Labour Law

Insurance collective agreement 2025-2028: what changes and how it affects your company

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Equipo Editorial CambiosLegales
23 Jul 2026 6 min 21 views

Key data

RegulationResolution of July 13, 2026, from the General Labor Directorate, registering and publishing the Collective Agreement for the sector of insurance entities, reinsurance and mutuals collaborating with Social Security
BOE PublicationJuly 23, 2026
Entry into forceAugust 12, 2026 (20 days after publication)
Agreement validityJanuary 1, 2025 — December 31, 2028
Affected partiesInsurance entities, reinsurance entities, reinsurance brokers and mutuals collaborating with Social Security
CategoryLabor Legislation
BOE ReferenceBOE-A-2026-16077
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Insurance companies, reinsurers and mutuals collaborating with Social Security have a new labor framework until 2028. The sectoral collective agreement, published in the BOE on July 23, 2026 (BOE-A-2026-16077), comes into force on August 12, 2026 and its validity starts retroactively from January 1, 2025.

For HR departments and managers in the sector, this means immediately reviewing whether current workforce conditions meet the minimums established by the agreement, and adapting existing company agreements if necessary.

What does this regulation establish?

The agreement establishes a mandatory minimum framework of working conditions for the entire insurance sector at the national level. Its most relevant structural elements are:

  • Temporal scope: Validity from January 1, 2025 to December 31, 2028. Comes into force 20 days after its publication in the BOE, that is, on August 12, 2026.
  • Mandatory minimum framework: Acts as a floor of conditions for all companies in the sector without their own agreement. Companies with a company agreement can supplement it in specific matters, but never below the sectoral minimums.
  • Prohibition of lower sectoral agreements: The signatory parties expressly commit not to negotiate sectoral agreements of scope lower than the national level, guaranteeing uniformity throughout the territory.
  • Agreed ultra-activity: If the agreement is terminated before 2028 and a new agreement is not reached, it maintains its validity during negotiation and in ultra-activity until a new agreement is signed.
  • Conflict resolution mechanisms: If a year of negotiation passes without agreement, the parties can resort to mediation and arbitration through the ASAC (Autonomous Labor Conflict Resolution Agreement).

Economic and operational impact

The direct impact of this agreement translates into several operational dimensions for companies in the sector:

  • Review of current working conditions: Companies must verify that their current conditions (salaries, working hours, leave, categories) are not below the minimums set by the sectoral agreement from January 1, 2025. Since it has retroactive validity from that date, there may be obligations that should already be in place.
  • Complementarity with company agreements: Companies that already have their own agreement must review which matters they can continue to regulate autonomously and which are fixed by the sectoral agreement as non-derogable minimums.
  • Stability until 2028: The four-year validity (2025-2028) offers predictability for labor cost planning, although salary reviews or specific conditions agreed in the agreement must be applied within the established timeframes.
  • Risk in case of termination: If any of the parties terminates the agreement, the company is not left in a regulatory vacuum: the agreement remains in force in ultra-activity, which guarantees continuity but also requires continuing to apply its conditions until the new agreement.

Who does it affect?

The agreement precisely defines its subjective scope. Included are:

  • Insurance entities
  • Reinsurance entities
  • Reinsurance brokers
  • Mutuals collaborating with Social Security

Expressly excluded are:

  • External mediators (insurance agents and brokers acting as independent natural or legal persons)
  • Senior executives (subject to Royal Decree 1382/1985)
  • Commercial service providers

If your company operates in any of the included areas and does not have its own company agreement, this sectoral agreement is directly and fully applicable from August 12, 2026.

Practical example

A mutual collaborating with Social Security that until now applied working conditions agreed individually or through previous company agreements must, as of August 12, 2026, verify that such conditions respect the minimums of the new sectoral agreement.

If that mutual has its own company agreement that regulates, for example, working hours or salary supplements, it can maintain it in matters where the sectoral agreement allows complementarity. However, in matters where the sectoral agreement sets a non-derogable minimum, the company agreement cannot establish lower conditions, although it can establish higher ones.

In the event that the mutual and workers' representatives terminate the company agreement and do not reach an agreement within one year, the sectoral agreement acts as a safety net: its conditions remain in force in ultra-activity until a new agreement is reached, avoiding a regulatory vacuum.

Do you need to monitor this and other regulations?

Consult the full details in CambiosLegales

What should companies do now?

  1. Identify if your company is included in the scope of the agreement: Confirm whether your activity fits into the categories of insurance company, reinsurer, reinsurance broker or mutual collaborating with Social Security. If you have doubts about the exclusion of external mediators or senior executives, review it with your labor advisor.
  2. Review current working conditions against the agreement: Check that salaries, working hours, professional categories and other conditions are not below the sectoral minimums. Remember that validity starts on January 1, 2025, so there may be obligations with retroactive effect.
  3. Audit your own company agreement if it exists: Identify which matters your company agreement regulates and which are now fixed as non-derogable minimums by the sectoral agreement. Adapt what is necessary.
  4. Inform the legal representation of workers: Communicate the changes resulting from the new sectoral agreement to union representatives or the works committee, if any.
  5. Plan collective bargaining until 2028: Take advantage of the four-year stability to plan labor costs. Keep in mind that sectoral agreements of scope lower than the national level cannot be negotiated during this period.
  6. Know the conflict resolution mechanisms: Familiarize yourself with ASAC as a means of mediation and arbitration in case conflicts arise during the validity of the agreement.

Frequently asked questions

When does the new collective agreement for insurance and mutuals come into force?

The agreement comes into force on August 12, 2026, twenty days after its publication in the BOE on July 23, 2026. Its validity extends from January 1, 2025 to December 31, 2028.

Which companies does the 2025-2028 insurance sector collective agreement affect?

It affects all insurance entities, reinsurance entities, reinsurance brokers and mutuals collaborating with Social Security. External mediators, senior executives and commercial service providers are excluded.

What happens if my company already has its own company agreement?

The sectoral agreement acts as a mandatory minimum framework. If your company has its own agreement, it can supplement the sectoral agreement in specific matters, but cannot reduce the minimums established by this agreement.

What happens if the agreement is terminated before 2028 and no new agreement is reached?

In case of termination, the agreement maintains its validity during the negotiation period. If a year passes without agreement, it enters ultra-activity until a new agreement is reached. Additionally, the parties can resort to mediation and arbitration through ASAC.

Can sectoral agreements of scope lower than the national level be negotiated in the insurance sector?

No. The signatory parties of the agreement have expressly committed not to negotiate sectoral agreements of scope lower than the national level, which reinforces the uniformity of conditions throughout the sector.

Official source

Consult complete regulation in official source

Notice: This article is purely informational in nature 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-2026-16077



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