Discretionary passenger transport in Spain: what it is and what it requires

Discretionary passenger transport is transport carried out with no pre-established itinerary, calendar or timetable: the excursion, the wedding, a company transfer or a group trip. It is defined this way by Ley 16/1987, de Ordenación de los Transportes Terrestres (LOTT, Spain's Land Transport Act), as opposed to regular transport, which runs on fixed itineraries with pre-set calendars and timetables.

To do it in Spain you need the authorisation for public passenger transport by bus, and each service carries its route sheet (hoja de ruta), which from 5 October 2026 must be digital. Here you will find the definition, the authorisation, the paperwork for each service and how it is handled in Bus Center.

What discretionary passenger transport is

It is public passenger transport that is not tied to a fixed itinerary, calendar or timetable. The LOTT says that public passenger transport by road may be regular, discretionary or on-demand, and that discretionary transport is that carried out with no pre-established itinerary, calendar or timetable (our translation).

The third category, on-demand transport, was added by Ley 9/2025, de Movilidad Sostenible (Spain's Sustainable Mobility Act), which amended this article of the LOTT: it is transport provided on the user's request within a public-sector contract (our translation).

With that definition, an excursion, a wedding, the transfer of a company's staff or a group trip, booked for a specific date and route, are discretionary services.

How it differs from regular transport

The difference lies in what is fixed in advance. Regular transport is that carried out within pre-established itineraries and subject to pre-set calendars and timetables; discretionary transport is organised for each service (our translation).

There is another difference that matters when selling: discretionary passenger transport is, as a general rule, contracted for the vehicle's whole capacity. The law allows a regulation to admit, in exceptional cases, booking by seat with individual payment, and the LOTT regulations make this conditional on the administration's express authorisation. We explain it in organised coach trips.

What authorisation is needed

You need a public passenger transport authorisation. The LOTT says that carrying out public passenger and goods transport is subject to holding an authorisation that enables it, issued by the competent State body or, where applicable, by the autonomous community where the carrier is based, when the State has delegated that power (our translation).

For bus transport, the LOTT regulations (Real Decreto 1211/1990) require proof of the requirements of establishment, professional competence, good repute and financial capacity. And whoever applies for a new public passenger transport by bus authorisation must have at least one vehicle that, at the time of applying, is no more than two years old from its first registration (our translation).

It is the authorisation that the abbreviation “VD” refers to, which already appears in ministerial orders from 1988 that the regulations themselves list, such as the one on the national annual quota of VD authorisations. In addition, the public passenger transport authorisation enables the holder both to carry out transport and to act as intermediary in contracting it.

The route sheet for each discretionary service

Each discretionary service carries its route sheet. Orden FOM/1230/2013 (the Spanish ministerial order on the route sheet) says that all buses intended for providing public passenger transport services must travel provided with the corresponding route sheet, and exempts only vehicles assigned to a regular general-use line, or owned by a company with a regular special-use authorisation, while they run a trip of that service (our translation). Discretionary transport has no such exemption.

The route sheet records, among other data, the name and tax ID (NIF) of the carrier and of the contracting party, the origin, destination and date, the bus's registration number, the driver's name and NIF, and the nature of the service. The company keeps it for one year from the date of the service, available to the inspectorate.

From 5 October 2026 it has to be digital. Spain's Ministry of Transport explains it this way: the eighth transitional provision of Ley 9/2025, de Movilidad Sostenible, has established that on that day the goods control document and the route sheet for public passenger transport will necessarily be digital (our translation). We cover it in detail in the electronic route sheet and in which buses need a route sheet.

The classes of discretionary service

The route sheet distinguishes four classes, and it is worth choosing the right one for each service:

• Discretionary service, the general one.
• Discretionary service provided as reinforcement of a regular general-use line, identifying the service being reinforced.
• Discretionary service provided as collaboration in a regular special-use transport, identifying the transport being collaborated in.
• Tourist service.

The tourist service has its own definition in the LOTT: tourist transport is that carried out within the execution of a package trip offered and contracted in accordance with consumer protection legislation (our translation).

How a discretionary service is handled in Bus Center

In Bus Center, each service is a file that runs from start to finish: quote, sent, confirmed, completed and invoiced, with customer, route, schedule, passengers, coach and driver. The program validates every change of status and says what is missing, and a coach or a driver cannot be on two services at once.

The route sheet is issued from the service itself: a PDF with a QR code and a direct download link. It does not let you issue it half-complete: if a mandatory item is missing, it says which one and why it is asked for, and it never invents a NIF or the nature of the service. The obligation remains the carrier's: the regulations do not require a specific program, and Bus Center generates the document that is required.

Afterwards, the service moves on to the invoice without retyping. To prepare the price, see how a coach quote is prepared, and for a summary of the route sheet, see Bus Center's home page (in Spanish).

Sources consulted

Checked on 11 October 2026. We link to the original source so that you can consult the current text.

• Ley 16/1987, de 30 de julio, de Ordenación de los Transportes Terrestres (texto consolidado). BOE.
• Real Decreto 1211/1990, de 28 de septiembre, Reglamento de la Ley de Ordenación de los Transportes Terrestres (texto consolidado). BOE.
• Orden FOM/1230/2013, de 31 de mayo, normas de control en relación con los transportes públicos de viajeros por carretera (texto consolidado). BOE.
• Documento electrónico de control administrativo (DeCA). Ministerio de Transportes y Movilidad Sostenible.