The lobby registry is still not operating a week after coming into effect.

As of today, September 2, 2026, the so-called “Lobby Law” in the form of a decree-law corresponds to the Royal Decree-Law 21/2026, of August 25, on transparency and integrity of interest groups' activities, published in the BOE on August 26, 2026. Its ratification has not yet been debated or voted on in the Congress, so the regulation is at the stage where it is already in force but pending the debate on ratification or repeal.

According to the parliamentary information gathered for the Bill on transparency and integrity of interest groups' activities (file 121/000046, process process_ini_360183), the Government had previously processed this content as an ordinary bill, whose procedure is still active in the Congress. That bill:

• Was submitted by the Council of Ministers on January 28, 2025, and registered on January 30, 2025.
• Was admitted for processing on February 7, 2025, and a broad amendment period was opened, extended several times.
• Passed the general debate on March 25, 2025, with the rejection of total amendments.
• On September 17, 2025, the Plenary agreed by a large majority on the referral: the committee report will be voted on in Plenary.
• On September 22, 2025, the amendments to the articles were published, and the deadline had formally closed on September 10.

Therefore, that bill is in the phase of working on the committee report and opinion, referred to Plenary, but not concluded. The Government, faced with this deadlock, has now opted for Royal Decree-Law 21/2026 to advance the regulation.

Specific stage of the ratification of Royal Decree-Law 21/2026

Regarding the decree-law itself, official data show:

• August 25, 2026: the Council of Ministers approves Royal Decree-Law 21/2026 on interest groups.
• August 26, 2026: it is published in the BOE and comes into force.

In the agendas and notes of the Congress consulted between August 25 and September 2, 2026:

• No Plenary session with a specific item for “ratification or repeal” of this decree-law appears yet.
• The first Plenary of the new session period (September 3, 2026) is dedicated to hearings on Ceuta, without decree-law debates.

Consequently, the ratification has not yet begun its effective parliamentary processing. The decree-law is in the phase following its publication in the BOE and awaiting inclusion on the agenda of a Plenary session (or the Permanent Deputation) for debate and voting, within the maximum 30-day period established by Article 86 of the Constitution.

Pending procedures for ratification

With the available information, the pending steps related to the ratification of Royal Decree-Law 21/2026 are:

• Qualification and scheduling in the Congress: the Board and the Spokespersons' Committee must agree to include the decree-law on the agenda of a Plenary session (or, if there is dissolution, of the Permanent Deputation) before the 30-day period expires.
• Debate on ratification or repeal: the Plenary will hold a monographic debate in which the Government will defend the decree-law and the groups will state their positions.
• Vote on ratification or repeal: at the end of the debate, a vote will be held on whether to ratify or repeal the decree-law.
  • If it is ratified by a simple majority, the decree-law will remain in force.
  • If it is repealed, it will lose validity from that moment, without prejudice to what has already occurred during its application period.
• Decision on its processing as a bill (optional): in the same act, the Plenary may agree to process the decree-law as a bill by the urgent procedure, which would open a new cycle of amendments, committee work, Plenary, and subsequent referral to the Senate.

Relation with the previous bill

Meanwhile, the Bill 121/000046 on interest groups remains formally in the Congress, after passing the general debate, closing amendments, and having its final vote referred to the Plenary. The pending procedures there are:

• Constitution and effective work of the committee to integrate the amendments.
• Approval of the report in the Finance and Public Function Committee.
• Debate and vote in the Congress Plenary (due to referral).
• Processing in the Senate and return to the Congress, if applicable, for final approval.

But, strictly regarding your question, the ratification of the lobby decree-law is at the stage prior to debate in the Congress, pending setting a date and holding the ratification or repeal vote.

The Transparency and Good Governance Council (CTBG) is the independent state body created by Law 19/2013, of December 9, to promote transparency, guarantee the right of access to public information, and ensure compliance with good governance rules. Its powers and functions are distributed between the Council itself (through its Commission) and its Presidency, supported by the Statute that the Government must approve by royal decree.

1. General purpose and scope of action

According to Law 19/2013 (articles of Title III), the CTBG aims to:

• Promote transparency of public activity within the scope of the General State Administration and, through agreements, of the autonomous communities and local entities that adhere.
• Ensure compliance with active publicity obligations provided in Title I of the Law.
• Safeguard the exercise of the right of access to public information, acting as a guarantee body against denials or silence.
• Guarantee observance of good governance provisions in Title II, promoting their application and the associated sanctioning regime.

2. Functions of the Transparency and Good Governance Council

The article corresponding to Title III establishes that, to achieve its objectives, the CTBG is entrusted, among others, with the following functions:

• Adopt recommendations for better compliance with transparency, access to information, and good governance obligations set out in the Law.
• Advise on transparency, access to public information, and good governance to the various obligated subjects.
• Mandatorily report on state regulatory projects that develop Law 19/2013 or are related to its purpose, contributing to shaping the regulatory framework.
• Evaluate the degree of application of the Law, by preparing an annual report on compliance with transparency obligations, which is submitted to the General Courts.
• Promote the development of guidelines, guides, and codes of good practice in transparency, access, and good governance, guiding administrations and the public sector.
• Develop training and awareness activities aimed at both public personnel and citizens, to foster a culture of transparency.
• Cooperate with other analogous bodies, especially with autonomous transparency authorities, organizing at least one annual meeting with them and enabling local administration participation.
• Exercise any other functions assigned by laws or regulations, allowing updating its scope of action.

3. Control of active publicity and the right of access

Law 19/2013 expressly assigns the CTBG the control of compliance with active publicity obligations by the General State Administration (Article 8, after its amendment by Law 14/2022). The Council may issue resolutions that:

• Order the necessary measures to end non-compliance with active publicity.
• Request the initiation of disciplinary actions against those responsible, when appropriate.

Regarding the right of access, the Law establishes a optional claim before the CTBG (Article 24) against express or presumed resolutions of the subject administrations. The Council:

• Knows and resolves such claims at the state level and in territories without a specific autonomous body.
• Must process the file, hear affected third parties when interests or rights are at stake, and resolve within a maximum period of three months.
• Publishes its resolutions, after dissociating personal data, and communicates them to the Ombudsman.

4. Specific functions of the CTBG Presidency

The Law also distinguishes the functions of the Council President, who acts as a single-person management body:

• Adopt uniform interpretation criteria of the obligations contained in Law 19/2013, a key function to standardize administrative practice.
• Ensure compliance with active publicity obligations, under the terms of Article 9, promoting supervisory actions.
• Know and resolve claims regarding access to information submitted to the Council.
• Respond to facultative consultations from bodies processing and resolving access requests, reinforcing legal certainty.
• Request the initiation of sanctioning procedures for good governance infractions provided in Title II; the competent body must justify if it decides not to initiate the procedure.
• Approve the draft budget of the body and submit it to the ministry of assignment.
• Exercise other functions assigned by laws or regulations.

5. Cooperation and relationship with other bodies

The Law expressly provides for collaboration with the Spanish Data Protection Agency in determining criteria to apply transparency regulations when personal data are involved, as well as the articulation of agreements with autonomous communities to extend the CTBG's functions to their scopes. At the same time, it recognizes the competence of autonomous authorities created under their normative autonomy.

As of today, in the official information consulted, the specific regulation establishing a general state registry of interest groups (lobbies) and detailing their registration requirements has not yet been published in the BOE. Therefore, a regime already in force and closed for the future state registry cannot be described. However, there is Spanish regulatory experience regarding interest group registries, particularly the CNMC Interest Groups Registry, which offers a good reference for the minimum foreseeable requirements.

That reference is the Resolution of March 9, 2016 of the Presidency of the National Commission on Markets and Competition, which creates the personal data file “CNMC Interest Groups Registry” (BOE-A-2016-2488). The file is created under the application of the Organic Law 15/1999, on data protection (LOPD), its implementing regulation (Royal Decree 1720/2007), and within the framework of Law 19/2013, on transparency, and Law 3/2013, creating the CNMC.

1. Who can or must register (CNMC reference)

The resolution describes the “CNMC Interest Groups Registry” file as an information system supporting the registry, whose purpose is to reinforce transparency and good governance of the Commission. Regarding the subjects:

• The persons about whom data are obtained are the interested party (natural or legal person), their legal representative, or the contact persons of interest groups.
• That is, private entities or individuals who carry out influence activities before the CNMC and their representatives or contact persons may register.

The data are provided voluntarily by the subjects through declarations or forms. This logic of voluntary but necessary registration to operate with full transparency is the standard likely to be transferred to a state registry when regulated.

2. Formal requirements and data to provide

The resolution details the file structure, which practically equates to the minimum data required from registrants:

• Personal and entity identification data: name and surname of the interested party, their legal representative or contact person; name of the company or interest group; tax identification number (NIF) or equivalent document.
• Professional address and contact: registered office and/or full postal address, professional phone and fax numbers, email, and website.
• Professional data: position or type of representation held by the person acting before the CNMC.
• Information on influence activity: purpose and objectives of the interest group, specific activities it carries out, and areas of interest in which it seeks to influence.

All these aspects are collected through forms (paper or electronic) and constitute, in practice, the “responsible declaration” about who the interest group is, whom it represents, and in which matters it acts. Any coherent state registry with this model should, at a minimum, require this type of basic identifying and functional information.

3. Obligations linked to registration

Although the CNMC resolution focuses on creating the file, several obligations and guarantees associated with registration can be inferred from its content:

• Publicity of the registry: public access via internet consultation is foreseen, implying that the interest group accepts the public exposure of essential information about its identity, activities, and areas of operation.
• Personal data protection: the body responsible for the file must guarantee confidentiality, security, and integrity of the data and the exercise of rights of access, rectification, cancellation, and opposition according to the LOPD and its regulation.
• Quality and updating of information: although no specific deadline is stated, the fact that it is a transparency and good governance file implies the material obligation to keep data updated (changes of representative, address, areas of interest, etc.).
• Limitation of data transfers: beyond public access via the web, no other data communications or international transfers are foreseen, setting a limited use framework for the information.

In the future state registry of interest groups, the CNMC experience and the framework of Law 19/2013 and data protection rules allow anticipating a similar scheme: complete identification of the lobby and its representatives, description of its activity and areas of influence, electronic registration, registry publicity, and duty to maintain truthful and updated information. However, the specific requirements will be defined in the law or specific regulation approved for that state registry, which to date has not yet been published.