Lobbies without registration but with obligations: what interest groups can do until they are registered

Under the label of the “Lobby Law”, two key pieces coexist today: the Bill on transparency and integrity of interest group activities (being processed in Congress, exp. 121/000046) and the new Royal Decree-Law 21/2026, of August 25, on transparency and integrity of interest group activities, already published in the BOE and in force. Both respond to the same lobby regulation agenda, but are at different stages.

1. Status of the bill in Congress

The Bill on transparency and integrity of interest group activities, promoted by the Ministry for Digital Transformation and Public Function, was approved by the Council of Ministers in January 2025 and sent to Congress shortly thereafter. According to the reconstructed processing:

• 01/30/2025: registration of the bill in Congress.
• 02/07/2025: qualification and admission for processing.
• The amendment period opens; this period is repeatedly extended (up to 17 times according to the press) until its definitive closure on 09/10/2025.
• 03/18/2025: total amendments are published; Vox requests the return of the bill. The Plenary rejects that amendment (32 yes, 177 no, 136 abstentions), so the text remains alive.
• In autumn 2025, the committee is constituted in the competent commission and work on the amendments begins.
• 09/17/2025: the Plenary approves the referral to Plenary (340 yes, 0 no, 6 abstentions), that is, it decides that the final vote on the committee report will not be resolved in the committee with full legislative competence, but in the Plenary of Congress.
• 09/22/2025: publication of the amendments to the articles.
• 09/25/2025: publication of the confirmation of the referral to Plenary.

Parliamentary information and Demócrata news agree that, despite these advances, the bill has not yet been approved by the Plenary of Congress nor sent to the Senate. The European Commission, in its Rule of Law report, explicitly states that the bill “has not yet been approved by Parliament” and rates progress on interest groups as limited due to political blockage.

2. Appearance of Royal Decree-Law 21/2026

Faced with this deadlock, the Government has opted for a parallel route: the Royal Decree-Law 21/2026, of August 25, on transparency and integrity of interest group activities, which Moncloa itself and the press describe as the new “lobby law.”

According to the Council of Ministers’ reference, this royal decree-law:

• Regulates, within the scope of the General State Administration and its institutional public sector, the relationship between interest groups and public officials and personnel susceptible to influence.
• Defines who is an interest group, what influence activity is, and who can be the object of such influence.
• Creates a State Register of Interest Groups, public, free, electronic, and with mandatory registration, managed by the Transparency and Good Governance Council, with data accessible through the Transparency Portal.
• Establishes a sanctioning regime for interest groups (very serious, serious, and minor infractions) and obligations of publication of agendas and contacts for public personnel.
• Provides for the preparation of a normative footprint that records the influence of lobbies in each regulatory project.
• Is based on prior parliamentary work: it starts “from the work carried out during the processing of the lobby bill in Congress” and incorporates already negotiated amendments.

The royal decree-law has been in force since its publication in the BOE (08/26/2026), but must be submitted to confirmation or repeal by Congress within a maximum period of 30 days.

3. What steps remain for “full application”

As of today, the situation can be summarized as follows:

• The Bill remains under processing in Congress, in committee phase after the closure of amendments and referral to Plenary. It has not completed:
  • Debate and approval of the committee report.
  • Final debate and vote in the Plenary of Congress.
  • Referral to the Senate, possible amendment phase or veto and, if applicable, return to Congress for veto lifting or acceptance/rejection of amendments.
  • Promulgation, royal sanction, publication as ordinary law, and eventual entry into force (generally after 20 days, unless otherwise specified).
• The Royal Decree-Law 21/2026:
  • Still requires the confirmation vote in Congress. If confirmed, the state register and the designed regime will remain in force; Congress may also agree to process it as a bill to introduce additional changes.
  • Requires regulatory and operational development (effective launch of the register, IT systems, supervision and sanction procedures) for the regulation to be fully applicable in practice.
• In parallel, the reform of the Congress Rules on lobbies continues, which regulates the relationship of interest groups with deputies and parliamentary groups and their internal sanctioning regime; this part is necessary to have a complete system within the Cortes.

In summary: the “Lobby Law” as a parliamentary bill remains stalled in Congress and has not completed its processing. However, the basic framework has already been advanced through Royal Decree-Law 21/2026, which is in force but pending confirmation and regulatory and organizational deployment to allow the interest group register and transparency obligations to operate at full capacity.

The Transparency and Good Governance Council (CTBG) is the independent body created by Law 19/2013, on transparency, access to public information, and good governance, in its Title III, to promote transparency, guarantee the right of access, and ensure compliance with good governance rules. It acts with its own legal personality and full autonomy and independence (art. 33).

1. General purpose and regulatory framework

According to art. 33 of Law 19/2013, the CTBG’s purpose is to:

• Promote transparency of public activity.
• Monitor compliance with publicity obligations.
• Safeguard the exercise of the right of access to public information.
• Guarantee observance of good governance provisions.

Its regime is completed with references made by Law 19/2013 to budgetary, contracting, asset, and administrative procedure legislation, and with its Statute, approved by Royal Decree (which does not alter the core competencies defined in the law).

2. Functions in transparency and access rights

In the field of transparency and access to information, Law 19/2013 assigns the Council and its President, among others, the following functions:

• Control of active publicity obligations of the General State Administration, verifying compliance with the publicity chapter and being able to issue resolutions ordering cessation of non-compliance and initiation of disciplinary actions (control provision cited in the legal text after modification by Law 14/2022).
• Adopt recommendations for better compliance with transparency obligations contained in the Law (letter a of the general functions list).
• Advise on transparency and access to public information (letter b).
• Evaluate the degree of application of Law 19/2013, by preparing an annual report on compliance with transparency obligations, presented to the General Courts (letter d).
• Hear claims regarding access to information against express or presumed resolutions of administrations, optionally and prior to administrative litigation (art. 24 and express reference to CTBG competence in its sections 1 and 6).
• Respond to queries raised by bodies responsible for processing and resolving access requests (specific function of the President).

3. Functions in good governance

Regarding good governance, the CTBG:

• Monitors observance of good governance provisions contained in Title II of Law 19/2013, directed at Government members and senior officials.
• Instigates initiation of sanctioning procedures for good governance infractions, under the sanctioning regime of that title, being able to formally request the opening of the file; the competent body must justify its decision if it decides not to open it (function of the President, letter e).

These functions place the CTBG as a central piece of ethical and integrity control of senior officials, in coordination with sanctioning bodies provided in the law itself and other public function regulations.

4. Advisory, interpretative, promotional, and training functions

The Law details a block of more “soft” functions, but decisive to guide administrative practice:

• Issue mandatory reports on state regulatory projects that develop Law 19/2013 or relate to its object (letter c).
• Adopt uniform interpretation criteria of the obligations contained in the Law, a function expressly attributed to the President, which guides all transparency management units (letter a of the President’s functions).
• Promote drafts of recommendations, guidelines, and good practice standards in transparency, access, and good governance (letter e).
• Promote training and awareness activities to improve knowledge of the regulated matters (letter f).
• Collaborate with analogous bodies, especially regional ones, and convene at least one annual coordination meeting with them and with local administration (provision on the Transparency and Good Governance Commission).
• Exercise all other functions assigned by laws or regulations (open clause of letters h of the general list and g of the President’s functions).

5. Control and sanctioning functions

Although the CTBG is not a sanctioning body in the strict sense, the Law grants it a key role of guarantee and activation of the sanctioning regime:

• Controls compliance with active publicity obligations of the General State Administration and can issue resolutions indicating necessary measures and initiation of disciplinary actions.
• Resolves access claims (art. 24), acting as the specialized route prior to courts and setting criteria binding on the Administration unless judicially reviewed.
• Instigates sanctioning procedures for good governance, as noted, reinforcing the deterrent effect of ethical principles in Title II.

The main relevant reform, Law 14/2022, has adjusted some contents of active publicity and references in art. 8, but has not substantially modified the CTBG’s catalogue of competencies: its role as an independent body for supervision, interpretation, control, and promotion of transparency and good governance in the state public sector remains.

The legal requirements for an interest group to access a register, once the registration form is opened, are determined by the specific regulations of each register (state, sectoral, or regional). Although details vary, the analyzed rules —such as Decree-Law 1/2017 of the Catalonia Interest Group Register, Law 25/2018 and Decree 172/2021 of the Valencian Community, and the Resolution of March 9, 2016 on the “CNMC Interest Group Register”— allow identifying a common pattern of requirements.

1. Who is considered an interest group and who can register?

According to these rules, interest groups are natural or legal persons who carry out influence or intermediation activities before public institutions to defend their own or third-party interests. Law 25/2018 of the Valencian Community conceives them as actors seeking to influence public decision-making, defending business, professional, labor, academic, associative, or non-profit interests, among others.

Therefore, the following may register:

• Companies and business associations.
• Professional associations and sectoral organizations.
• Unions, NGOs, citizen platforms, and other civil society entities.
• Public affairs consultancies, professional firms, and natural persons who perform interest representation activities.

In specific registers (for example, the National Commission on Markets and Competition register, regulated by the Resolution of March 9, 2016, BOE-A-2016-2488), registration is aimed at groups interacting with that specific body.

2. Minimum data and documentation in the form

Based on the CNMC Resolution on the “CNMC Interest Group Register” file and the index of Decree 172/2021 of the Valencian Community (articles on registration request of organizations and representatives), it appears that, at minimum, the form usually requires:

• Group identification: corporate name or name, tax ID or equivalent document, registered or postal address, phone, email, and, if applicable, website.
• Representative identification: personal and professional data of the person acting before authorities (name and surname, position or type of representation).
• Purpose and objectives: description of the group’s general aims and the interests it defends.
• Specific activities and areas of interest: main influence activities carried out or planned and the sectors or public policies on which it acts.
• Categories and areas of interest (in the Valencian case, art. 12 of Decree 172/2021): classification of the group into certain typological categories and material areas of action.
• Acceptance of a code of conduct: express commitment to the ethical and transparency rules established by the regulation (mentioned in art. 11 of Decree 172/2021).

Data is usually provided through electronic forms, as foreseen by the CNMC, and incorporated into a public file whose processing must comply with data protection regulations.

3. Obligations arising from registration

Regional laws and Valencian regulatory development establish a set of obligations, among which stand out:

• Transparency: making visible the identity of the group and its representatives, as well as the interests it defends, through its public registration.
• Information update: communicate relevant changes (representatives, contact data, activities, areas of interest), as set out in provisions such as article 10 of Decree 172/2021.
• Respect for the code of conduct: comply with integrity, behavior, and relationship guidelines with public officials established by interest group legislation.
• Activity register: in some cases, maintain a record of meetings and influence contacts with the administration (art. 14 of Decree 172/2021) that may be subject to publicity or control.

4. Denial, suspension, or cancellation

Although details are found in chapters on control and sanctioning procedure (Chapter II, Section two, and Chapter V of Decree 172/2021), the general scheme is that registration may:

• Be denied if minimum required data is not provided or if the applicant does not fit the legal definition of interest group.
• Be temporarily suspended, according to article 20 of Decree 172/2021, when investigations exist for possible breaches of the code of conduct or registration obligations.
• Be cancelled when serious falsehood in information, repeated non-compliance with obligations, or imposition of sanctions leading to deregistration is verified.

In short, once the form is opened, access to the register requires the interest group to identify itself completely and truthfully, specify which interests it defends and in which areas, designate its representatives, and accept an ethical and transparency framework; from there, registration entails obligations of updating, traceability of its influence activity, and submission to a control and sanctioning regime that may culminate in suspension or cancellation of registration.