Alicia Koplowitz leaves Indra and Amadeus, bets on Repsol and Aena and tweaks her foreign portfolio

The basic regulation of SICAVs in Spain is already "closed" following the 2021 anti-fraud tax reform, and as of today, there is no new specific law on SICAVs under processing. The regulatory agenda has shifted towards horizontal reforms of collective investment institutions (IIC) and capital markets (draft bills) and towards regulatory simplification via CNMV circulars. The updates that indirectly affect SICAVs are mainly related to supervision, transparency, and investor information, as well as adjustments in the tax treatment of their operations in the Personal Income Tax (IRPF). Meanwhile, CNMV data shows a very reduced SICAV sector after the 2022 reform, with some stabilization but far from its previous weight.

Current regulatory framework for SICAVs and IICs

At the corporate and supervisory level, SICAVs are framed within Law 35/2003, on Collective Investment Institutions, and its Regulation approved by Royal Decree 1082/2012, which develop the regime for investment companies and funds, their managers, and custodians (Law 35/2003, IIC Regulation). Closed-end collective investment entities and their managers are regulated by Law 22/2014, which in turn modifies aspects of the IIC Law (Law 22/2014).

This regulatory framework has been recently adjusted by Royal Decree 816/2023, which modifies the IIC Regulation and removes, among others, certain provisions to adapt the regulation to the latest European legislation (Royal Decree 816/2023).

On the tax front, the SICAV regime is mainly structured around Law 27/2014 on Corporate Tax, but the major shift came with Law 11/2021 on measures to prevent and combat tax fraud, which tightened the conditions for SICAVs to access the reduced rate and special regime (Law 11/2021).

Current situation of SICAVs after the anti-fraud reform

The impact of Law 11/2021 is very clear in CNMV data. In its 2023 Annual Report, the regulator highlights that since the reform came into force in January 2022, 1,831 SICAVs have been deregistered (641 in 2023 alone): the number dropped from 2,280 entities in 2021 to 450 in December 2023. Assets fell from 28,502 million to 14,311 million euros, and the number of investors from 75,213 to 46,020 (CNMV 2023 Annual Report).

In its report on non-bank financial intermediation, the CNMV also emphasizes that the average leverage of investment funds and SICAVs is moderate, around 19% of assets (gross exposure), well below regulatory limits, indicating a prudent risk profile in this segment (IFNB report).

Supervision has remained active: for example, the CNMV sanctioned Bankinter Gestión de Activos with 300,000 euros for failing to verify that the liquidation fees of six SICAVs under its management were equal to or more favorable than market fees and for not having prior authorization from the shareholders' meeting, qualifying the infringement as "serious" based on Law 35/2003 (Bankinter sanction for six SICAVs).

Recent executive reforms on collective investment

In the last two years, the Ministry of Economy and the CNMV have promoted regulatory and secondary reforms affecting all IICs (and therefore the ecosystem in which SICAVs also operate):

• Securities lending by funds and investment companies: a 2025 ministerial order allows Spanish IICs to temporarily lend shares, bonds, ETFs, or other securities to supervised financial entities, with limits on percentage of assets, diversification requirements for borrowers, and liquid guarantees whose value exceeds that of the lent securities. The Ministry highlights that the measure improves returns for participants and aligns the Spanish framework with the European one (Ministry of Economy note, Demócrata article on securities lending).
• Statistical information and reporting: the CNMV consulted in 2025 a new circular on statistical requirements for IICs and venture capital (2025 statistical consultation) and later approved Circular 3/2025, which sets new statistical reporting models for IICs, ECR, and EICC and introduces a specific statement on participants (Circular 3/2025).
• Deposits, net asset value, and custodian functions: in 2024, the CNMV opened consultation on a draft circular modifying Circular 11/2008 (venture capital accounting), Circular 4/2016 (custodian functions of IICs and entities regulated by Law 22/2014), and Circular 6/2008 (net asset value and operational aspects of IICs), adapting success fees to ESMA guidelines and digitizing information submission (2024 circular consultation).
• Key Investor Information Documents (KIIDs): in 2025, the CNMV reviewed the KIIDs of IICs and venture capital entities to verify their compliance with the European Regulation on Packaged Retail and Insurance-based Investment Products (PRIIPs) (2025 KIID review).

In July 2026, the CNMV took a further step in simplification: it initiated consultation on a draft circular modifying four circulars to reduce and clarify periodic public information obligations of IICs, adjust internal control rules of managers, and update prospectuses when there are regulatory changes, also repealing nine obsolete circulars. The hearing process is open until September 18, 2026 (CNMV consultation 07/13/2026, Demócrata news).

Legislative reforms under processing affecting collective investment

At the legislative level, there is no specific bill or draft law on SICAVs under processing, but there are broad initiatives on capital markets and collective investment:

• Draft bill for transposition of European rules on securities markets: approved in first round by the Council of Ministers on March 24, 2026, this draft explicitly modifies Law 35/2003 on IICs, Law 22/2014 on venture capital, Law 5/2015 on promotion of business financing, and Law 6/2023 on the Securities Market. Its objective is to modernize the Spanish framework, facilitate access of companies (especially SMEs) to non-bank financing, reduce listing costs, introduce multiple voting shares, and strengthen the asset management industry, improving information and reducing conflicts of interest for retail investors (Council of Ministers report).
• Draft bill on collective investment and securities markets in public consultation: the “I Want to Influence” section of Demócrata reports that the Ministry of Economy has opened a public consultation on a “Draft Law modifying various rules on collective investment, capital companies, business financing, securities markets, and investment services,” part of the financial transposition package (April 21 consultations, April 7 consultations). No further details on the articles are available, but it is expected to also adjust aspects of the IIC regime.

Additionally, the Government’s Annual Regulatory Plan includes a future “Law for the transposition of regulations and directives in the field of capital markets,” which also points to new modifications of Law 35/2003 and the collective investment ecosystem, although still in the planning phase (Annual Regulatory Plan).

Tax changes and Personal Income Tax (IRPF) related to SICAVs

After the major adjustment in 2021, recent changes regarding SICAVs are more technical and focused on the IRPF. The 2025 Income Tax Campaign (to be filed in 2026) introduces new specific boxes to declare capital gains derived from ETFs and SICAVs and facilitates the automatic transfer of information on these operations (AEDAF analysis, explanation of 2025 Income Tax changes).

According to consulted sources, there is no concrete government proposal under processing to again modify the tax regime of SICAVs beyond these declaration adjustments. Recent tax discussions have focused more on other vehicles (SOCIMI, green taxation, incentives for affordable housing, etc.), as shown, for example, by the debate on the SOCIMI regime in the Senate (SOCIMI debate).

Summary: processing status and pending reforms

In summary, the “processing status” of SICAV regulation is characterized by:

• A base framework already reformed (Law 11/2021) that has caused a sharp decline in the number of SICAVs and is not being reopened in Parliament.
• An ongoing legislative agenda focused on adapting Law 35/2003 and Law 22/2014 to new European market regulations and strengthening the role of IICs in financing the real economy, without specific measures announced to either relax or tighten SICAVs again.
• A continuous reform via CNMV (circulars under consultation or recently approved) to simplify obligations, adjust success fees, improve statistical information, and investor transparency.
• Window-dressing tax adjustments in the IRPF that refine the declaration of income from SICAVs, but without a new structural reform of their tax regime.

No further information is available from consulted sources on specific parliamentary, government, or group initiatives aiming to again change the basic SICAV regime in the short term. Political and regulatory attention is shifting towards capital market competitiveness, regulatory simplification, and promoting collective investment as a financing channel, rather than towards a new “SICAV reform.”

The National Securities Market Commission (CNMV) is the state authority responsible for authorizing, registering, supervising, inspecting, and, where appropriate, sanctioning collective investment institutions (IIC) — funds and investment companies — and their managers and custodians. These functions are exercised with the aim of ensuring market transparency, proper price formation, and investor protection, according to the Law 6/2023 on Securities Markets. In the specific field of IICs (including investment companies like Morinvest, if they have that legal nature), the central framework is in Law 35/2003 on Collective Investment Institutions and its regulation approved by Royal Decree 1082/2012, complemented, for closed-end vehicles, by Law 22/2014.

General framework of the CNMV

Law 6/2023 establishes the CNMV as the reference supervisor of securities markets and investment services in Spain, with the mission to ensure transparency, market integrity, and investor protection. This “framework” law grants the CNMV the classic powers of a modern financial supervisor: authorization, continuous supervision, inspection authority, intervention, and a broad sanctioning regime, as well as competencies in information and client conduct matters.

Authorization and registration of investment companies

In the specific field of collective investment institutions, Law 35/2003 establishes that the CNMV is the competent body to authorize the constitution project of IICs and to register them in its official registers. The preamble of the law states that Title II contains the “basic common provisions” for access to the activity, explicitly indicating that the CNMV resolves authorization requests within a maximum period (with positive administrative silence if exceeded). This includes:

• Investment companies (SICAV or other forms admitted by applicable regulation).
• Investment funds, which are separate assets managed by a management company under the supervision of a custodian.
• Management companies of IICs and custodians, which must also be authorized and registered by the CNMV.

Continuous supervision, inspection, and intervention

The final part of Law 35/2003 describes a block of “conduct, supervision, intervention, and replacement rules” applicable to management companies, custodians, and investment companies that do not fully delegate their management. Combined with Royal Decree 1082/2012, this means the CNMV can:

• Require periodic information and detailed financial statements from IICs, managers, and custodians.
• Review investment policies, concentration limits, and risk diversification.
• Conduct on-site or documentary inspections on activities and internal controls.
• Adopt intervention or replacement measures of governing bodies when there is a serious risk to investors or proper market functioning.

Sanctioning authority

The CNMV has a specific sanctioning regime in IIC matters, set out in Title VI of Law 35/2003, which classifies infringements as minor, serious, and very serious for breaches of conduct rules, information, or investment limits, among others. It can impose fines, public reprimands, suspension or revocation of authorizations, and disqualify administrators and executives. For closed-end vehicles (venture capital and other closed entities), Law 22/2014 reinforces this scheme for venture capital entities and their managers, also under CNMV supervision.

Investor protection and information

Investor protection is a central axis. Law 35/2003 emphasizes:

• Transparency obligations and conduct rules to prevent conflicts of interest.
• Recognition of minimum rights of participants, such as access to customer service, the client ombudsman, or the Investor Protection Commissioner.
• Requirement of standardized information documents (such as the “key investor information document” developed by Royal Decree 1082/2012), comparable among funds from different member states.

Under Law 6/2023, the CNMV can also intervene in areas such as advertising of complex products or client classification, further strengthening protection.

Cooperation with other authorities

Royal Decree 1082/2012 highlights the need to strengthen cooperation, consultation, and information exchange among competent authorities, especially due to the expansion of cross-border activity of IICs and managers. In practice, the CNMV cooperates with:

• Supervisors of other EU member states within the framework of the IIC and manager “passport.”
• European Securities and Markets Authority (ESMA), to which Law 6/2023 and European regulation assign coordination functions and, in some cases, direct supervision of certain data service providers.

In summary, any investment company that qualifies as a collective investment institution in Spain, such as Morinvest might be, falls fully within the CNMV’s supervisory perimeter, covering from its authorization and registration to possible sanctioning, including prudential and conduct supervision aimed at safeguarding the investor.

Alicia Koplowitz appears in sources as a major businesswoman investor who channels her wealth mainly through the SICAV Morinvest and her philanthropic activity through the Alicia Koplowitz Foundation. Her trajectory, as reflected in the economic press, is today more linked to diversified wealth management and social projects than to direct management of operating companies. Traditionally, she has invested in international equities (especially technology and large multinationals), some Spanish stocks, and has promoted initiatives in mental health and disability. No complete business biography (early stages, past positions) is available in these sources, but rather a fairly detailed snapshot of her current role as a major investor and philanthropist.

Main vehicle: the SICAV Morinvest

The newspaper Demócrata places Morinvest as Alicia Koplowitz’s main investment vehicle. An article on the SICAV ranking indicates that Morinvest, “of businesswoman Alicia Koplowitz,” reaches assets of 616 million euros, placing it among the largest Spanish investment companies by size, according to Demócrata in a report on major SICAVs (article on SICAVs).

In a later piece, focused specifically on recent portfolio moves, Demócrata updates Morinvest’s snapshot and values its assets at 659 million euros, showing a large and growing SICAV (Demócrata report on Morinvest). The same information emphasizes that it is a SICAV controlled by Alicia Koplowitz, which reports its positions to the CNMV and acts as a professionalized family office.

Sectors traditionally invested in

1. Spanish stock market and listed companies

Morinvest’s recent portfolio shows that its direct exposure to the Spanish stock market is limited in percentage but diversified by sectors. In Spain, Demócrata highlights:

• Indra, a defense and technology company, where Morinvest entered with an investment of 557,000 euros to acquire 11,475 shares, approximately 0.006% of the capital, representing only 0.08% of the SICAV’s portfolio (investment in Indra).
• Exit from Cellnex, a telecommunications infrastructure operator, after selling a position valued at 141,000 euros.
• Exit from Proeduca Altus, an online university education holding (including UNIR), in which she had a position valued at 28.7 million euros before fully divesting.
• Smaller positions in Amadeus (travel software, 116,000 euros) and Banco Santander (127,000 euros).

Despite these names, exposure to Spanish equities is only about 800,000 euros, around 0.12% of the SICAV’s total assets, indicating that the traditional focus of her investment is outside the domestic market.

2. Technology and large international multinationals

The bulk of the assets is concentrated in international equities and funds, with a clear bias towards large technology companies. Among the “major international bets” listed by Demócrata are:

• Nvidia, semiconductor manufacturer and a reference in artificial intelligence chips, with more than 6.3 million euros invested (almost 1% of the portfolio).
• Amazon, e-commerce and cloud giant, with approximately 5.8 million euros.
• Microsoft, world leader in software and cloud services, with a position valued at 5.3 million euros.

These data show that, consistently, Alicia Koplowitz’s investment strategy through Morinvest is oriented towards sectors of technology, digitalization, and the global economy, complemented by a small fraction in Spanish companies in defense, telecommunications infrastructure, banking, and services linked to tourism and online education.

Trajectory and philanthropic role

Besides her investor facet, Alicia Koplowitz’s recent trajectory is closely linked to financing social and health projects through the Alicia Koplowitz Foundation. Various notes from the Community of Madrid and health articles highlight her involvement in:

• Child and adolescent mental health programs in schools, co-financed by the Foundation and the Community of Madrid, extended to Special Education centers and reaching thousands of teachers (extension to Special Education and program in 146 schools).
• Support for research projects on the impact of stress in adolescence on diseases such as depression, mentioning funding by the Alicia Koplowitz Foundation (depression research).
• Initiatives for the well-being of minors with severe neurological disorders, promoted together with other health and social entities (program for minors with neurological disorders).
• The Alicia Koplowitz Multiple Sclerosis Center in Madrid, where the Community has increased public investment by 25% (11.3 million euros between 2024 and 2026), serving as a reference for telemedicine and specialized care projects in advanced multiple sclerosis (multiple sclerosis center and telemedicine model).

Other institutional references place this center as a key place for the inclusion of people with disabilities, even hosting the Disability Awards of the Community of Madrid (disability awards), reinforcing Koplowitz’s image as a patron in the social-health field.

No further information is available in the consulted sources about the early stages of her career or specific positions in large business groups; the profile offered today by the media focuses on her role as a major investor via Morinvest and as a philanthropist in mental health, disability, and neurological disease.