Key data
| Regulation | Resolution of June 9, 2026, Joint Committee for Relations with the Court of Auditors |
|---|---|
| Publication | October 5, 2026 |
| Entry into force | Not specified |
| Affected parties | Citizens using Social Security, INSS, TGSS and Institute of Maritime Social Services (ISM) |
| Category | Social Security |
| Audited fiscal year | 2023 |
| Key deadline | December 31, 2026 (INSS reports on appointment management and human resources) |
| Regulation to be modified | Law 39/2015, on Common Administrative Procedure |
The Joint Committee for Relations with the Court of Auditors has approved a resolution that requires Social Security System bodies to reverse the trend of forced digitalization that has left thousands of citizens without adequate service, especially the most vulnerable. The resolution, published on October 5, 2026 and referenced as BOE-A-2026-20661, brings concrete mandates with deadlines and requires significant legislative changes.
For companies and labor advisors, the most relevant change is operational: procedures with the INSS and TGSS can be carried out by telephone with the same validity as at the counter, and workers or beneficiaries cannot be rejected for not having an appointment.
What does this regulation establish?
The resolution contains differentiated mandates for each body. Below are the most relevant changes broken down by entity:
| Body | Main mandate | Deadline |
|---|---|---|
| INSS | Eliminate the appointment as a mandatory requirement for in-person service | Not specified |
| INSS | Submit detailed report on appointment management and human resources by departments | December 31, 2026 |
| INSS | Equate the telephone channel with in-person service to allow requesting benefits by telephone | Not specified |
| INSS | Guarantee service in Spanish in all its offices | Not specified |
| TGSS | Improve systems for recording and analyzing citizen service data | Not specified |
| TGSS | Implement user satisfaction surveys | Not specified |
| ISM | Improve systems for recording, analyzing data and user satisfaction surveys | Not specified |
| Legislator | Modify Law 39/2015 to recognize the right to in-person service | Not specified |
The central axis of the resolution is the priority of in-person service for vulnerable groups: elderly people, those with disabilities or with low digital literacy cannot be excluded from their rights for not knowing how to use an electronic office. Progressive digitalization is promoted, but conditioned on not replacing in-person service.
The modification of Law 39/2015 is the most important structural change: if it succeeds, the right to be served in person by the Administration will be expressly recognized in the common administrative procedure regulation, which would affect all public bodies, not just Social Security.
Economic and operational impact
For companies and their HR departments, the changes have immediate practical consequences:
- Management of sick leave and benefits: if the telephone channel is equated with in-person service, workers will be able to initiate benefit procedures (temporary disability, unemployment, retirement) without traveling or depending on available appointments, reducing management times.
- Less absenteeism due to procedures: the elimination of mandatory appointments and the possibility of processing by telephone reduces the need for employees to request time off to go to the Social Security office.
- Advisors and management firms: the equating of the telephone channel can open the door to managing more procedures without the physical presence of the principal, streamlining the operations of offices with many clients.
- TGSS and contributions: the improvement of TGSS data recording and analysis systems can lead to greater detection of contribution errors, which requires companies to keep their data updated and correct.
The direct cost for private companies is zero at this stage: the mandates fall on public bodies. The impact is one of operational efficiency, not regulatory compliance with associated sanctions.
Who does it affect?
- Citizens using Social Security: workers, pensioners, unemployed and anyone who needs to manage benefits with the INSS, TGSS or ISM.
- Vulnerable groups: elderly people, those with disabilities or with low digital literacy, who are the main beneficiaries of the elimination of mandatory appointments.
- HR departments and labor advisors: who manage benefit procedures on behalf of workers or companies.
- Management firms and labor offices: that operate with the INSS and TGSS on a recurring basis.
- Maritime workers affiliated with ISM: who will see improved service quality and recording systems in their specific organization.
- INSS, TGSS and ISM: as bodies directly required to implement the changes and report to Congress.
Practical example
A 68-year-old retired female worker needs to modify her banking details for her pension payment. Until now, if she did not have a digital certificate and the nearest INSS office had a full appointment schedule for weeks, she would be blocked without being able to complete the procedure.
With the changes required by this resolution, the worker will be able to go directly to the office without an appointment and be served in person. Alternatively, once the telephone channel is equated, she will be able to call the INSS and make the data modification by telephone with the same legal validity as if she did it at the counter. In both cases, service must be provided in Spanish.
For a labor management firm that manages benefits for 200 workers of a client company, the telephone equating means being able to resolve contribution incidents or benefit requests without moving the worker or waiting weeks to get an appointment, significantly reducing the time to resolve procedures.
What should companies do now?
- Inform workers: communicate that the appointment will no longer be mandatory at INSS offices and that benefit procedures can be initiated by telephone, so they can manage their procedures more efficiently.
- Update internal HR protocols: review procedures for managing sick leave, benefits and procedures with Social Security to incorporate the equated telephone channel once it comes into force.
- Verify data at TGSS: take advantage of the improvement in TGSS recording systems to verify that the company's contribution and affiliation data are correct, anticipating greater error detection capacity by the body.
- Follow the December 31, 2026 deadline: the INSS must submit its reports on appointment management and human resources before that date. That report can anticipate changes in office and staff availability, relevant for planning end-of-year procedures.
- Stay alert to the modification of Law 39/2015: if it succeeds, the right to in-person service will be legally recognized for all public bodies, which can also affect other administrative procedures of the company.
Frequently asked questions
When can you go to the INSS without an appointment?
The resolution requires eliminating the appointment as a mandatory requirement, but does not set a specific date for this change to come into force. The mandate is approved by Congress and the INSS must implement it, but the specific deadline is not determined in the resolution published on October 5, 2026. It is advisable to follow the regulatory evolution and INSS communications.
Can Social Security benefits be requested by telephone?
Yes, that is one of the express mandates of the resolution: to equate the telephone channel with in-person service so that citizens can request benefits by telephone with the same validity as at the counter. This measure is pending implementation by the INSS.
What report must the INSS submit before December 31, 2026?
The INSS must submit before December 31, 2026 detailed reports on appointment management and human resources by departments. These reports will allow Congress to assess the actual capacity of the body to serve citizens and plan necessary changes.
What changes in Law 39/2015 with this resolution?
The resolution requires modifying Law 39/2015 on Common Administrative Procedure to expressly recognize the right to in-person service. Currently that law does not explicitly include that right. The legislative modification is mandated but has not yet occurred: it requires a separate parliamentary process.
What must TGSS and ISM improve according to this resolution?
Both TGSS and ISM must improve their systems for recording and analyzing citizen service data, and implement user satisfaction surveys. The objective is to have reliable information about the actual quality of service provided in order to correct deficiencies.
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-2026-20661