Coal mining quotation 2026: special deadline to pay differences in February 2027

Key data

Coal mining companies have an unavoidable appointment in February 2027: to regularize in a single payment all quotation differences accumulated during the 2026 fiscal year. The State Secretariat for Social Security and Pensions has set this extraordinary deadline through the Resolution of 16 July 2026, published in the BOE on 27 July 2026, to cover the adjustments derived from the Order ISM/727/2026, of 13 July, which approved the new normalized quotation bases for common contingencies of the Special Regime of Social Security for Coal Mining.

The mechanism is common in this regime: normalized bases are set with some delay with respect to the start of the fiscal year, which requires retroactive regularization of quotations for the current year. The novelty of this resolution is that it guarantees that this adjustment will not generate surcharges, as long as it is carried out within the special deadline enabled.

What does this regulation establish?

Order ISM/727/2026, of 13 July, set the normalized quotation bases for common contingencies applicable in the Special Regime of Social Security for Coal Mining during the 2026 fiscal year. However, its approval occurred mid-year, when companies had already been paying quotations for months with the bases from the previous fiscal year.

This creates a difference between:

• What companies have paid to Social Security since January 2026 (with old bases).
• What they should have paid according to the new normalized bases approved by Order ISM/727/2026.

The Resolution of 16 July 2026 establishes that the difference accumulated throughout 2026 must be paid in a single payment in February 2027, within the special deadline enabled. This mechanism prevents companies from incurring surcharges for late payment, which would otherwise be automatic since they have paid quotations below the final bases.

Economic and operational impact

The specific economic impact for each company depends on the difference between the previous normalized bases and the new ones approved by Order ISM/727/2026. The resolution does not publish these figures directly, but the effect is cumulative: it affects all months elapsed from January 2026 to December 2026.

From an operational perspective, companies should take the following into account:

• Accounting provision: the quotation difference is a certain liability that must be provisioned before February 2027.
• Treasury: the payment is concentrated in a single month (February 2027), which can generate a significant cash outflow if the accumulated difference is significant.
• No surcharges if the deadline is met: the special deadline eliminates the risk of surcharge for late payment, which in the general regime can reach 20% of the debt.
• Inspection risk: if not regularized within the enabled deadline, Social Security can claim the differences with the corresponding surcharges and interest.

Who does it affect?

• Companies classified in the Special Regime of Social Security for Coal Mining with active workers during 2026.
• Workers included in said special regime, whose quotation bases for common contingencies are adjusted.
• HR, payroll and administration departments of coal mining companies responsible for managing quotations.
• Labor management firms and advisors who manage quotations for companies in the sector.

Practical example

A coal mining company with 30 workers has been paying quotations for common contingencies during the 12 months of 2026 with the normalized bases of the previous fiscal year. In July 2026, the new bases are approved through Order ISM/727/2026, which turn out to be higher than the previous ones.

Suppose the monthly quotation difference per worker between the old and new bases is 50 euros (employer contribution + employee contribution). With 30 workers and 12 months, the total accumulated difference would be 18,000 euros (30 workers × 50 € × 12 months). That amount must be paid in a single payment in February 2027.

If the company does not make that payment within the special deadline enabled, Social Security may claim the debt with the corresponding surcharges and interest on arrears, significantly increasing the final cost. The special deadline is, therefore, the most efficient way to regularize without additional cost.

Note: the figures in the example are illustrative. The actual amount depends on the specific differences between the previous normalized bases and those approved by Order ISM/727/2026, which should be consulted in that order.

What should companies do now?

1. Review Order ISM/727/2026: consult the new normalized quotation bases for common contingencies approved on 13 July 2026 to know the exact amount of the differences.
2. Calculate the accumulated difference: compare the bases with which quotations have been paid since January 2026 with the new normalized bases and calculate the total amount to regularize for each worker.
3. Provision the amount: record the debt with Social Security in the accounts before the end of fiscal year 2026, so that the balance sheet reflects the actual liability.
4. Plan February 2027 treasury: the payment is single and concentrated in one month; anticipate the cash outflow to avoid liquidity tensions.
5. Make the payment within the special deadline of February 2027: make the payment within the enabled deadline to avoid surcharges for late payment.
6. Keep proof of payment: save the payment receipt as evidence for possible inspections by the Labor and Social Security Inspection.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-16350