On 26 August, Spain’s Official State Gazette published Royal Decree-Law 21/2026 of 25 August, on transparency and integrity in the activities of interest groups. At first glance it looks like a rule written for large corporations and Brussels consultancies. In our experience, the opposite tends to happen: once regulators start putting names to who talks to government and how, the effect reaches companies of every size.
What has actually been published
The measure takes the form of a royal decree-law, which means it enters into force through the urgent legislative route and must be ratified by Congress in the following weeks. Its stated purpose is twofold: transparency and integrity in the activity of what the law calls interest groups. In plain terms, this is about influencing — legitimately — how rules are drafted and how public decisions are made.
One point deserves emphasis, because it often gets lost. Lobbying is neither illegal nor inherently suspect. A trade association submitting its position on a draft regulation, a professional body appearing in a public consultation, a company requesting a meeting with a regional ministry — all of these are entirely legitimate activities. What this type of regulation aims for is visibility and traceability, not silence.
Does this apply to me? Probably more than you think
This is where it gets practical. Plenty of mid-sized companies would never describe themselves as an “interest group”, yet routinely do things that fit the description quite naturally: taking part in a public consultation on a municipal ordinance, belonging to a sector association that negotiates with regional government, hiring an external adviser to defend a position before a regulator, or maintaining regular contact with public officials in heavily regulated sectors such as energy, tourism, healthcare, construction or transport.
If your company does any of these, the question is no longer whether the rule touches you, but how far. That depends on the scope and the specific obligations the text sets out: who must register, what has to be declared, how often, and what happens if you don’t. Those are questions to work through carefully in the published text, not from a headline summary.
What you can start doing now
Even while the detail is being digested, some preparatory work never goes to waste. First, take an honest inventory of who your organisation talks to in the public sphere and through which channels — direct contacts, associations, external consultants. Second, check whether those contacts are documented anywhere or live only in one person’s diary. Third, look at your code of conduct or compliance policy and see whether it says anything meaningful about engagement with public authorities. In many companies that section stopped at two generic lines.
Closing
Transparency rules rarely feel urgent in month one, and that is precisely the risk: they get shelved until a request for information arrives. If your company deals regularly with public authorities — directly or through third parties — it is worth setting aside a session to see where you stand. At EBF we can help you run that diagnosis and put the process in order before it becomes a deadline. Get in touch and we’ll look at it together.