The Government will put the Lobby Law to a vote next week.

The Government decides to put the decree-law to a vote without rushing the one-month deadline that the Constitution provides.

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The Government has not rushed the deadline to vote in Congress on the new Lobby Law. The Executive has requested Congress to vote on the ratification of the decree-law next week.

According to parliamentary sources reported to DEMÓCRATA, the Board of Spokespersons has accepted the request and the Chamber will examine this regulation in the next plenary session.

The decree-law was approved in the Council of Ministers on August 25. The Executive has one month to defend the regulation in Congress and achieve its ratification.

Ratification in the air

To remain in force, the decree-law must obtain a majority of positive votes. Otherwise, it will be repealed by Congress.

And the Government does not have, at least for now, the guaranteed votes, with the uncertainty of whether PP and Junts will allow the ratification, either by giving their support or through an abstention. 

The Registry is already underway

The decree-law, which came into force on August 27, a day after its publication in the Official State Gazette, requires all interest groups to register in the  new registry before any contact with high-ranking officials, temporary personnel, or executives and public employees with decision-making capacity.

The form to register in the registry, managed by the Council of Transparency and Good Governance, began to be operational on September 4, a week after its entry into force.

In it, groups must state their identity, the funding they have, and the budget they allocate to influence activities. They must also list the individuals linked to the group who have held public positions or jobs in the last five years and the minutes or notes of the meetings held.

The information provided to the Registry must be updated at least once a year. Failing to do so constitutes a serious infringement (suspension of registration for between three to twelve months and a fine of 2,000 to 5,000 euros).

The same punishment applies to concealing the status of interest group in contacts or meetings with public sector workers susceptible to receiving influence.

‘Revolving doors’ audit

Interest groups must identify which individuals have held public positions or jobs in the last five years, as that list must be published on the website itself when this influence activity is professional and communicated biannually to the Council of Transparency.

Document traceability system

The groups must have a system for recording meetings, documents delivered, and written communications, which must be submitted within fifteen working days from the influence activity. Failing to comply with this obligation is considered a serious infringement.

All information provided to the registry and made available to the General Administration of the State, with justified exceptions in accordance with the Transparency Law, will be public.

The entities must keep any documentation delivered to the General Administration when exercising their influence activity. Concealing, altering, or destroying this documentation constitutes a very serious infringement (cancellation of registration, prohibition of application for two to five years, and a fine of between 5,000 and 40,000 euros).

Adaptation of the codes of conduct

They must be adapted to the principles of Article 12 of the regulation, which includes a series of obligations and prohibitions.

For example, the offering of gifts, favors, or services under advantageous conditions to public officials or personnel that may be perceived as an attempt to influence them is prohibited (very serious infringement, unless it is a crime according to the provisions of the Penal Code).

It is also prohibited to present a public official with a possible conflict of interest, to provide false information, or to attempt to influence unlawfully or by resorting to abusive pressure. The sanctioning regime classifies as a very serious infringement to fraudulently influence decision-making or the obtaining of information.

Influence budget

Interest groups must calculate how much budget they dedicate to influence activities, as they must provide this data to the Transparency Council, which will be public by default unless a motivated and expressly requested restriction is applied.

More key points, information and questions with FREN

AI-GENERATED CONTENT

What parliamentary phase is the Lobby Law currently in, and what are the next steps for its final approval?

The term "Lobby Law" is currently used for two different regulatory pieces: the Draft Law on transparency and integrity of interest group activities (under consideration in the Congress) and the recent Royal Decree-Law 21/2026, on transparency and integrity of interest group activities, already in force. In parliamentary terms, the draft law is stuck in the committee phase, while the decree-law is pending validation by the Congress and, if applicable, possible processing as a draft law.

1. The Government's draft law in Congress

The initiative colloquially called "Lobby Law" since 2025 is the Draft Law on transparency and integrity of interest group activities, submitted by the Government to Congress to regulate lobbying activities before the General State Administration and its institutional public sector.

According to Congress notes and Demócrata's coverage, the processing in the XV Legislature has followed this path:

  • Submission and publication: the Council of Ministers approved the draft and sent it to Congress, where it was published and the amendment period opened.
  • General debate: the Plenary debated and rejected Vox's return amendment, so the text continued its ordinary processing in committee (Congress note, 25-3-2025).
  • Amendments to the articles: the amendment period was opened and extended multiple times, finally closing as detailed in several Demócrata pieces about the deadline closure and volume of group amendments.
  • Working group: the working group was established in the Finance and Public Function Committee and began work on the amendments. Parliamentary press places this phase as completed, with a working group report ready to be submitted to the committee.

According to the latest follow-up published by Demócrata and included in its July 2026 chronicle on the regulation blockage, the draft:

  • has passed the amendment deadline and working group phase,
  • but has not yet been approved by the Congress Plenary nor sent to the Senate.

That is, the "Lobby Law" in draft law format is formally in the committee phase in Congress, with the report pending approval and possible submission to the Plenary for the final vote of the Lower House. There is no record of it having passed to the Senate nor, therefore, a final promulgation phase.

2. Royal Decree-Law 21/2026 on lobbies

Faced with the draft's blockage, the Government opted for an alternative route: the Royal Decree-Law 21/2026, on transparency and integrity of interest group activities. The press (for example, Demócrata in its analysis “Spain debuts Lobby Law…”) notes that:

  • the decree-law has already been approved by the Council of Ministers and published in the Official State Gazette (BOE),
  • therefore, it is in force and establishes a mandatory state registry of interest groups, rules for agenda publicity, and a regulatory footprint, among other elements.

However, every decree-law has its own parliamentary phase:

  • It must be debated and voted on in the Congress Plenary within a maximum of 30 days for validation or repeal.
  • In that same session, or a later one, Congress may agree to process it as a draft law to introduce amendments.

To date, available information indicates that the Royal Decree-Law 21/2026 is pending that parliamentary validation. This means that, although it already provisionally governs as a law, its consolidation depends on the validation debate result and whether or not a subsequent processing as a draft law is opened.

3. Next steps towards final approval

Combining both routes, the remaining parliamentary steps are:

  • For the Draft Law on transparency and integrity of interest group activities:
    • That the corresponding Committee approves the report on the text, incorporating (or not) the groups' amendments.
    • That it is included in the Congress Plenary agenda for final debate and vote.
    • If approved, its submission to the Senate, where the Upper House may amend or veto it, and if applicable, return it to Congress for acceptance, modification, or veto lifting.
    • Once bicameralism is overcome, the sanction, promulgation, and publication in the BOE, with the consequent entry into force on the date set by the law itself.
  • For Royal Decree-Law 21/2026:
    • Debate and validation vote in the Congress Plenary within 30 days of its approval.
    • Plenary decision on whether it is processed as a draft law, which would open a new cycle of amendments, committee, working group, and again Plenary and Senate.

In summary, there is already a lobby regulation in force via the decree-law route, but the "final approval" as a fully processed law by the Cortes will depend on Congress validating that text and, in parallel or alternatively, unblocking the draft law still pending in committee.

What are the powers and functions of the Transparency and Good Governance Council according to Spanish legislation?

The Transparency and Good Governance Council (CTBG) is an independent state body created by Law 19/2013, on transparency, access to public information, and good governance. The law itself sets its purpose: to promote transparency in public activity, ensure compliance with publicity obligations, safeguard the right of access to public information, and guarantee observance of good governance rules. From there, it details a set of powers and functions that can be grouped into three main blocks.

1. General supervision and promotion functions

Law 19/2013 configures the CTBG as a supervisory and control body for the application of the law within the scope of the General State Administration and linked or dependent entities, as well as, through agreements, in autonomous communities that adhere.

Among its general functions are:

  • Adopting recommendations for better compliance with transparency, access to information, and good governance obligations provided by the law.
  • Advising administrations and obligated subjects on transparency, access rights, and good governance.
  • Evaluating the application of the law, preparing an annual report on the degree of compliance with transparency and access obligations, which is submitted to the General Courts.
  • Promoting guidelines, guides, and best practices in transparency, access to information, and good governance.
  • Driving training and awareness activities to improve knowledge and culture of transparency in the public sector.
  • Collaborating with other similar bodies, especially at the regional level, fostering coordination and uniformity of criteria.

2. Powers in transparency and access rights

2.1. Active publicity and Transparency Portal

Regarding transparency in the strict sense (active publicity), the law assigns the CTBG control functions over compliance with information dissemination obligations by the General State Administration:

  • Controlling compliance with active publicity obligations provided by law by the General State Administration.
  • Issuing resolutions, in the procedures provided by regulation, establishing necessary measures to correct non-compliance with active publicity obligations and to promote, if applicable, disciplinary actions.
2.2. Guarantee of the right of access

Regarding the right of access to public information, the CTBG assumes a central quasi-judicial guarantee role:

  • Knowing and resolving claims filed against resolutions (express or presumed) on access to information issued by state obligated subjects. This claim is optional and prior to administrative litigation.
  • Publishing its resolutions on access matters, once notified to interested parties and with personal data properly dissociated.
  • Adopting uniform interpretation criteria on transparency and access obligations, through resolutions and pronouncements that guide law application.
  • Responding to optional consultations from bodies handling access requests, helping resolve interpretative doubts about limits, data protection, etc.
  • Communicating to the Ombudsman the resolutions issued on access matters, thus reinforcing external control and rights protection.

3. Powers in good governance matters

Regarding good governance rules established by Law 19/2013 for Government members and senior officials, the CTBG is not the sanctioning body but has relevant promotion and guarantee functions:

  • Ensuring observance of good governance provisions, integrating this dimension into its general supervisory function.
  • Requesting initiation of sanctioning procedures when possible infringements of the good governance title are detected. The competent body for sanctions must justify if it decides not to initiate the procedure.
  • Incorporating analysis of good governance compliance in its reports and memories, linking it to responsibility and proper management of public resources.

4. Other organic and development functions

The law also provides powers related to its own institutional functioning, completing the function framework:

  • Mandatory reporting on state regulatory projects that develop Law 19/2013 or relate to its object.
  • Proposing and approving its draft budget, within the limits of general budgetary regulations.
  • Participating in the elaboration of its own organizational statute, which must be approved by royal decree and specifies its internal structure, functioning, and resources.

Overall, the CTBG combines functions as a control body (claim resolution and compliance monitoring), a rights guarantee body (access rights), and a promotion and interpretation body (recommendations, criteria, training, and advice) in the three areas articulated by Law 19/2013: transparency, access to public information, and good governance.

What legal requirements must interest groups meet to register according to current regulations?

In the Spanish legal system, the regulation of interest groups has mainly developed at the regional level, taking models such as Catalonia and the Valencian Community as references. Although the design of a general state registry is in the process of being configured, current regulations show a fairly homogeneous pattern of requirements to register in interest group registries.

1. Who can and must register

The consulted regional laws (Law 19/2014 of Catalonia and its development by Decree-Law 1/2017, and Law 25/2018 of the Valencian Community and its development by Decree 172/2021) agree that:

  • Interest groups are natural persons and organizations, platforms, or networks (with or without legal personality) that carry out activities likely to influence the development or application of public policies, regulations, draft regulations, or parliamentary initiatives, in their own interest, that of third parties, or even in defense of an organized general interest.
  • This influence activity includes contacts with public officials, public employees, deputies, or political leaders, as well as contributions in public consultations seeking to influence the content of public decisions.

Registration is usually mandatory for all subjects fitting that definition when they want to interact with the Administration or institutions included in the law's scope (regional administration, instrumental public sector, regional parliament, etc.).

2. Excluded subjects or with specific regimes

The rules also distinguish who is not obliged to register, although they may still have public relevance:

  • Intergovernmental organizations and bodies linked to them, when acting within their public functions.
  • Public law corporations (professional associations, chambers, etc.) when exercising public functions, although they can be interest groups when performing other representation or lobbying functions.
  • Political parties and trade unions in exercising their constitutional functions, without prejudice to entities created or financed by them that may be considered interest groups.
  • In the Valencian case, it is specified that natural persons acting on their own matters without significant economic interests due to size or relevance are not considered interest groups.

These criteria delimit who has the legal burden to register and who operates under a different legal regime.

3. Formal registration requirements

The development decrees (for example, Decree 172/2021 of the Consell, which develops Law 25/2018) detail the minimum content of the registration application in the corresponding regional registry:

  • Identification of the interest group: name, legal nature, tax identification number or equivalent identifier, address, contact details, and, if applicable, territorial scope of action.
  • Identification of representatives: data of natural persons acting on behalf of the group (employees, external consultants, professional firms, etc.), with their contact details.
  • Description of influence activity: sectors, subjects, or public policies intended to influence, and types of activities (meetings, participation in consultations, proposal drafting, etc.).
  • Category and areas of interest: registries usually classify interest groups into categories (business, NGOs, professional firms, think tanks, etc.) and thematic areas, which must be declared at registration.

The registry is generally electronic, public, free, open, and independent. The information must be accessible through the transparency portals of the corresponding administration.

4. Associated commitments and obligations

Besides providing basic information, registration entails material obligations:

  • Adherence to a code of conduct: regional regulations require acceptance of a minimum ethical code of mandatory compliance, regulating how interest groups may relate to authorities and public employees (prohibition of offering undue advantages, duty to identify as an interest group, truthfulness in provided information, etc.).
  • Truthfulness and updating of data: interest groups must keep registry information updated (changes in representatives, structure, areas of interest, etc.) and may be subject to verifications and controls by the registry's responsible body.
  • Activity registry: some frameworks, like the Valencian one, provide an activity registry where interest groups must record their main lobbying actions, which may later integrate the “regulatory footprint” of legislative or regulatory processes.

5. State scope and convergence of principles

At the state level, information shows the existence of specific sectoral registries (for example, in regulatory authorities) and personal data files called “Interest Group Registry” in certain bodies. The principles inspiring these instruments coincide with those of the regional examples: transparency, publicity of actors influencing public policies, prior registration to maintain lobbying contacts, and acceptance of ethical and control rules.

In practice, to assess the specific requirements applicable to an interest group, it is essential to identify the territorial and institutional scope (Generalitat, Community of Madrid, Valencian Community, General State Administration, or other) and refer to the specific regulation of its interest group registry, which develops the common elements described: definition of interest group, excluded subjects, mandatory data, acceptance of the code of conduct, updating, and control and sanction regime.

Can you specifically summarize the obligations of the code of conduct that registered interest groups must accept? What are the main differences between the interest group registry of Catalonia and that of the Valencian Community? How is the “regulatory footprint” or legislative trace of interest groups articulated in the norm-making processes?

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