The latest on contributions, IT and permits: key points from bulletin 11/2025

Bulletin RED 11/2025 contains several important developments for companies and employment law firms. Firstly, the special DANA deferrals provided for in RDL 6/2024 are extended, allowing for the deferral of contributions accrued between November 2025 and February 2026 (with different schedules depending on whether it is the Sea Regime or other self-employed workers) to be requested at a reduced interest rate of 0.5%. In addition, new contributions covered by this deferral may be added to a special deferral already granted, integrating them into a single resolution with specific repayment terms.

With regard to contributions, specific procedures are enabled in CASIA for the recognition of contribution periods assimilated for childbirth (art. 235 LGSS), for the purposes of applying the contribution exemptions of articles 152 and 311 LGSS. The favourable decision will include a new additional affiliation status "235" for each birth, valid for any scheme in which the worker is registered or enrols.

The bulletin also discusses the recent extension of birth and care leave: two additional weeks are added (four in single-parent families), which can be taken until the child reaches the age of 8. For events occurring between 2 August 2024 and 30 July 2025, these weeks may be requested from 1 January 2026, always with a company certificate and a maximum of 15 days' notice before the start of the leave.

In the area of temporary incapacity (TI), the obligation for companies to report the "Job position" and "Job description" in TI reports is reinforced through the FDI and the "TI Online" service of the RED System. Failure to complete these fields correctly may lead to errors (158 and 159) and a possible administrative offence, as this information is key to the medical assessment of the process.

Finally, from 2 December 2025, the INSS will begin to send all companies the IT regulatory base through the FIE file (and the FIER service), for information and review purposes, once the contribution bases have been consolidated. A new type of incident is also planned in ACRASS ("BRIT - IT Regulatory Base") to manage discrepancies between the base calculated by the INSS and that determined by the company.

Article written by the Labour Department of ECIJA Madrid.