Law 25/2005 introduces important changes to mandatory insurance, including the future requirement for insurance for personal mobility vehicles (PMVs), such as electric scooters.
Introduction
The year 2025 brought a key reform to the insurance sector. With the transposition of Directive (EU) 2021/2118 through Law 25/2005, Spain updated its Law on Civil Liability and Insurance in the Circulation of Motor Vehicles (LRCSCVM). This reform expands the concept of a motor vehicle, redefines the fact of circulation, and, for the first time, establishes mandatory insurance for light personal vehicles. In this post, we explain clearly and concisely the most relevant points that will affect drivers, owners, and insurance companies.
1. Redefinition of key concepts
The law updates the concept of liability, linking it to the risk of driving, not simply to that of operating. This consolidates the objective nature of this liability.
Motor vehicles are also redefined to include any self-propelled land vehicle that exceeds certain speed limits (25 km/h) or weight limits (25 kg). The requirement for a registration or driving permit for this classification is eliminated.
The fact of circulation extends to any use consistent with the transport function, even if the vehicle is stopped, regardless of the terrain or the purpose of the journey.
2. New insurance obligations
The obligation to take out civil liability insurance is extended to:
– Electric-assist bicycles with speeds exceeding 25 km/h.
– Light vehicles of category L1eB and others with advanced auxiliary propulsion.
– Light personal vehicles (LPVs), such as electric scooters, provided that: – They are registered with the DGT (Directorate General of Traffic). – They have a vehicle registration certificate. – They bear a license plate or identification tag.
These vehicles must have insurance covering: – €6,450,000 for personal injury. – €1,300,000 for property damage.
Important: Mandatory insurance for PMVs will not come into effect immediately, but will instead be enforced when the regulations governing their registration and identification are published. This regulation must be approved by January 2, 2026.
3. Exceptions and particularities
The following are exempt from the insurance obligation:
– Trailers under 750 kg.
– Vehicles that have been decommissioned or are not intended for transport.
– VMP for people with reduced mobility.
– Pedal-assisted bicycles up to 25 km/h and motor less than 250W.
Intentional uses, sports competitions on closed circuits, or use in restricted areas (airports, ports, etc.) are also not considered "traffic events."
4. Administrative measures and additional guarantees
– Insurers must issue accident certificates within a maximum of 15 days.
– The insurer may not oppose exclusions to the victim other than those expressly provided for by law.
– The Insurance Compensation Consortium extends its coverage to situations excluded from compulsory insurance, provided that no financial guarantee has been provided.
5. New compensation limits and update of the scale
The new minimum limits for civil liability coverage are set at: – €6,450,000 for personal injury. – €1,300,000 for property damage.
Likewise, the amounts and criteria for the compensation scale have been updated, which could lead to an increase in premiums and adjustments to the sector's combined ratio.
It will also impact compensation for workplace accidents and the need to establish a sufficient sublimit per victim for employer liability.
6. Transitional period
For vehicles that are now considered "motor vehicles" under this reform, a six-month period is established from the date of publication in the Official State Gazette (BOE) to obtain mandatory insurance. During this time, they will not be penalized, although they will be considered "uninsured vehicles" for the purposes of the Consortium.
Vehicles with motor vehicles (VMPs) will be required to purchase mandatory insurance once the corresponding regulations come into force, which must be approved before January 2, 2026.
Conclusion
The reform of the LRCSCVM strengthens victim protection and adapts the legislation to new modes of mobility. For insurers and industry professionals, this represents both an opportunity and a challenge: products, procedures, and commercial strategies will need to be adapted to this new regulatory reality before 2026.
