COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Spain Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union

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COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 909 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in Spain
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Rule of Law Report
The rule of law situation in the European Union
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1
ABSTRACT
In Spain, the Council for the Judiciary was renewed following a structured dialogue held in
2024 with the European Commission, and certain steps were taken to advance with the
process to adapt the appointment procedure of its judges-members. The new Council for the
Judiciary is proceeding with appointments to top judicial positions. Some measures have
been taken and others are under way to modify the statute of the Prosecutor General, with
some stakeholders expressing critical views of the reform. New measures have also been
adopted in relation to the incompatibilities regime for judges and prosecutors. A law on the
right of defence was adopted and the legal aid framework has been reinforced. Further
measures are being implemented to improve the digitalisation of justice and to address
challenges regarding the resources of the justice system. There are currently protest actions
by judges and prosecutors reflecting tensions around the proposed reforms on the judiciary.
The length of proceedings, in particular in the Supreme Court, remains a challenge and new
measures have been adopted to improve the situation.
The Government is required by law to adopt a comprehensive strategy to prevent and fight
corruption but work on it is yet to start. Work on the revision of the Code of Criminal
Procedure is ongoing and more resources have been provided to reduce the length of
investigations and prosecutions of high-level corruption, while the level of enforcement on
foreign bribery remains low. Cooperation between different authorities in the fight against
corruption remains good and the efficiency of the work of the Council of Transparency and
Good Governance has improved despite resource constraints. Some initial steps were also
taken to strengthen the rules on conflict of interest for persons in top executive functions. A
draft law was submitted to Parliament to regulate lobbying and to strengthen the
independence and powers of the Office for Conflicts of Interest. However, no further steps
have been taken to improve rules on conflicts of interest for public employees in the different
administrations.
The audiovisual regulator is preparing for the new supervisory functions. The Law on state-
owned radio and television was amended to change the composition of the management
board and its election system, giving more powers to its chairperson. Ownership transparency
of media other than audiovisual media services, video sharing platforms and influencers
remains an area of concern, pending the adoption of the draft Law on Digital Services and
Media which envisages the creation of a public registry of media supervised by the National
Commission for Markets and Competition (CNMC), while the legal framework for
institutional advertising remains unchanged, despite an increased number of campaigns.
There has been no further progress on the recommendation to strengthen access to
information, pending adoption of new legislation. Despite steps foreseen through ongoing
legislative proposals, journalists continue facing increasing challenges regarding working
conditions and safety.
The Spanish Constitutional Court declared the Amnesty Law to be compatible with the
Constitution. Requests for preliminary rulings in relation to the Amnesty Law have been
submitted to the European Court of Justice. Initiatives to promote a rule of law culture are
being taken, a new equality body has been set up and several appointments to independent
authorities and bodies have been made. A draft law to reform the Citizen Security Law has
been put forward so as to address concerns that had been previously raised by stakeholders.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Spain has made:
• Some further progress on strengthening the statute of the Prosecutor General, in particular
regarding the separation of the terms of office of the Prosecutor General from that of the
Government, taking into account European standards on independence and autonomy of
the prosecution.
• Significant progress on renewing the Council for the Judiciary and taking forward the
process in view of adapting the appointment procedure of its judges-members, taking into
account European standards on Councils for the Judiciary.
• Some progress on proceeding to adopt legislation on lobbying, including the
establishment of a mandatory public register of lobbyists.
• Some further progress on stepping up efforts to address the challenges related to the
length of investigations and prosecutions to increase the efficiency in handling high-level
corruption cases, including by finalising the reform of the Code of Criminal Procedure.
• Some progress on strengthening the rules on conflicts of interest and asset declarations of
persons with top executive functions, including by reinforcing the independence and
sanctioning power of the Office for Conflicts of Interest.
• No further progress on advancing with strengthening access to information, in particular
via revision of the Law on Official Secrets, taking into account European standards on
access to official documents.
On this basis, and considering other developments that took place in the period of reference,
and in addition to recalling the relevant commitments made under the Recovery and
Resilience Plan and the relevant country-specific recommendations under the European
Semester, it is recommended to Spain to:
• Continue ongoing efforts to strengthen the statute of the Prosecutor General, in particular
regarding the separation of the terms of office of the Prosecutor General from that of the
Government, taking into account European standards on independence and autonomy of
the prosecution.
• Take forward the process in view of adapting the appointment procedure of the Council
for the Judiciary’s judges-members, taking into account European standards on Councils
for the Judiciary.
• Continue the ongoing procedure to adopt legislation on lobbying, including the
establishment of a mandatory public register of lobbyists.
• Strengthen efforts to address the challenges related to the length of investigations and
prosecutions to increase the efficiency in handling high-level corruption cases, including
by finalising the reform of the Code of Criminal Procedure.
• Take forward the legislative process to strengthen rules on conflicts of interest and asset
declarations of persons with top executive functions, including by further reinforcing the
independence and sanctioning power of the Office for Conflicts of Interest.
• Advance with strengthening access to information, in particular via revision of the Law
on Official Secrets, taking into account European standards on access to official
document.
3
I. JUSTICE SYSTEM1
Independence
The level of perceived judicial independence in Spain continues to be low among the
general public and is now average among companies. Overall, 39% of the general
population and 40% of companies perceive the level of independence of courts and judges to
be ‘fairly or very good’ in 20252
. The perceived judicial independence among the general
public has slightly increased in comparison with 2024 (37%), as well as in comparison with
2021 (38%). The perceived judicial independence among companies has significantly
increased in comparison with 2024 (32%) and has slightly increased in comparison with 2021
(39%).
There was significant progress on the recommendation to finalise the renewal of the
Council for the Judiciary and certain steps were taken to advance with the process to
adapt the appointment procedure of its judges-members3. Following a structured dialogue
with the European Commission, on 25 June 2024 an agreement was reached on the renewal
of the Council for the Judiciary. The new members of the Council for the Judiciary took
office on 25 July 2024. The new President of the Council for the Judiciary, who is also the
President of the Supreme Court, was appointed and took office on 4 September 20244
. The
legislative reform of August 2024 of the Organic Law on the Judiciary and of the Organic
Statute of the Public Prosecutor’s Office5
required the Council for the Judiciary to submit,
within six months of the entry into force of the law, a report and a reform proposal for the
system of appointment of its judges-members. On that basis, the Government or the
Parliament itself can table a draft law with a view to reforming the system for the election of
the Council’s judges-members, taking into account European standards. On 5 February 2025,
the Council for the Judiciary adopted by unanimity a report examining similar European
systems of election of Councils’ members, together with a proposal for how to reform the
election of the judges-members, presenting alternative models both with and without
Parliamentary involvement. The report has been submitted to the Venice Commission.
Stakeholders have called for a swift advancement of the process in order to address the
existing concerns related to the current system of appointment6
. Overall, significant progress
1
An overview of the institutional framework for all four pillars can be found here.
2
Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The
level of perceived judicial independence is categorised as follows: very low (below 30% of respondents
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%).
3
The 2024 Rule of Law Report recommended Spain to: “[b]uilding on the agreement of 25 June 2024,
finalise the renewal of the Council for the Judiciary and take forward the process in view of adapting the
appointment procedure of its judges-members, taking into account European standards on Councils for the
Judiciary”.
4
Constitution of Spain, art. 122(3): the Council for the Judiciary consists of the President of the Supreme
Court (chairing) and of 20 individuals – 12 judges or magistrates, and 8 lawyers or other jurists of
recognised competence with more than 15 years of professional practice. The Parliament is responsible for
the appointment of all its members, subject to a qualified majority of three fifths. While the Constitution
requires the eight lawyers and other jurists to be appointed by a three-fifths majority in each chamber of the
Parliament (four by the Congress and four by the Senate), it does not specify how the members representing
judges are to be appointed.
5
Organic Law 3/2024, of 2 August, that entered into force on 6 August 2024.
6
Hay Derecho (2025), written input, pp. 11-12; Professional Association of the Magistracy (2025), written
input, p. 10; Judges and Magistrates’ Association “Francisco de Vitoria” (2025), written input, p. 11;
Independent Judicial Forum (2025), written input, p. 13.
4
has been made on the recommendation in the 2024 Rule of Law Report while further steps
are needed to finalise the process to adapt the appointment procedure of the judges-members.
The new Council for the Judiciary is proceeding with appointments to top judicial
positions, including to the Supreme Court. The prolonged lack of renewal of the Council
for the Judiciary had a negative impact on the work of the justice system as a whole7
, notably
as the law temporarily precluded an acting Council from making appointments to top judicial
positions, including to the Supreme Court8
. The agreement of 25 June 2024 to renew the
Council for the Judiciary has significantly improved the situation, since the new Council has
been able to proceed with 120 appointments to top judicial positions9
. For the first time a
woman has been appointed as President of the Council for the Judiciary and the Supreme
Court in Spain10
.
Some further progress has been made on the recommendation to strengthen the statute
of the Prosecutor General11, although some stakeholders express critical views of the
reform. The August 2024 law reforming the Organic Statute of the Public Prosecutor’s
Office12
sets out a prohibition for citizens having been in political office in the last five
years13
from becoming Prosecutor General. The law also provides that the Prosecutor General
and members of the Prosecutor’s Office cannot act in cases that affect them personally. In
May 2025, the Council of Ministers adopted a preliminary draft law further reforming the
Organic Statute of the Public Prosecutor’s Office. The aim of the preliminary draft law is to
reinforce the independence and autonomy of prosecutors to adapt to their new role as
investigators in criminal cases, in accordance with the planned draft amendment of the
Criminal Procedure Code14
. It provides that the term of office of the Prosecutor General will
no longer coincide with that of the Government and it will be a non-renewable five-year term.
Furthermore, the preliminary draft law aims to improve the transparency of the relations of
the Government and the Prosecutor General, stating that communications between the latter
and the Government will be public and in writing. The reform also provides that if the
Government would want to dismiss the Prosecutor General for serious or repeated failure to
perform his or her duties, it would first need to require the opinion of the Council for the
Judiciary. The preliminary draft law also provides for new grounds for the recusal of
prosecutors. The appointment, promotion and sanctions of the chief prosecutors would be
attributed to the Prosecutor General and not to the Government, and other measures have
already been taken to increase the autonomy of the Prosecution Service in the budgetary and
7
European Network of Councils for the Judiciary (2025), written input, p. 1.
8
2024 Rule of Law Report, Spain, p. 6.
9
Council for the Judiciary (2025), written input, p. 6; country visit Spain, Technical Cabinet of the Supreme
Court.
10
Women are still underrepresented in the top judicial positions, although they represent the majority of the
judiciary. Currently, 57.2% of the total number of judges are women. Association of Women Judges of
Spain (2025), written input, p. 7-8.
11
The 2024 Rule of Law Report recommended Spain to “[c]ontinue to strengthen the statute of the Prosecutor
General, in particular regarding the separation of the terms of office of the Prosecutor General from that of
the Government, taking into account European standards on independence and autonomy of the
prosecution”.
12
Organic Law 3/2024, of 2 August.
13
This includes Ministers, Secretaries of State, regional governments’ counsellors, presidents of local
corporations, members of the Congress, the Senate, and the European Parliament or regional parliaments.
14
The Government has indicated that it intends to approve both reforms together and table them in Parliament
before summer 2025.
5
training fields15
. This preliminary draft law is undergoing consultations with national
consultative bodies before its final approval by the Government and subsequent submission
to Parliament. On 23 June 2025, the Council for the Judiciary adopted its report on the
envisaged reform, stressing it provides for certain progress, but warning that it falls short in
terms of fully ensuring independence safeguards and internal checks and balances. On 6 June
2025, the Prosecutorial Council adopted a critical report on this preliminary draft law that
also contains an individual opinion of the Progressive Union of Prosecutors. According to
that opinion, the draft law includes some positive aspects as regards the duration of the
mandate of the Prosecutor General and the need to request an opinion of the Council for the
Judiciary for the possible dismissal of the Prosecutor General for serious or repeated failure
to perform his or her duties16
. Some stakeholders have expressed concerns about the
envisaged reform considering that it poses a risk to the independence of justice by reinforcing
the powers of the Prosecutor General and lowering the professional safeguards of
prosecutors17
. Overall, as some measures have been taken and more are envisaged to
strengthen the statute of the Prosecutor General, there has been some further progress on the
recommendation.
The Council for the Judiciary18 and the four main associations of judges19 have warned
about public statements by politicians, including from the Government, criticising the
judiciary. According to the Technical Cabinet of the Supreme Court20
, statements by
politicians that lead to personal reproaches and discrediting of judges and their professional
activity, often also questioning their independence, seriously undermine citizens’ confidence
in justice. According to European standards, while criticising judicial decisions is a normal
aspect of democratic discourse, the executive and legislative powers should avoid criticism
that undermines the independence of or public confidence in the judiciary21
. All State bodies,
of the executive, legislative and judiciary, should apply mutual respect to safeguard the well-
functioning of constitutional institutions and protect the trust of the general public in them22
.
New measures have been adopted as regards the incompatibilities regime. The August
2024 reform of the Organic Law on the Judiciary23
stipulates that judges that have been in
political office cannot perform judicial functions for two years after their re-entry into
service. Additionally, new safeguards have been introduced in this same reform as regards
the appointment of legal professionals other than judges for the position of member of the
15
Country visit Spain, Technical Cabinet of the Prosecutor General’s Office.
16
Individual opinion of the Progressive Union of Prosecutors of 6 June 2025 referring to positive aspects of
the envisaged reform.
17
A joint statement sharing these concerns has been made on 23 May 2025 by Professional Association of the
Magistracy, Judges and Magistrates’ Association “Francisco de Vitoria”, Independent Judicial Forum,
Association of Prosecutors and Professional and Independent Association of Prosecutors. On 28 May 2025,
the Spanish Union of Prosecutors and Judges published a statement on the envisaged reform also raising
such concerns.
18
Country visit Spain, Council for the Judiciary.
19
Country visit Spain, Professional Association of the Magistracy, Judges and Magistrates’ Association
“Francisco de Vitoria”, Judges for Democracy and Independent Judicial Forum.
20
Country visit Spain, Technical Cabinet of the Supreme Court.
21
Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council of Europe, para. 18. See
also Venice Commission (2013), CDL-AD(2013)038, paras. 21-22.
22
CCJE (2015), Opinion No. 18, ‘The position of the judiciary and its relation with the other powers of state
in a modern democracy’, para. 54: ‘Any analyses and criticisms by one power of state of the other powers
should be undertaken in a climate of mutual respect’.
23
Organic Law 3/2024, of 2 August.
6
Council of the Judiciary: they are not eligible if they have been in political office in the five
previous years.
Quality
A new law on the right of defence was adopted and further improvements on the legal
aid framework were implemented. The new law on the right of defence24
which entered
into force in December 2024, is the first self-standing law on this fundamental right in Spain,
with the aim of providing legal certainty for both citizens when exercising their rights of
defence and lawyers when performing their work25
. It focuses, among others, on guaranteeing
a legal aid framework for vulnerable individuals and the possibility of resorting to alternative
dispute resolution mechanisms. The entry into force of this new law is part of a specific
milestone included in the Spanish Recovery and Resilience Plan26
. Spain provides a wide
coverage of legal aid27
. Further financial support has been given to the legal aid framework,
and a draft law on its use is under preparation28
.
The remuneration of judges and prosecutors has been progressively increased, and
measures are being taken to address challenges regarding the resources allocated to the
justice system, although judges’ and prosecutors’ associations expressed mixed views.
The number of judges per inhabitant is still one of the lowest in the EU29
, and a number of
vacancies continue to be covered by substitute-judges30
. In this context, in May 2025 a draft
law on the judicial and prosecutorial careers has been tabled, which aims at reforming the
access to these legal professions, stepping up resources of the justice system, and stabilising
the situation of substitute-judges and prosecutors. Some stakeholders have raised concerns
about these proposed measures and their possible impact on the independence of justice,
while other stakeholders support a number of elements of the envisaged reform31
. A
progressive increase in the remuneration of judges and prosecutors has been applied since
July 202432
, although some associations of prosecutors and of judges33
continue to voice
concern about the level of remuneration, notably with respect to the work-on-call shifts34
.
24
Organic Law 5/2024, of 11 November 2024, that entered into force on 4 December 2024.
25
Spanish Government (2025), written input, p. 9; country visit Spain, General Council of Spanish Lawyers.
26
Milestone 435 under Component 11 of Annex to the Council Implementing Decision on the approval of the
assessment of the recovery and resilience plan for Spain (ST 10150 2021; ST 10150 2021 ADD 1 REV 2 as
amended by ST 13695 2023; ST 13695 2023 ADD 1 REV 1; ST 9303 2024; ST 9303 2024 ADD 1; ST
17099 2024; ST 17099 ADD 1; ST 8053/25 INIT; ST 8053/25 ADD 1, and ST 9583/25 + ADD 1 + ADD 1
COR 1, 10408/25, pp. 118-148.
27
2025 EU Justice Scoreboard, Figure 23.
28
Spanish Government (2025), written input, p. 10.
29
2025 EU Justice Scoreboard, Figure 37. This category consists of judges working full-time, in accordance
with the CEPEJ methodology. It does not include the court clerks (Rechtspfleger/letrados) that exist in
some Member States such as Spain. Spanish Letrados de la Administración de Justicia (Rechtspfleger)
perform lots of almost-judicial tasks.
30
Judges and Magistrates’ Association “Francisco de Vitoria” (2025), written input, p. 11.
31
Joint statements have been made on 14 May and 4 June 2025 signed by Professional Association of the
Magistracy, Judges and Magistrates’ Association “Francisco de Vitoria”, Independent Judicial Forum,
Association of Prosecutors and Professional and Independent Association of Prosecutors. On 28 May 2025,
the Spanish Union of Prosecutors and Judges has made a statement on this possible reform also raising
concerns. A statement by Judges for Democracy supporting some aspects of this reform has been made on 6
June 2025.
32
Spanish Government (2025), written input, pp. 10-11.
7
There are currently protest actions by judges and prosecutors reflecting tensions
around the proposed reforms on the judiciary. Some judicial and prosecutorial
associations called for a 3-day strike manifesting against the draft law on judicial and
prosecutorial careers calling for its withdrawal from the legislative process. The Council for
the Judiciary has stated that strikes by the judiciary are not regulated.
The Prosecutor General is subject to ongoing judicial proceedings. An investigative judge
of the Supreme Court requested the indictment of the Prosecutor General. On 9 June 2025,
the Prosecutor General was charged by the Supreme Court for allegedly leaking confidential
information linked to a tax fraud case. The Prosecutor General has filed an appeal.
Work continued on improving the digitalisation of justice. The digitalisation of justice in
Spain continues to advance, and the use of ICT tools in the justice system is consolidated35
.
Further measures, including legislative ones, to improve the digitalisation of justice are being
implemented. This includes the adoption of the e-Evidence digital exchange system
(‘eEDES’), on the basis of which the possibilities for interoperability with the case
management system of prosecution offices at EU level are being explored36
. Stakeholders
have raised the need to further improve the interoperability between different procedural
management systems used by Autonomous Communities37
, where the Justice Administration
is not managed by the Ministry of the Presidency, Justice and Relations with the Parliament,
and to further invest in financial and human resources for the digitalisation of justice38
.
Efficiency
The length of proceedings, in particular in the Supreme Court, remains a challenge and
new measures have been adopted to improve the situation. The disposition time for civil
and commercial cases at the Supreme Court remains very high (691 days both in 2022 and
2023)39
. The disposition time for administrative cases at first instance increased in 2023 (414
days)40
. The adoption of the law on measures for the efficiency of the public administration
of justice41
updates the current judicial structure and introduces procedural reforms aimed at
further speeding up the handling of court proceedings in all four jurisdictions42
. The new law
focuses on the specialisation of courts to improve the allocation and handling of cases and
resources43
. It also regulates the resort to alternative dispute resolution mechanisms and
provides for a series of procedural steps to be conducted electronically. The entry into force
33
Association of Prosecutors (2025), written input, p. 13. Country visit Spain, Professional Association of the
Magistracy, Judges and Magistrates’ Association “Francisco de Vitoria”, Judges for Democracy and
Independent Judicial Forum.
34
Judgments of the CJEU (2025), case C-146/23 and case C-374/23, para 60: “The remuneration of judges
may, […], vary according to seniority and the nature of the functions entrusted to them. In any event, it
must always be commensurate with the importance of the functions they carry out”.
35
2025 EU Justice Scoreboard, Figures 40-48.
36
Spanish Government (2025), written input, pp. 11-14.
37
Country visit Spain, Letrados de la Administración de Justicia (Rechtspfleger) and Technical Cabinet of the
Supreme Court.
38
Country visit Spain, Association of “Abogados del Estado”.
39
2025 EU Justice Scoreboard, Figure 6.
40
2025 EU Justice Scoreboard, Figure 7.
41
Organic law 1/2025, of 2 January 2025.
42
Civil, criminal, contentious administrative, and social or employment areas.
43
Spanish Government (2025), written input, pp. 15-16.
8
of the new law is part of a specific milestone included in the Spanish Recovery and
Resilience Plan44
.
II. ANTI-CORRUPTION FRAMEWORK
The perception among experts, citizens, and businesses is that the level of corruption in
the public sector is relatively high. In the 2024 Corruption Perceptions Index by
Transparency International, Spain scores 56/100 and ranks 16th
in the European Union and
46th
globally45
. This perception has significantly increased over the past five years46
. The
2025 Special Eurobarometer on Corruption shows that 89% of respondents consider
corruption widespread in their country (EU average 69%) and 51% of respondents feel
personally affected by corruption in their daily lives (EU average 30%). As regards
businesses, 87% of companies consider that corruption is widespread (EU average 63%) and
53% consider that corruption is a problem when doing business (EU average 35%).
Furthermore, 30% of respondents find that there are enough successful prosecutions to deter
people from corrupt practices (EU average 36%), while 12% of companies believe that
people and businesses caught for bribing a senior official are appropriately punished (EU
average 33%)47
.
Work has not yet started on the national anti-corruption strategy foreseen by law for
September 2024. Law 2/2023 regulating the protection of whistleblowers included a
requirement that the Government adopts a national Anti-Corruption Strategy by September
2024. A first draft will be prepared by the Independent Authority for the Protection of
Whistleblowers following the recent appointment of its President48
. According to
stakeholders, despite the inclusion of anti-corruption priorities in sectorial plans and
strategies, the absence of a unified strategy risks leading to fragmentation and insufficient
oversight of anti-corruption measures49
. On the other hand, preparation of a National
Antifraud Strategy is at an advanced stage, following extensive consultations, although no
specific timeline for its finalisation has been set out yet50
. The Democracy Action Plan (DAP)
presented in September 2024 envisages the adoption of an Open Government Strategy, the
preparation of a draft Law on Open Administration 51
, and of a Fifth Plan52
, in collaboration
44
Milestone 434 under Component 11 of Annex to the Council Implementing Decision on the approval of the
assessment of the recovery and resilience plan for Spain (ST 10150 2021; ST 10150 2021 ADD 1 REV 2 as
amended by ST 13695 2023; ST 13695 2023 ADD 1 REV 1; ST 9303 2024; ST 9303 2024 ADD 1; ST
17099 2024; ST 17099 ADD 1; ST 8053/25 INIT; ST 8053/25 ADD 1, and ST 9583/25 + ADD 1 + ADD 1
COR 1, 10408/25), pp. 118-148.
45
The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-60),
relatively high (between 59-50), high (below 50).
46
In 2020 the score was 62, while, in 2024, the score was 56. The score significantly increases/decreases
when it changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively
stable (changes from 1-3 points) in the last five years.
47
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
48
Country visit Spain, Spanish Government. The adoption of an anti-corruption strategy is expected to be
included also under the Fifth Open Government Plan (see below).
49
Country visit Spain, Foundation ‘Hay Derecho’. Fundación Baltasar (2025), written input, p. 11. See also
2024 Rule of Law Report, Spain, pp. 13-14.
50
Country visit Spain, Spanish Government. See also 2024 Rule of Law Report, Spain, p.14.
51
Democracy Action Plan, p.15.
52
This follows the Fourth Open Government Plan, which ended in October 2024, covered 111 initiatives, of
which 87 were finalised, 20 were partially implemented, and four were cancelled, Transparency Portal,
Follow-up to the IV Open Government Plan. The preparation of the Fifth Plan (2024-2028) is ongoing,
following broad consultation with relevant stakeholders (Spanish Government (2025), written input, p. 37).
9
with civil society. The draft Fifth Plan, submitted to public consultation in June 2025, lists
integrity and accountability as one of its priorities, including through a roadmap for the
public sector, rules on lobbying and interest groups, as well as rules on conflicts of interest53
.
It also outlines the main objectives of the draft Law on Open Administration. A coordination
mechanism was set up in order to supervise the implementation of the Democracy Action
Plan54
.
While efforts have been made to address foreign bribery, gaps remain in the legislative
framework and the level of enforcement remains low. Measures have been taken to
facilitate the detection of foreign bribery, including to detect it from diverse sources and
strengthened cooperation between relevant bodies. In addition, training and awareness-raising
activities have been conducted throughout the public administration55
. In 2025, the OECD
reiterated its recommendations as regards the need to clarify provisions on corporate liability
and to ensure a sufficient time limitation period for judicial investigations of foreign bribery.
The level of enforcement remains low, with only two cases concluded successfully since
2016, and many investigations terminated56
.
There has been some progress to address the recommendation on the length of
investigations and prosecution of high-level corruption cases, as the reform of the
Criminal Procedure Code has advanced further and additional resources have been
provided57. In December 2024, the Council for the Judiciary issued a favourable opinion on
the draft law to amend the Code of Criminal Procedure58
. Further work on the draft law is
required to reflect all input provided and it is expected to be submitted to Parliament in the
course of 202559
. The Government acknowledges that corruption cases take longer due to
their increasingly complex nature and has taken steps to strengthen human resources in the
judicial system60
. In April 2025, two new prosecutor positions were established within the
Anti-Corruption Prosecutor’s Office61
. In October 2024, two specialised Prosecutorial
Chambers were established: one for Economic Crimes and one for Crimes against Public
Administration, thereby increasing the staff of the Public Prosecutor’s Office62
. Stakeholders
signal risks of duplication between the activities of the two new Chambers and the Anti-
Corruption Prosecutor’s Office63
. The new law on measures for the efficiency of the public
administration of justice aims to speed up the processing of judicial procedures and increase
53
Transparency Portal, Framework document for the elaboration of the Fifth Open Government Plan 2024-
2028.
54
Royal Decree 955/2024 on the creation of the Interministerial Commission on supervision and
implementation of the Democracy Action Plan.
55
These measures operate in conjunction with the entry into force of Law 2/2023 on the protection of
whistleblowers and the adoption of the Statute of the Independent Authority for the Protection of
Whistleblowers.
56
OECD (2025).
57
The 2024 Rule of Law Report recommended Spain to “[s]tep up efforts to address the challenges related to
the length of investigations and prosecutions to increase the efficiency in handling high-level corruption
cases, including by finalising the reform of the Code of Criminal Procedure”. 2024 Rule of Law Report,
Spain, p.2.
58
Spanish Government (2025), written contribution, p. 17.
59
Spanish Government (2025), written input, p.17; country visit Spain, Spanish Government.
60
Country visit Spain, Spanish Government.
61
News item of the Prosecutor’s Office (2025).
62
Royal Decree 1100/2024. In line with the Decree, 79 new positions of prosecutors have been created.
Spanish Government (2025), written input, p.17.
63
Country visit Spain, Association of prosecutors.
10
the number of staff in the Anti-corruption Prosecutor’s Office, as well as the number of
judges64
. Stakeholders noted that the reform of the Code of Criminal Procedure should also
ensure an adequate statute of limitations to investigate complex cases65
. The number of
procedures opened on corruption charges amounted to 22 in 2024 (32 in 2023). Of all
adjudicated cases of corruption crimes in 2024, a total of 26 cases were convictions or partial
convictions, while 12 were acquittals66
. In October 2024, a former Minister and member of
parliament was indicted as person of interest in an alleged corruption case related to the
COVID-19 pandemic67
. The EPPO reported 4 corruption cases among its open cases in
Spain68
. Overall, given the ongoing work on the revision of the Criminal Procedure Code and
the provision of additional resources to the prosecution service, some progress has been made
on the recommendation in the 2024 Rule of Law Report.
IT tools have improved the efficiency of the work of the Council of Transparency and
Good Governance, but it lacks mechanisms to ensure compliance with its binding
recommendations. In 2024, the Government approved a new statute for the Council for
Transparency and Good Governance, which has facilitated coordination with the public
administration69
. New IT tools, including the new electronic management system for courts,
improved the efficiency of the Council’s work70
. The Council’s budget and staff remained
unchanged due to lack of agreement on a new budget in Parliament71
. No measures have been
taken or are planned to ensure compliance with the Council’s binding resolutions72
. As
previously reported, the Council considers having enforcement powers a necessary step to
effectively perform its tasks.
There have been no further steps taken to improve rules on conflicts of interest for
public employees despite ongoing work since 2021. The revision of the Law on
Incompatibilities of Personnel in the Service of Public Administrations, foreseen under the
Fourth Open Government Plan, was not carried out73
. The preparation of the draft law on
Open Administration is ongoing and is planned to be approved by the Council of Ministers in
the second half of 202574
. It is expected to strengthen transparency obligations and the
control over public authorities, especially as regards conflicts of interest, through a regime of
incompatibilities and new post-employment limitations. The Integrity System of the General
State Administration, approved by the Council of Ministers in January 2025, is fully
64
Organic law 1/2025, of 2 January 2025.
65
Country visit Spain, Foundation ‘Hay Derecho’ and Transparency International. See also press release of
the Asociación de Fiscales (2024).
66
Information obtained from the database of the Council for the Judiciary. In 2023, 38 cases were convictions
or partial convictions, 18 acquittals. See also 2024 Rule of Law Report, Spain, p. 15.
67
Country visit Spain, Association of Prosecutors.
68
EPPO (2025b), p. 57.
69
Royal Decree 615/2024 of 2 July 2024. Country visit Spain, Transparency Council.
70
The time needed for processing of complaints has been reduced by 40 days on average. The Council
received 1396 complaints, which constitutes an increase of 19.3% compared to 2023. It resolved 1530
complaints, representing an increase by 30.9% compared to 2023. Transparency Council (2025). In 2024,
42% of appeals before the Council were motivated by the lack of response from an administration at the
state level, and 73.3% by the lack of response at the regional level.
71
Country visit Spain, Transparency Council.
72
GRECO recommended to ensure “proper independence, authority and resources” of the Council to
effectively perform its monitoring functions. GRECO (2022a), p. 8.
73
See 2024 Rule of Law Report, Spain, p. 17. The draft Law, intended to amend Law 53/1984 of 26
December 1984, was foreseen for adoption in the first semester of 2022.
74
Democracy Action Plan, p.16.
11
operational75
. It aims to foster a culture of integrity through the prevention of conflicts of
interest, fraud and corruption. In August 2024 an Integrity System of the Civil Guard and an
Ethical Conduct Observatory were established76
. An Action Plan on Professional Ethics for
the Civil Guard is still under preparation by the Civil Guard jointly with the Ministry of
Interior. Work on rules on conflicts of interest for the National Police and the Civil Guard,
planned for 2023, is still ongoing77
.
There has been some progress on the recommendation to strengthen the rules governing
conflicts of interest and asset declarations of persons in top executive functions, in
particular as regards the independence of the Office for Conflicts of Interest (OCI)78.
Under the Democracy Action Plan, work has been initiated on a draft law to amend the rules
on incompatibilities79
. Amendments to strengthen the independence and powers of the OCI
have been included in a draft law on transparency and integrity of the activities of interest
groups80
. In particular, that draft law foresees that the Head of the OCI, the heads of its sub-
directorates, or its personnel, may not request or accept instructions from any public or
private entity. The draft law details the powers of the OCI and the functions of the Head of
the OCI, who would be appointed for a non-renewable period of 6-years. However, the OCI
remains integrated in the Government’s structure for organisational and budgetary purposes.
While the draft law grants OCI enforcement powers against interest groups that breach
lobbying rules, its sanctioning powers vis-à-vis the administration have not been strengthened
under the draft. Consequently, sanctions on persons in top executive functions would be
imposed by the Council of Ministers upon proposal by the Minister of Finance and Public
Administration81
. In addition, the OCI will still not have direct access to fiscal or tax data and
does not carry out in-depth asset checks. Every six months, the OCI informs on the status of
reports on the asset positions of senior officials82
. No proceeding was initiated in 2024,
similarly to 202383
. Given that changes to the legal framework aiming to reinforce the
independence and powers of the OCI have been submitted to Parliament, there is some
progress on the recommendation made in the 2024 Report.
75
It contains a Code of Good Administration, a Code of Good Governance and a specific chapter on Integrity
Risk Management. Both Codes are complemented by a section on conflicts of interest, including a specific
provision on gifts. The Integrity System of the General State Administration includes a dedicated chapter
focused on training and awareness initiatives, which are considered a fundamental pillar of an
organisational culture grounded in ethical principles. A guide of good practices for the application of the
System is under preparation. Spanish Government (2025), written input, pp.22-23.
76
Order PJC/849/2024 of 8 August, BOE no. 193. It covers organisational elements, policies, rules, processes
and procedures, whose purpose is the promotion of ethical behaviour, as well as prevention, detection and
prosecution of conduct contrary to the law.
77
Country visit Spain, Civil Guard and National Police. The rules would address pending GRECO
recommendations. See GRECO (2022a), p. 16.
78
The 2024 Rule of Law Report recommended Spain to ‘[s]trengthen the rules on conflicts of interest and
asset declarations of persons with top executive functions, including by reinforcing the sanctioning power
of the Office for Conflicts of Interest’. 2024 Rule of Law Report, Spain, p. 2.
79
Democracy Action Plan, p. 16. The current regime is set out in Law 53/1984.
80
Draft law on transparency and integrity of the activities of interest groups (121/000046). Previous Rule of
law reports have stressed the need to strengthen the independence and autonomy of the Office, in particular
by reinforcing the sanctioning power. See 2024 Rule of Law Report, Spain, p.19.
81
These issues have also been raised by GRECO, see GRECO (2025a).
82
The 6-months report only provides aggregate of investigations in progress and the number of sanctions,
additional details are only disclosed to Parliament information on the number. It is published in the Official
State Gazette.
83
Office for Conflicts of Interest (2025); Office for Conflicts of Interest (2024).
12
Whereas disclosure requirements for parliamentarians are mostly met, only few
Parliamentarians publish information about meetings with interest groups. In its 2023
annual report, the Parliament Office for Conflicts of Interest (Parliament OCI) issued four
recommendations concerning the obligations to submit a declaration of financial interests and
to publish the agenda, including meetings held with lobbyists84
. In its 2024 annual report, the
Parliament OCI considered that the disclosure requirements had overall been met and only
recalled the need to update the declaration when contributions to associations or foundations
were made. However, it reiterated the recommendation as regards the publication of meetings
with interest groups, as only few parliamentarians comply with this obligation85
. The
Democracy Action Plan includes a reform of the rules of procedure of both the Congress and
the Senate to strengthen penalties for the failure to submit asset declarations or for providing
false or incomplete information86
. In June 2025, a proposal to amend the rules of procedure
of Congress to regulate lobbying was introduced and is under deliberation in the chamber87
.
Some progress has been made on the recommendation on lobbying, as the Government
submitted a draft law to Parliament88. The draft law introduces a broad definition of what
constitutes a group of interest and influence activities. It also provides for the establishment
of a mandatory public register of lobbyists, managed by the OCI, and envisages a Code of
Conduct for interest groups and their members89
. Work on the IT tool to operationalise the
register has been initiated but its finalisation depends on the adoption of the law90
. Civil
society organisations have welcomed the draft law, which also aims to implement
outstanding GRECO recommendations91
. At the same time, stakeholders call for stronger
sanctions, mandatory traceability of lobbying contacts and a wider coverage of entities
engaging in influence activities92
. This reform is included in the Recovery and Resilience
Plan as part of steps to modernise the public administration93
. Overall, in view of the
submission of the draft law to Parliament, some progress has been made on the
recommendation made in the 2024 Rule of Law Report.
The Statute of the Independent Authority for the Protection of Whistleblowers was
adopted and its first President was appointed by the Government. In view of the
obligations established by the Whistleblowers’ Directive, the 2023 law on the protection of
persons who report regulatory breaches and the fight against corruption foresees the creation
of a new Independent Authority for the Protection of Whistleblowers responsible for
84
Code of Conduct, article 4.3 and 6.2.
85
In 2023, for instance, only 10% of parliamentarians fulfilled this obligation. Parliament OCI (2025), pp. 17-
18. The point was also noted by GRECO (2022a) p. 10.
86
Democracy Action Plan, p. 29.
87
Proposal 410/000009 of 30 May 2025 to amend the rules of procedure of Congress introducing Title XIV
on the regulation of interest groups. It would set out new transparency obligations for members of
Congress, a legislative footprint, a register of interest groups, as well as a sanctions regime. Newtral (2025).
88
The 2024 Rule of Law Report recommended Spain to “proceed to adopt legislation on lobbying, including
the establishment of a mandatory public register of lobbyists”.
89
Draft law 121/000046 on transparency and integrity of the activities of interest groups.
90
Country visit Spain, Spanish Government.
91
GRECO (2022b).
92
X-net (2022), Civio (2025), Democrata (2025).
93
Milestone 432 under Component 11 of Annex to the Council Implementing Decision of 13 July 2021 on the
approval of the assessment of the recovery and resilience plan for Spain (ST 10150 2021; ST 10150 2021
ADD 1 REV 2 as amended by ST 13695 2023; ST 13695 2023 ADD 1 REV 1; ST 9303 2024; ST 9303
2024 ADD 1; ST 17099 2024; ST 17099 ADD 1; ST 8053/25 INIT; ST 8053/25 ADD 1, and ST 9583/25 +
ADD 1 + ADD 1 COR 1, 10408/25), pp. 118-148.
13
receiving external whistleblower reports and corruption complaints94
. The Authority is in the
process of establishing its full capacity and will play a central role in the overall protection of
whistleblowers in Spain95
. The Statute of the Independent Authority was adopted on 29
October 2024 and its first President was appointed in April 202596
. Some civil society
organisations expressed concerns that the Statute does not establish an open and transparent
process for the submission of candidacies for the President’s position97
. Internal reporting
channels have been set up within the Civil Guard, the Transparency Council and the Tax
Agency98
in accordance with law 2/2023, which requires all public administrations to set up
such a reporting channel99
.
Public procurement, political party financing, infrastructure projects and public service
contracts are key sectors at high-risk of corruption. The Flash Eurobarometer on
Businesses’ attitudes towards corruption in the EU shows that 40% of companies in Spain
(EU average 25%) think that corruption has prevented them from winning a public tender or
a public procurement contract in practice in the last three years100
. The Single Market and
Competitiveness Scoreboard on access to public procurement in Spain reports 33% of single
bids for 2023 (EU average 29%). 61% of businesses perceive the level of independence of the
public procurement review body (Central Administrative Court of Contract Appeals) as very
or fairly good101
. The 2024 Annual Report on Supervision of Public Procurement in Spain
highlights that service contracts are the most frequently reported type of contract (64.25% of
complaints)102
. The main causes of complaints and communications in public procurement
matters are alleged irregularities in the award of the contract, followed by alleged corrupt
practices, complaints related to the execution of the contract and, finally, issues regarding use
of sub-contracting103
. As in the previous year, the report highlights corruption prevention
actions, including training and education activities, as well as good practices followed by the
Anti-Fraud Offices and agencies, as well as other relevant bodies104
. Political party financing
remains a high-risk area, and no steps have been taken to reform the electoral legislation in
line with recommendations made by the Court of Auditors105
. In the healthcare sector, the
first Strategic Plan of the Observatory against Healthcare Fraud and Corruption, established
within the Ministry of Health, was approved in September 2024. Stakeholders however
highlight that it does not propose sufficiently concrete risk-mitigating measures106
.
94
Law 2/2023. This act covers not only breaches of European Union law, but also breaches of serious national
criminal and administrative law, thereby going beyond the material scope of Directive (EU) 2019/1937.
95
Country visit Spain, Foundation ‘Hay Derecho’ and Transparency International.
96
Royal Decree 1101/2024. Infobae (2025).
97
Foundation ‘Hay Derecho’ (2025), written input, p.26. Country visit Spain, Foundation ‘Hay Derecho’ and
Transparency International
98
Spanish Government (2025), written input, p. 16.
99
The law covers all including territorial or institutional public administrations, independent authorities or
other bodies managing social security services, universities, companies, and foundations belonging to the
public sector, as well as public law corporations.
100
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 15
percentage points above the EU average.
101
2025 EU Justice Scoreboard, Figure 59.
102
The report is prepared by the Independent Office on Supervision of Public Procurement in Spain.
103
Spanish Government (2025), written input, pp. 27-28.
104
Spanish Government (2025a).
105
Country visit Spain, Court of Auditors. See 2024 Rule of Law Report, Spain, p.22.
106
Foundation ‘Hay Derecho’, written input, p. 30.
14
III. MEDIA PLURALISM AND MEDIA FREEDOM
The audiovisual regulator is preparing for the new supervisory functions attributed to it
under EMFA and DSA. Based on a new draft law on Digital Services and Media107
, the
National Commission for Markets and Competition (CNMC) is attributed the supervisory
authority under the European Media Freedom Act (EMFA)108
and Digital Services Act
(DSA)109
. The CNMC will be assigned six additional staff for two new Directorates on digital
services and media, and it will also be tasked to assess the impact on media pluralism of
concentration operations in the media market. In February 2025, the new Vice-President and
four new members of the CNMC Board took office. The Media Pluralism Monitor (MPM)
risk score for plurality of media providers remains stable at very-high risk (91%)110
. The
MPM 2025 registers low risk in terms of the independence and effectiveness of the media
authority (19%), unchanged compared to the previous year111
. In September 2024, the CNMC
launched a public consultation on the self-regulation and co-regulation systems for the rating
of audiovisual programmes, which includes a possible self-regulatory code of conduct on
age-ratings. This initiative is in line with the draft Organic Law on the protection of minors in
digital environments of June 2024.
The Law on state-owned radio and television was amended to change the composition of
the management board and its election system, giving more powers to its chairperson.
According to the Government, the amendment112
was approved to prevent parliamentary
deadlock in the renewal of the management board of RTVE, an issue that was already
highlighted as problematic in the 2024 Rule of Law Report113
. The amendment maintains the
two-thirds majority of the plenary session of Congress and the Senate, but if this is not
achieved, an absolute majority is sufficient. The decree also increases the membership of the
Board, from 10 to 15 members with full time commitment, establishes a parity of composition
between men and women, and enables the chairperson of the Board to sign contracts that will
not need the agreement of the Board. The Government contended that the number of vacant
posts – six out of ten – made it impossible to achieve a two thirds majority for a renewal, and
that the new system better represents the political and ideological plurality in Congress114
.
Stakeholders have cautioned that lowering the majority requirement could weaken the public
broadcaster’s independence and risks making Board appointments vulnerable to political
107
Draft Law for the Improvement of Democratic Governance in Digital Services and the Media. This law will
adapt the Spanish legislation to both the European Media Freedom Act (EMFA) and the Digital Services
Act (DSA).
108
Regulation (EU) 2024/1083 of the European Parliament and of the Council of 11 April 2024 establishing a
common framework for media services in the internal market and amending Directive 2010/13/EU
(European Media Freedom Act).
109
Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single
Market For Digital Services and amending Directive 2000/31/EC (Digital Services Act).
110
Media Pluralism Monitor (2025), country report for Spain, p. 18.
111
Media Pluralism Monitor (2025), country report for Spain, p. 10.
112
Royal Decree-Law 5/2024, of 22 October, amending Law 17/2006, of 5 June, on state-owned radio and
television, to adopt urgent measures relating to the legal regime applicable to the RTVE Corporation. The
Decree Law was adopted by Government and subsequently approved by Parliament.
113
See 2024 Rule of Law report, Spain, p. 25.
114
Congress endorsed 11 members of the Board proposed by the Government and supporting parties, while the
Senate approved its 4 representatives, all of them proposed by the main opposition party. Some of the new
members of the Board are linked to political parties.
15
interests115
. The News Councils116
of TVE and RNE criticised the Decree117
, asking for a
merit-based competition to guarantee the suitability of the Board members118
. The
Government argued119
that suitability is guaranteed because the proposed candidates must
first appear at a public hearing before the relevant Appointment Committees of the
Parliament, so that both Houses can assess their suitability for the position. The MPM
indicator on independence of public service media went down from high risk (67%) in 2024
to medium-high risk (62%) in 2025120
. Furthermore, some stakeholders continue to express
concern about the lack of independence and use of regional public service media for political
purposes121
.
Ownership transparency of media other than audiovisual media services, video sharing
platforms and influencers remains an area of concern, pending the adoption of new
legislation. The draft Law on Digital Services and Media envisages the creation of a public
registry of media supervised by the CNMC122
. Registration will be mandatory for national
media, which will have to keep updated information on both ownership and income received
from institutional advertising. The register will be available for free and will include media
from regional registries. The CNMC will not be able to work on the registry until the new
Law is adopted123
. For the MPM 2025, the transparency deficit that exists in all non-
audiovisual media will continue until the new registry is set up. It therefore continues to
record a very-high risk level (85%)124
.
The legal framework for state advertising remains unchanged, despite an increased
number of advertising campaigns. The Government aims to reform the Institutional
Advertising Law125
to incorporate criteria of transparency, objectivity, proportionality and
non-discrimination; oblige all public administrations to inform on advertising expenditure;
and set limits on public administrations’ funding for media126
. The draft law has not been
adopted yet, and, under the current law, the lack of information on final beneficiaries of
institutional advertising makes it difficult to assess the impact of institutional advertising and
commercial campaigns on the media market. An upward trend is observed in the number of
national institutional campaigns and their cost. The 2025 institutional advertising and
communication plan127
foresees EUR 161.2 million128
for 146 institutional campaigns, a 16%
increase over the 2024 plan and the highest amount since 2008. As regards the use of state
115
Country visit Spain, Association of Communications Users, Journalists’ associations; Hay Derecho (2025),
written input, p. 34. Media Pluralism Monitor (2025), country report for Spain, p. 32.
116
Internal bodies established by the Law on RTVE for the participation of professionals to ensure the
neutrality and objectivity of news content.
117
Joint statement from the News Councils of RNE and TVE on the decree law approved by the Government
for the renewal of the Board of Directors of RTVE, 22 October 2024.
118
Complain No. 211/2024 to the Council of Europe’s platform on the safety of journalists.
119
Spanish Government (2025a), p. 15.
120
Media Pluralism Monitor (2025), country report for Spain, p. 27.
121
Country visit Spain, Association of Communications Users, Journalists’ associations. Hay Derecho (2025),
written input, p. 38. Liberties Rule of Law report 2025, p. 962.
122
Through a reform of the General Law on Audiovisual communication 13/2022 of 7 July 2022.
123
Country visit Spain, CNMC.
124
2025 Media Pluralism Monitor, country report for Spain, p. 19.
125
Law on Advertising and Institutional Communication 29/2005, of 29 December 2005.
126
Spanish Government (2025), written input, p. 39.
127
2025 Plan for Advertising and Institutional Communication.
128
This figure does not include the 53 commercial campaigns planned in 2025 for 109.6 million euro, to which
Law 29/2005 does not apply.
16
advertising by public administrations at regional level, thirteen of the seventeen Spanish
Autonomous Communities have developed specific legislation on institutional advertising,
but only three of them could be considered fully transparent129
. Stakeholders criticise the use
of institutional advertising for capturing media and call for more transparency and fair criteria
in the allocation of public funds130
.
There has been no further progress on the recommendation to strengthen access to
information, pending adoption of new legislation131. The legal framework on access to
documents has not been changed yet. The Government, however, has pledged to adopt the
draft law on classified information132
as well as a new law on open administration to expand
transparency obligations. Spain has ratified the Council of Europe Convention on Access to
Official Documents133
. Public institutions and political parties increasingly have press
conferences where press statements are given without the possibility to ask questions or where
certain media are excluded134
. Overall, no further progress has been made on the
recommendation to strengthen access to information.
Despite steps foreseen through ongoing legislative proposals, journalists continue facing
increasing challenges regarding working conditions and safety. Since the publication of
the 2024 Rule of Law Report, six new alerts have been recorded for Spain in the Council of
Europe’s Platform to Promote the Protection of Journalism and Safety of Journalists135
,
relating to attacks on physical safety and integrity, harassment and intimidation of journalists,
and other acts having chilling effects on media freedom136
. The platform registers twenty-
seven active alerts in total. The Media Freedom Rapid Response platform137
has recorded
thirty-seven. Professional associations granted protection to journalists who had been targeted
online by one member of the Government138
or by political activists, some of whom are
accredited as journalists in the Parliament and abuse this position to hinder the work of other
journalists acting in their professional capacity139
. As a result, the Parliamentary Journalists
Association advocated for an urgent adoption of a review of Parliament´s internal rule of
procedure to guarantee the work of journalists140
. A proposal to this effect has been tabled by
a majority of political groups of the Parliament141
. In March 2025, a court in Madrid charged
four journalists with revealing confidential information when publishing on the content of a
police report in an ongoing case against the Prosecutor General. Journalists, professional
129
Observatorio de Medios (2025), Ranking de transparencia de la publicidad institucional de las CCAA 2024.
130
Country visit Spain, Journalists’ associations. Cuadernos de Periodistas, January 2025, p. 48. Liberties Rule
of Law report 2025, p. 960.
131
The 2024 Rule of Law Report recommended Spain to “advance with strengthening access to information,
in particular via revision of the Law on Official Secrets, taking into account European standards on access
to official documents”.
132
To replace the current Law on Official Secrets 9/1968 of 5 April 1968.
133
The Council of Europe Convention on Access to Official Documents (CETS No. 205), also known as the
Tromsø Convention, entered into force on 1 December 2020.
134
Impulso ciudadano, Hay Derecho (2025), written inputs, p. 3 and 39 respectively. Country visit Spain,
journalists’ associations.
135
Council of Europe, Platform to promote the protection of journalism and safety of journalists, Spain.
136
Spain has replied to the six alerts.
137
The Media Freedom Rapid Response (MFRR) is a Europe-wide mechanism that tracks, monitors and reacts
to press and media freedom violations in EU member states and candidate countries.
138
APM (2025a); APM (2025b).
139
FAPE (2024); FAPE (2025a); FAPE (2025b).
140
APP (2025).
141
410/000007 Proposal to amend the Rules of Procedure of the Congress of Deputies.
17
associations and civil society criticised this decision and highlighted the right to inform and
the confidentiality of sources142
. The draft law on the professional secrecy of journalism is
expected to be adopted by the Government shortly143
. Meanwhile, the October 2024
proposal144
to amend the Citizen Security Law whereby the taking of images of police actions
would no longer be sanctioned, continues being discussed in the Parliament. In December
2024, the Council of Ministers approved the Draft Organic Law on Rectification145
, allowing
false or inaccurate information that causes harm to individuals to be publicly corrected. The
law will include content creators with more than 100 000 followers on a single social network
or more than 200 000 on several networks. On 11 March 2025, the Government adopted the
draft Bill on Artificial Intelligence146
, which establishes as a serious infringement the failure
to properly label any image, video or audio generated or manipulated by AI147
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
Less than half of the companies surveyed in Spain express high levels of confidence in
the effectiveness of investment protection. 47% of companies are very or fairly confident
that investments are protected by law and courts148
. The main reason among companies for
their lack of confidence is the difficulty to obtain a fair compensation or to protect property
when something goes wrong149
. 62% of companies perceive the level of independence of the
national competition authority (National Markets and Competition Commission) as very or
fairly good150
. A number of judicial mechanisms are in place at the level of the Supreme
Court to ensure the implementation of administrative court judgments, including fines for
responsible officials for non-compliance, the possibility to take direct enforcement measures,
and to award direct damages151
.
The Spanish Constitutional Court has declared the Amnesty Law to be compatible with
the Constitution and four requests for preliminary rulings have been submitted to the
Court of Justice of the European Union. The “Organic Law on Amnesty for the
Institutional, Political and Social Normalisation of Catalonia”, which was the subject of
major controversy in Spain152
, entered into force on 11 June 2024 and on 26 June 2025, it was
declared to be compatible with the Constitution. The Amnesty Law has so far been applied to
more than 300 persons and provides for an amnesty applying to acts and events encompassing
criminal, administrative or accounting liability, defined both in terms of the dates of the acts
142
Country visit Spain, Journalists’ associations FAPE and APM. PDLI (2025), written input.
143
Country visit Spain, Spanish Government.
144
22/000131, Proposal for an Organic Law on the Protection of Freedoms and Citizen Security, 11 October
2024.
145
That should replace Organic Law 2/1984, of 26 March, regulating the right of rectification.
146
Bill for the Governance and fair use of Artificial Intelligence, adapting Spanish legislation to the Artificial
Intelligence Act.
147
Journalists expressed a preference for labelling of AI generated content through self-regulation. Country
visit Spain, Journalists’ associations.
148
2025 EU Justice Scoreboard, Figure 54.
149
2025 EU Justice Scoreboard, Figure 55. 37% and 32% of the surveyed investors respectively perceive the
frequent changes in legislation or concerns about the quality of the law-making process and the quality,
efficiency or independence of justice as a reason for the lack of confidence in investment protection.
150
2025 EU Justice Scoreboard, Figure 60.
151
2025 EU Justice Scoreboard, Figure 49. The data presented reflects exclusively the mechanisms in place at
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower
instance administrative courts.
152
See 2024 Rule of Law Report, Spain, p. 28. See also Opinion of the Venice Commission, CDL-
AD(2024)003.
18
and their connection with events around the “independence process” in Catalonia153
. The
Commission has been assessing the relevance of the amnesty law from an EU law
perspective, aspects of which are subject to requests for a preliminary ruling before the Court
of Justice of the European Union154
.
A draft law amending the Code of Criminal Procedure, including as regards popular
action in criminal investigations, was tabled. The draft law, tabled on 10 January 2025,
includes provisions circumscribing popular action in criminal investigations and proceedings
(“acción popular”). The “acción popular” is a mechanism laid down in Article 125 of the
Spanish Constitution and developed in the Spanish Criminal Procedure Code. It allows
natural and legal persons to bring a criminal action and intervene as a party in the
proceedings without being directly affected or harmed by a criminal offence. While the
proposal’s stated objective, considering a ruling of the Supreme Court155
, is to prevent
perceived abuses of this mechanism156
, some stakeholders have criticised the planned reform,
considering its envisaged limitations excessive and undermining in practice the value of this
mechanism157
. The draft law proposes to limit the number of criminal offences for which the
popular action can be exercised and requiring those who intend to exercise it to act under a
specific, relevant and sufficient link with the public interest protected in the corresponding
criminal proceedings. It also proposes to prohibit political parties and associations linked to
them, as well as judges, prosecutors and their associations, from exercising popular action,
and it further provides for the retroactive extinction of ongoing proceedings. The legislative
process is ongoing.
Initiatives aimed at fostering a rule of law culture have been taken forward, a new
equality body has been set up and several appointments to independent authorities and
bodies have been made. The Democracy Action Plan, approved on 17 September 2024,
includes a proposal for an obligation to hold an annual parliamentary debate in order to assess
the Government’s compliance with the rule of law and fundamental rights158
. The next
Congress of the World Conference on Constitutional Justice159
will take place in Madrid, in
October 2025, and will be dedicated to the “Rights of Future Generations”160
. The
Government continued working on the setting up of a new equality body, following a law
adopted in July 2022161
. The new Independent Authority for Equal Treatment and Non-
Discrimination, whose President was appointed on 27 May 2025, is tasked to protect and
promote equality and non-discrimination of all citizens both in the public and private sector.
A new President and Deputy of the Spanish Data Protection Agency were appointed on 26
153
This applies to acts committed between November 2011 and November 2023 related to the Catalan
“independence process”.
154
C-523/24, C-587/24, C-666/24 and C-123/25.
155
See also Spanish Supreme Court, ruling 459/2019 of 14 October 2019.
156
The draft law proposes to prohibit the launch of criminal investigations triggered by complaints of
individuals who rely only on press material and adds new grounds for the recusal of judges, preventing
them from ruling on cases on which they have made political statements.
157
Hay Derecho (2025), written input, p. 18; Independent Judicial Forum (2025), written input, p. 6; Judges
and Magistrates’ Association “Francisco de Vitoria” (2025), written input, p. 14; country visit Spain, Civic
Platform for the Judicial Independence.
158
Spanish Government (2025), written input, p. 49.
159
The World Conference on Constitutional Justice unites Constitutional Courts and Councils and Supreme
Courts across the world. Its aim is to foster constitutional justice – as constitutional review including human
rights case law – as a key element for democracy, the protection of human rights and the rule of law.
160
Country visit Spain, Constitutional Court.
161
Law 15/2022 of 12 July 2022 on equal treatment and non-discrimination.
19
February 2025. The Ombudsperson, which is the national human rights institution, accredited
with A status by the UN Global Alliance of National Human Rights Institutions (GANHRI),
published its annual report in March 2025, including different suggestions, reminders and
warnings related to citizens’ rights, to ensure that they are considered in the decision-making
process162
.
On 1 January 2025, Spain had 23 leading judgments of the European Court of Human
Rights pending implementation, the same number as the previous year163. At that time,
Spain’s rate of leading judgments from the past 10 years that remained pending was at 52%
(compared to 49% in 2024; 48% remained pending), and the average time that the judgments
had been pending implementation was 3 years and 3 months (compared to 2 years and 10
months in 2024)164
. The oldest leading judgment, pending implementation for 10 years,
concerns the lack of an effective suspensive remedy against decisions to remove asylum
seekers165
. As regards the respect of payment deadlines, on 31 December 2024 there was 1
case in total awaiting confirmation of payments (compared to 3 in 2023)166
. On 16 June 2025,
the number of leading judgments pending implementation had decreased to 22167
.
A draft law to reform the Citizen Security Law has been tabled so as to address
concerns previously raised by stakeholders. Civil society space continues to be considered
narrowed168
. The Democracy Action Plan includes the reform of the Citizen Security Law,
and a draft law on this matter has been tabled in October 2024. The aim of the reform is to
address the concerns raised by stakeholders169
in relation to the impact of the current law on
the right of assembly and the freedom of expression, as well as on the civic space in general
and specifically on human rights defenders and journalists.
162
Defensor del Pueblo (2025), Annual Report 2024.
163
For an explanation of the supervision process, see the website of the Council of Europe.
164
All figures calculated by the European Implementation Network (EIN) and based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 8.
165
Judgment of the ECtHR, 6528/11, A.C. and Others v. Spain, pending implementation since 2014.
166
Council of Europe (2025), p. 157.
167
Data according to the online database of the Council of Europe (HUDOC).
168
Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed
and closed.
169
2024 Rule of Law Report, Spain, p. 31.
20
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2025 Rule of Law report
can be found at https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en.
APM (2025a), The APM grants protection to journalist Ketty Garat, of 'The Objective', after the
accusation by Óscar Puente (La APM concede amparo a la periodista Ketty Garat, de 'The Objective',
tras el señalamiento por parte de Óscar Puente), https://www.apmadrid.es/comunicado/la-apm-
concede-amparo-a-la-periodista-ketty-garat-de-the-objective-tras-el-senalamiento-por-parte-de-oscar-
puente/
APM (2025b), The APM grants protection to Elisa Beni in the face of continued harassment by
Minister Óscar Puente (La APM concede amparo a Elisa Beni ante el hostigamiento continuado por
parte del ministro Óscar Puente), https://www.apmadrid.es/comunicado/la-apm-concede-amparo-a-
elisa-beni-ante-el-hostigamiento-continuado-por-parte-del-ministro-oscar-puente/
Asociación de Fiscales (2024), Press release from the Association of Public Prosecutors in relation to
the meeting held today with the Attorney General of the State (Comunicado de la Asociación de
Fiscales en relación a la reunion celebrada en el día de hoy con el Fiscal General del Estado),
http://www.asociaciondefiscales.es/index.php/general1/itemlist/date/2024/2
Asociación de Periodistas Parlamentarios (2025), The APP rejects behaviour contrary to the right to
information (La APP rechaza comportamientos contrarios al derecho a la información), La APP
rechaza comportamientos contrarios al derecho a la información | Periodistas Parlamentarios
Association of Prosecutors (2025), Contribution from the Association of Prosecutors for the 2025
Rule of Law Report.
Association of Women Judges of Spain (2025), Contribution from the Association of Women Judges
of Spain for the 2025 Rule of Law Report.
Centre for Media Pluralism and Media Freedom (2025), Media pluralism monitor 2025, Media
Pluralism Monitor – Centre for Media Pluralism and Media Freedom
Civio (2025), Regulating lobbying without independent control is a missed opportunity, 18 February
2025, https://civio.es/novedades/2025/02/18/regular-el-lobby-sin-un-control-independiente-es-una-
oportunidad-perdida/
Comisión de Publicidad y Comunicación Institucional (2025), 2025 Plan for Advertising and
Institutional Communication (PLAN 2025 de Publicidad y Comunicación Institucional),
https://www.lamoncloa.gob.es/serviciosdeprensa/cpci/Documents/Plan%202025.pdf
Consultative Council of European Judges (2015), Opinion n°18 on the position of the judiciary and its
relation with the other powers of state in a modern democracy, https://rm.coe.int/16807481a1
Council for the Judiciary (2025), Contribution from the Council for the Judiciary for the 2025 Rule of
Law Report.
Council of Europe: Committee of Ministers (2025), Supervision of the execution of judgments and
decisions of the European Court of Human Rights, 18th
Annual Report of the Committee of Ministers,
https://rm.coe.int/gbr-2001-18e-rapport-annuel-2024/1680b4d77d
Council of Europe: Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council
of Europe, https://rm.coe.int/16807096c1
21
Council of Europe: Venice Commission (2013), Italy – Opinion on the legislation on defamation
(CDL-AD(2013)038), https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-
AD(2013)038-e
Council of Europe: Venice Commission (2024), Spain – Opinion on the rule of law requirements of
amnesties with particular reference to the parliamentary bill “on the organic law on amnesty for the
institutional, political and social normalisation of Catalonia” (CDL-AD(2024)003).
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2024)003-e
Council of Europe’s platform on the safety of journalists (2024), Draft Decree Risks Weakening the
Independence of Public Broadcasting – Alert No. 211/2024,
https://fom.coe.int/en/alerte/detail/107641658
Council of the European Union (2025), Revised Annex to the Council Implementing Decision
Amending Implementing Decision of 13 July 2021 on the approval of the assessment of the recovery
and resilience plan for Spain, https://data.consilium.europa.eu/doc/document/ST-17099-2024-ADD-
1/en/pdf
Council of Transparency and Good Governance (2025), The Council resolved 31% more complaints
against the AGE and its public sector in 2024, a record year for the entry of files (El Consejo resolvió
un 31% más reclamaciones frente a la AGE y su sector público en 2024, año récord de entrada de
expedientes),
https://www.consejodetransparencia.es/ct_Home/en/comunicacion/actualidadynoticias/hemeroteca/20
25/20250227.html
Court of Justice of the European Union, judgment of 25 February 2025, joined cases Sąd Rejonowy w
Białymstoku and Adoreikė, C-146/23 and C-374/23, ECLI:EU:C:2025:109, para. 60.
Cuadernos de Periodistas (2024), N°49 - News coverage of a world at war (N°49 - Cobertura
informativa de un mundo en guerra), https://www.cuadernosdeperiodistas.com/portadas/cuadernos-
de-periodistas-analiza-la-cobertura-informativa-de-un-mundo-en-guerra/
Defensor del Pueblo (2025), Annual Report 2024, https://www.defensordelpueblo.es/wp-
content/uploads/2025/03/Defensor-del-Pueblo_Informe-anual-2024.pdf
Demócrata (2025), The regulation of lobbying in Spain: a key step towards the normalisation of the
activity in Spain, https://www.democrata.es/analisis-y-opinion/la-regulacion-del-lobby-en-espana-un-
paso-clave-hacia-la-normalizacion-de-la-actividad-en-espana/
Directorate-General for Communication (2025), Special Eurobarometer 557: corruption.
Draft Law for the Improvement of Democratic Governance in Digital Services and the Media.
Draft Law on Transparency and Integrity of the Activities of Interest Groups (121/000046),
https://www.congreso.es/public_oficiales/L15/CONG/BOCG/A/BOCG-15-A-46-1.PDF#page=1
Draft Organic Law for the Protection of the Professional Secrecy of Journalism (121/000135).
EPPO (2025a), Contribution from EPPO for the 2025 Rule of Law Report.
EPPO (2025b), 2024 Annual Report, https://www.eppo.europa.eu/sites/default/files/2025-
03/EPPO%20Annual%20Report%202024_2.pdf
European Commission (2024), Rule of Law Report.
European Commission (2025), EU Justice Scoreboard.
22
European Court of Human Rights, judgment of 22 July 2014, A.C. and Others v. Spain, 6528/11.
European Implementation Network (2025), Contribution from the European Implementation Network
for the 2025 Rule of Law Report.
European Network of Councils for the Judiciary (2025), Contribution from the European Network of
Councils for the Judiciary for the 2025 Rule of Law Report.
FAPE (2024), FAPE grants protection to Patricia Romero and Daniel Ríos (La FAPE concede el
amparo a Patricia Romero y Daniel Ríos), https://fape.es/la-fape-concede-el-amparo-a-patricia-
romero-y-daniel-rios/
FAPE (2025a), FAPE grants protection to Ana Pardo de Vera (La FAPE concede el amparo a Ana
Pardo de Vera), https://fape.es/la-fape-concede-el-amparo-a-ana-pardo-de-vera//
FAPE (2025b), FAPE and APP protect journalist Marta Monforte (La FAPE y la APP amparan a la
periodista Marta Monforte), Federación de Asociaciones de Periodistas de España – La FAPE y la
APP amparan a la periodista Marta Monforte
Fundación Baltasar (2025), Contribution from the Fundación Baltasar for the 2025 Rule of Law
Report.
General Council for the Judiciary (2025), Contribution from the General Council for the Judiciary for
the 2025 Rule of Law Report.
General Council of the Judiciary, Data repository on corruption proceedings,
https://www.poderjudicial.es/portal/site/cgpj/menuitem.6d388940a4bbb8815ba9c5c0c684caa0/?vgne
xtoid=3a6d051c8a924510VgnVCM1000006f48ac0aRCRD&vgnextfmt=formato1&vgnextlocale=en
&perfil=3&lang_choosen=en
GRECO (2014), Fourth Evaluation Round – Evaluation Report on Spain on corruption prevention in
respect of members of parliament, judges and prosecutors,
https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000
016806ca048
GRECO (2019), Fifth Evaluation Round – Evaluation Report on Spain on preventing corruption and
promoting integrity in central Governments (top executive functions) and law enforcement agencies,
https://rm.coe.int/fifth-evaluation-round-preventing-corruption-and-promoting-integrity-i/168098c691
GRECO (2021), Fourth Evaluation Round – Second Compliance Report, https://rm.coe.int/fourth-
evaluation-round-corruption-prevention-in-respect-of-members-of/1680a3fd50
GRECO (2022a), Fifth Evaluation Round – First Compliance Report, https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680a5dd9e
GRECO (2022b), Fourth Evaluation Round – Addendum to the Second Compliance Report.
GRECO (2025a), Fifth Evaluation Round – Second Compliance Report, https://rm.coe.int/grecorc5-
2023-8-final-eng-2nd-compliance-report-spain-public/1680b547d8
GRECO (2025b), Fourth Evaluation Round – 2nd
Addendum to the Second Compliance Report,
https://rm.coe.int/grecorc4-2024-10-final-eng-2nd-add-to-the-2nd-compliance-report-spain-
/1680b5482c.
Hay Derecho (2025), Contribution from Hay Derecho for the 2025 Rule of Law Report.
23
Impulso ciudadano (2025), Contribution from Impulso ciudadano for the 2025 Rule of Law Report.
Independent Judicial Forum (2025), Contribution from the Independent Judicial Forum for the 2025
Rule of Law Report.
Infobae (2025), Villoria takes office as President of the Independent Authority for the Protection of
Whistleblowers, 9 May 2025, https://www.infobae.com/espana/agencias/2025/05/09/villoria-toma-
posesion-como-presidente-de-la-autoridad-de-proteccion-del-informante/.
Judges and Magistrates’ Association “Francisco de Vitoria” (2025), Contribution from the Judges and
Magistrates’ Association “Francisco de Vitoria” for the 2025 Rule of Law Report.
Liberties (2025), Rule of Law report 2025, https://www.liberties.eu/f/vdxw3e.
News Councils of RNE and TVE (2024), Joint statement from the News Councils of RNE and TVE on
the decree law approved by the Government for the renewal of the Board of Directors of RTVE, 22
October 2024, https://x.com/CdiRNE/status/1848806924537762127
Newtral (2025), The regulation of lobbies under deliberation in Congress would require
members to reveal all proposals they receive, 11 June 2025, https://www.newtral.es/lobbies-
grupos-interes-reglamento-congreso/20250611/
Observatorio de Medios (2025), Ranking of transparency of institutional advertising in the
Autonomous Regions 2024 (Ranking de transparencia de la publicidad institucional de las CCAA
2024), https://observatoriodemedios.org/wp-content/uploads/2024/07/Informe-transparencia-2024.pdf
OECD Working Group on Bribery (2022), Spain needs to step up its foreign bribery enforcement
without delay, says the OECD Working Group on Bribery,
https://www.oecd.org/daf/antibribery/spain-needs-to-step-up-its-foreign-bribery-enforcement-
without-delay.htm
OECD (2025), OECD Anti-Bribery Convention Phase 4 Follow-Up Report on Spain: Implementing
the Convention and Related Legal Instruments, https://doi.org/10.1787/4f4eb067-en
Office for Conflicts of Interest (2024), Report on the degree of compliance with Law 3/2015, of 30
March, regulating the exercise of senior positions in the General State Administration (Informe sobre
el cumplimiento por los altos cargos de las obligaciones que les impone la Ley 3/2015, de 30 de
marzo, reguladora del ejercicio del alto cargo de la Administración General del Estado), Disposición
16683 del BOE núm. 193 de 2024, https://digital.gob.es/funcion-publica/incompatibilidad-y-
conflicto-intereses/informe-cumplimiento-altos-cargos
Office for Conflicts of Interest (2025), Report on the degree of compliance with Law 3/2015, of 30
March, regulating the exercise of senior positions in the General State Administration (Informe sobre
el cumplimiento por los altos cargos de las obligaciones que les impone la Ley 3/2015, de 30 de
marzo, reguladora del ejercicio del alto cargo de la Administración General del Estado), Disposición
2970 del BOE núm. 40 de 2025, https://digital.gob.es/funcion-publica/incompatibilidad-y-
conflicto-intereses/informe-cumplimiento-altos-cargos
Office for Conflicts of Interest of the Spanish Parliament (2025), 2024 Annual report on the
implementation of the Code of Conduct.
Platform in Defence of Freedom of Information (2025), Contribution from the Platform in Defence of
Freedom of Information for the 2025 Rule of Law Report.
24
Professional Association of the Magistracy (2025), Contribution from the Professional Association of
the Magistracy for the 2025 Rule of Law Report.
Proposal for an Organic Law on the Protection of Freedoms and Citizen Security (22/000131).
Spanish Government (2020), Fourth Open Government Plan (IV Plan de Gobierno Abierto),
https://transparencia.gob.es/transparencia/en/dam/jcr:2a0d9dfb-0ee6-4329-a254-
c83b09835f06/170123%20IV%20PLAN%20DE%20GOBIERNO%20ABIERTO_ACTUALIZACIO
N.pdf
Spanish Government (2024a), Framework document for the elaboration of the Fifth Open
Government Plan 2024-2028 (Documento marco para la elaboracion del Quinto Plan de Gobierno
Abierto 2024-2028), https://transparencia.gob.es/transparencia/en/dam/jcr:145644ea-1149-4250-a5b8-
06513778aab6/2024%20documento%20marco%20V%20Plan_aprobado_ACTUALIZADO.pdf
Spanish Government (2024b), Democracy Action Plan (Plan de acción por la democracia),
https://www.mpr.gob.es/prencom/notas/Documents/2024/2024-3002_Plan_de_accion.pdf
Spanish Government (2025), Input from the Spanish Government for the 2025 Rule of Law Report.
Spanish Government (2025a), additional written contribution for the 2025 Rule of Law Report.
Transparency Council (2025), Press release,
https://www.consejodetransparencia.es/ct_Home/comunicacion/actualidadynoticias/hemeroteca/2025/
20250227.html
Xnet (2022), Observations on the regulation of interest groups/lobbies, https://xnet-
x.net/es/observaciones-regulacion-grupos-interes-lobbies/
25
Annex II: Country visit to Spain
The Commission services held virtual meetings in March and April 2025 with:
• Access Info Europe
• Association of 'Abogados del Estado'
• Association of Media Users
• Association of Prosecutors
• Association of Women Judges of Spain
• Civic Platform for the Judicial Independence
• Civil Guard
• Constitutional Court
• Coordinator of Non-Governmental Organisations for Development in Spain
• Council for the Judiciary
• Court of Auditors
• European Journalists’ Association (APE)
• Foundation ‘Hay Derecho’
• General Council of Spanish Lawyers
• Independent Judicial Forum
• Judges and Magistrates’ Association “Francisco de Vitoria”
• Judges for Democracy
• Madrid Press Association (APM)
• Ministry of Finance
• Ministry of Foreign Affairs
• Ministry of Home Affairs
• Ministry of the Presidency, Justice and Relations with the Parliament
• Ministry of State Administration and Digital Reform
• National Commission of Markets and Competition
• National Council of Court Clerks
• National Police
• Office of Conflict of interests
• Ombudsperson's Cabinet
• Platform in Defence of Freedom of Information
• Platform "Tercer Sector"
• Professional and Independent Association of Prosecutors (APIF)
• Progressive Union of Prosecutors
• Representatives of Congress and Senate
• Spanish Chamber of Commerce
• Supreme Court
• Technical Cabinet of the Prosecutor General’s Office
• Transparency Council
• Transparency International España
• Xnet
26
* The Commission also met the following organisations in a number of horizontal meetings:
• Amnesty International
• Araminta
• Civil Liberties Union for Europe
• Civil Society Europe
• European Civic Forum
• European Partnership for Democracy
• European Youth Forum,
• International Commission of Jurists
• International Federation for Human Rights (FIDH)
• JEF Europe
• Philea – Philanthropy Europe Association.
• Transparency International