Deferments

Is the moratorium compatible with the contribution exemptions granted to companies affected by the DANA?

The moratorium will be incompatible with the exemptions of 100% of the company contribution for common and professional contingencies and concepts of joint collection, granted to companies with a contribution account code with their place of business in the localities listed in the annex to Royal Decree-Law 6/2024, which have seen or see the development of their normalised activity impeded or limited, to which a temporary employment regulation plan (ERTE) is authorised due to force majeure, with respect to workers with a suspension or reduction of working hours.

Is the moratorium compatible with the extension of the regulatory payment period for social security contributions and for joint collection?

No, the moratorium will be incompatible with the extension of the regulatory payment period for social security contributions and joint collection concepts. Requests for a moratorium will result in the non-application of the extension of the regulatory payment period for social security contributions and for joint collection.

What is the deadline for submitting applications for deferral or moratorium for self-employed people whose place of residence or place of business is in those localities and who are covered by any social security scheme?

The request for deferral must be submitted, directly by the interested parties or through their authorised agents to act in the RED System, before the first ten calendar days of each of the regulatory deadlines for payment corresponding to the instalments accruing between November 2024 and February 2025, that is, between November 2024 and February 2025:

From 1 to 10 December 2024 for the October 2024 contributions for self-employed workers under the Special Scheme for Seafarers and for the November 2024 contributions for self-employed workers under the Special Scheme for Self-Employed Workers.
From 1 to 10 January 2025 for the November 2024 contributions for self-employed workers under the Special Scheme for Seafarers and for the December 2024 contributions for self-employed workers under the Special Scheme for Self-Employed Workers.
From 1 to 10 February 2025 for the December 2024 contributions for self-employed workers under the Special Scheme for Seafarers and for the January 2025 contributions for self-employed workers under the Special Scheme for Self-Employed Workers.
From 1 to 10 March 2025 for the January 2025 contributions for self-employed workers under the Special Scheme for Seafarers and for the February 2025 contributions for self-employed workers under the Special Scheme for Self-Employed Workers.

Applications may be submitted through the electronic registration service for requesting deferral of payment of Social Security debts at the Social Security e-Office, to which a link will be made available as soon as the option of requesting these special deferrals is available from 1 December 2024.

The application for a moratorium must also be submitted before the end of the first ten calendar days of each of the statutory payment deadlines for the instalments for the months of December 2024 to March 2025.

What is the time limit for making deferral or moratorium requests for companies with a contribution account code whose place of business is in the localities listed in the Annex to Royal Decree-Law 6/2024?

The request for deferral must be submitted, directly by the interested parties or through their authorised agents to act in the RED System, before the first ten calendar days of each of the regulatory deadlines for payment corresponding to the instalments for the months of October 2024 to January 2025, that is to say:

From 1 to 10 December 2024 for the October 2024 instalments
From 1 to 10 January 2025 for November 2024 instalments
From 1 to 10 February 2025 for December 2024 instalments
From 1 to 10 March 2025 for January 2025 instalments

The aforementioned applications may be submitted through the electronic registration service for requesting deferral of payment of Social Security debts at the Social Security e-Office. A link to this service will be made available when the option to apply for these special deferrals will be available from 1 December 2024.

The application for a moratorium must also be submitted before the end of the first ten calendar days of each of the statutory payment deadlines for the instalments for the months of November 2024 to February 2025.

Is it possible to request and obtain a moratorium and deferral in the payment of social security contributions and joint collection concepts?

No, the deferral will be incompatible with the moratorium, so that applications for deferral relating to periods for which a moratorium has also been applied for will be deemed not to have been submitted when the applicant has been granted a moratorium.

Can self-employed people, included in any social security scheme, delay the payment of social security contributions and for joint collection?

Self-employed workers whose place of residence or activity is in the affected localities, regardless of the Social Security scheme in which they are included, may request and obtain a moratorium of up to one year without interest on the payment of Social Security contributions and items of joint collection, the accrual of which takes place between December 2024 and March 2025.

Can the companies concerned delay the payment of contributions?

As an alternative to the deferral of payment, companies with a contribution account code whose place of business is in the localities listed in the annex to Royal Decree-Law 6/2024 may request and obtain a moratorium of up to one year without interest on the payment of Social Security contributions and joint collection items, which accrue between November 2024 and February 2025.

Have any special arrangements been made for the deferral of payment of contributions that may be requested by companies and self-employed workers seriously affected by the DANA?

Companies with contribution account codes whose place of business is in the affected localities may request a deferral in the payment of Social Security contributions and for joint collection items, which accrue between October 2024 and January 2025, provided that they are up to date with their Social Security obligations and have no other deferral in force.

Self-employed workers whose place of residence or place of business is in these localities, included in any Social Security scheme, may also request a deferral in the payment of Social Security contributions and for joint collection items accrued between November 2024 and February 2025, provided that they are up to date with their Social Security obligations and have no other deferral in force.

These deferrals will have the following, more beneficial, particularities:

The application of an interest rate of 0.5%.
The deferral shall be granted by means of a single decision.
It shall be amortised by monthly payments and shall determine a repayment period of four months for each monthly instalment requested, not exceeding a total of 16 monthly instalments.
The first payment shall be made as from the month following the month in which the decision authorising the deferral is issued.
The request for this deferral will determine that the debtor will be considered to be up to date with their Social Security obligations, with respect to the contributions affected by it, until the corresponding resolution is issued.

Deferrals

Companies under any scheme and self-employed workers under the Special Scheme for Self-Employed Workers and self-employed workers under the Special Scheme for Seafarers who continue with their activity can apply for a deferral at a reduced interest rate of 0.5% (compared to the interest rate of 4.065% established in general).

Who can apply for it?

Companies having contribution account codes with a place of business in the localities concerned, and
Self-employed workers from the Special Scheme for Self-employed Workers and self-employed workers from the Special Scheme for Seafarers, with their place of residence or activity in the affected localities.

They are up to date and have no other deferral in force.

Contributions that can be deferred

Companies included in any Social Security scheme, as well as self-employed workers included in the Special Scheme for Seafarers, can request a deferral in the payment of contributions corresponding to the months of October 2024 to January 2025.
Self-employed workers included in the Special Scheme for Self-Employed Workers (RETA) can request a deferral in the payment of the contributions corresponding to the months of November 2024 to February 2025.

Application period
Between 1 and 10 December 2024, it will be possible to request the deferral on contributions corresponding to October 2024, in the case of companies and self-employed seafarers, or November 2024, in the case of self-employed workers included in the RETA.

Subsequently, between the 1st and 10th of each following month, deferrals can be requested for subsequent months – for example, between the 1st and 10th of January 2025, deferrals can be requested for November, in the case of companies and self-employed workers in the Special Scheme for Seafarers, or for December in the case of self-employed workers in the RETA.

How to apply
Applications may be submitted by the self-employed worker of any Social Security Scheme, by means of the electronic registration service for requesting deferral of payment of Social Security debts at the Social Security e-Office, or from the IMPORTASS portal, in their own name or by proxy. The RED authorised party may submit the application through the electronic register. The possibility to apply for these special deferrals will be available from 1 December 2024.