The Spanish Club of Directors of Institutional Relations and Communication, in collaboration with the professional services firm KPMG, has launched its new institutional programme by analysing the regulatory, operational and reputational impact caused by the failure to ratify Royal Decree-Law 21/2026 of 25 August on transparency and integrity in the activities of interest groups.

The repeal of the legislation by the Congress of Deputies on 16 September 2026 leaves a significant gap in the Spanish regulatory and institutional landscape. This legislative setback highlights the complex parliamentary dynamics currently at play and places Spain, once again, at the bottom of the list of major European economies in terms of developing a formal and uniform regulatory framework for lobbying activities.

Impact on European funds and public integrity

The text presented by the Government sought to fulfil a dual fundamental objective: to provide the State with a structured ethical framework for interactions between public authorities and the private sector, and to fulfil the commitments made in the Recovery, Transformation and Resilience Plan (PRTR) to safeguard the disbursement of EU funds linked to milestones in democratic regeneration.

The centrepiece of the decree-law provided for the creation of a State Register of Interest Groups, which would be public and mandatory, designed to monitor the regulatory footprint, oversee the agendas of senior officials and enforce a system of penalties with fines of up to 40,000 euros for very serious offences.

Following an analysis carried out in conjunction with experts from KPMG, the Club has warned of the immediate operational and institutional consequences of this parliamentary rejection:

1. Loss of momentum in institutional transparency: The more than 250 registrations formalised during the brief period in which the legislation was provisionally in force have now come to a standstill, undoing the progress made in ensuring the explicit traceability of public agendas and the interaction of lobby groups.
2. Risk to the receipt of European funds: The repeal directly jeopardises EU budget allocations conditional upon the implementation of effective mechanisms for public governance, anti-corruption and transparency in decision-making.
3. Regulatory vacuum vis-à-vis the European Union: Unlike the directives and frameworks in force within EU institutions or among other European partners, public affairs firms and consultancies in Spain will continue to operate under a regime of voluntary self-regulation or marked regulatory fragmentation across the autonomous communities.

The need for a Regulatory Footprint Act with parliamentary consensus

The outcome of the vote places the public administration and the business community at a strategic crossroads. To regain lost ground and guarantee legal certainty for the sector, the Spanish Club of Directors of Institutional Relations and Communication considers it essential to reopen the legislative process by introducing a draft bill negotiated comprehensively in the Spanish Parliament.

The club emphasises that only a cross-party consensus — which clearly defines the representative nature of employers’ organisations and trade unions as opposed to commercial interest groups — will enable the passage of the much-needed ‘regulatory footprint law’ that institutions and society are calling for, in order to bring Spain into line with international standards of integrity.