's equipment and tools, integration into the company's organisational structure or the existence of economic dependence;
• Ensuring the regularity of the contributory framework with Social Security, including the correct registration of workers and the fulfilment of contributory obligations.

It should also be pointed out that the conclusion of contracts that conceal a genuine employment relationship and the consequent re-qualification of the contractual relationship may result in the amounts that would be legally owed to the workers becoming due. Furthermore, this practice constitutes a very serious administrative offence, punishable by large fines, the amount of which will be determined according to the company's turnover.

2. Private Security

During the first half of the year, a nationwide inspection programme will also be launched targeting private security organisations, with the aim of assessing compliance with their legal obligations.

As part of this initiative, the ACT will focus in particular on matters related to the organisation of working hours, remuneration and other compensation, bearing in mind the Collective Bargaining Agreements applied in the sector.

Measures to be considered by employers

• Verify compliance with labour obligations, namely by ensuring the correct display of work schedules, holiday schedules and other documents that are legally required to be displayed, as well as the timely and full payment of remuneration, including allowances and other remuneration benefits provided for in the applicable IRCT;
• Consult the guide for workers in the private security sector made available by the ACT.

3. Promoting Equal Pay for Women and Men

The inspection action, which covers nearly 4,000 employers and began in 2025, will continue throughout 2026, focusing on companies with more than 50 employees and a gender pay gap of more than 5 per cent.

These organisations are being asked to draw up and implement a pay gap assessment plan and, where applicable, an action plan aimed at eliminating the pay inequalities identified.

There is a 12-month deadline for implementing the pay gap assessment plan, after which employers must inform ACT of the results of this implementation, showing which differences are justified and correcting those that are not.

Measures to be considered by employers

• Mapping and evaluating existing jobs and their respective functional content, using uniform and comparable criteria, ensuring coherent pay structures and career progression;
• Define and implement an action plan to correct any unjustified pay differences;
• Draw up or review the remuneration policy and career progression criteria, ensuring transparency and alignment with clear and objective performance assessment systems, applicable to women and men equally.

It is important to emphasise that differences in pay without justifiable grounds are considered, for all intents and purposes, to be presumed discriminatory, and violation of the principle of non-discrimination constitutes a very serious administrative offence, punishable by high fines, with the amount to be determined according to the company's turnover.

In view of the above, it is recommended that companies carry out a structured internal review of their practices in these three areas, with a view to detecting any situations of non-compliance in good time and correcting them before any inspection intervention by the ACT.