
Spain – March 2026 The Spanish government has approved RoyalDecree-Law 7/2026 of 20 March, establishinga comprehensive response plan to addressthe crisis in the Middle East. Rules Applicable to Fixed‑discontinuousEmployees The same dismissal-related restrictions are extended tofixed-discontinuous employees. Therefore, the grounds cited in the previous section cannotbe used to justify the end of the activity period, nor the failureto recall the employee until 30 June 2026. Background and Purpose of the Legal Alert The purpose of this legal alert is to provide an overview of themain measures introduced by the Royal Decree-Law 7/2026of 20 March, which approves the Comprehensive ResponsePlan to the Crisis in the Middle East. This ensures that companies benefiting from public aid do notavoid the employment-maintenance obligation by modifyingthe seasonal activity cycle of these workers. In light of the above, before proceeding with any dismissaluntil 30 June 2026 based on ETOP grounds or force majeurearising from the situation that the relevant measures areintended to address, it is advisable to verify any direct publicaid received and confirm that such aid does not trigger theaforementioned prohibition on dismissals (for example, directaid for the road transport sector, which is expected to be verycommon). This regulation has been adopted by the Spanish governmentas an urgent response to the economic and geopoliticalconsequences arising from the recent escalation of theconflict in the region, particularly its impact on energymarkets, inflationary pressures and the stability of essentialsectors. Although the bulk of the Royal Decree-Law focuses onenergy, fiscal and industrial measures, it also introducesseveral provisions with significant implications for labor law,and, in particular, the employment protection. We would be pleased to discuss the implications of thisdevelopment with you and to assist with any immediatequeries you may have. The Royal Decree-Law entered into force on the day followingits publication in the Official State Gazette (BOE), meaning21 March 2026. Contacts Key Employment-related Measures Ignacio RegojoPartner, MadridT +34 91 426 4804M +34 647 545152E ignacio.regojo@squirepb.com Prohibition of Dismissal for CompaniesReceiving Public Aid Companies benefiting from direct public aid are prohibitedfrom dismissing employees on economic, technical,organisational or production-related (ETOP) grounds, or forcemajeure, arising from the situation caused by the crisis in theMiddle East. Juan NasarreDirector, MadridT +34 91 426 4866E juan.nasarre@squirepb.com Any dismissal carried out in breach of this prohibition must beclassified as null and void, and obliges the company to repaythe aid received.