Congress repeals the lobby transparency law

The Congress of Deputies agreed on September 16, 2026, to repeal Royal Decree-Law 21/2026, of August 25, on transparency and integrity of interest group activities, barely three weeks after it entered into force. The agreement is ordered to be published by the Resolution of September 16, 2026, of the Congress, disseminated in the Official State Gazette (BOE) no. 231, of September 18, 2026, section I, with official reference BOE-A-2026-19419. The decision is adopted under Article 86.2 of the Constitution and bears the signature of the President of the Congress, Francina Armengol Socias.

The repealed regulation had been published in the Official State Gazette no. 209, of August 26, 2026, with reference BOE-A-2026-18148, and entered into force the day following its publication, August 27. It was approved by the Council of Ministers at its meeting on August 25, 2026, at the proposal of the Minister for Digital Transformation and the Civil Service, and sanctioned by King Felipe VI, countersigned by the President of the Government, Pedro Sánchez Pérez-Castejón.

The royal decree-law was justified by the need to fulfill milestone CID 432, corresponding to reform C11.R1 of the Recovery, Transformation and Resilience Plan, and was aligned with the Action Plan for Democracy, the State Plan for the Fight against Corruption, the recommendations of the Council of Europe’s GRECO, and the OECD principles on lobbying transparency. It consisted of five titles, twenty articles, three additional provisions, one repealing provision, and six final provisions.

What the annulled regulation established

• A state-wide Register of interest groups, public, free, and with mandatory registration, managed by the Transparency and Good Governance Council.
• A legislative footprint report, mandatory in every regulatory drafting process, including the identity of the officials contacted and the contributions received.
• Codes of conduct for interest groups and a specific sanctioning regime.
• The modification of Law 3/2015, of March 30, on high-ranking officials, which prohibited exercising influence activities for two years following the termination of office.
• The modification of the Statute of the Transparency and Good Governance Council (Royal Decree 615/2024, of July 2), with the creation of the Sub-directorate General for Transparency and Integrity of Interest Group Activities.

Planned sanctions and obligations

• Very serious infractions: cancellation or prohibition of registration for between two and five years and a fine of 5,000 to 40,000 euros.
• Serious infractions: suspension of registration from three months to one year and a fine of 2,000 to 5,000 euros.
• Minor infractions: warning.
• Annual update of financial information, with the registration expiring after three years without updating.
• Publication of the agendas of senior officials and regulatory footprint reports on the Transparency Portal of the General State Administration.

Who it affected

The scope of application was limited to the General State Administration and its institutional public sector. Personnel susceptible to influence included senior officials, cabinet members with trust or special advisory functions, public management personnel, temporary staff, and members of advisory bodies. Public administrations, international organizations, political parties, and professional associations were excluded from the concept of interest groups when exercising public functions.

In the same session, Congress also agreed to the validation of Royal Decree-Law 22/2026, of September 1, on urgent support measures for the city of Ceuta, likewise published in the Official State Gazette no. 231 with reference BOE-A-2026-19420.

The repeal nullifies the first mandatory state lobby register and the associated sanctioning regime, meaning that meetings and contacts with senior officials are once again without the obligation of prior registration or publicity on the Transparency Portal. The sector that exercises institutional pressure and the affected ministries thus lose, for now, the traceability framework that the regulation had introduced.

Source: Official State Gazette, no. 231, of September 18, 2026, section I. General Provisions, page 123452 (official reference: BOE-A-2026-19419).