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
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Spain, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN 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 {COM(2025) 900 final} - {SWD(2025) 901 final} - {SWD(2025) 902 final} - {SWD(2025) 903 final} - {SWD(2025) 904 final} - {SWD(2025) 905 final} - {SWD(2025) 906 final} - {SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} - {SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} - {SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} - {SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 921 final} - {SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} - {SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 927 final} - {SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} - {SWD(2025) 931 final}  
 
 
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. 

1 

 
 
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. 

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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. 

3 

 
 
 
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. 

4 

 
 
 
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. 

5 

 
 
 
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. 

6 

 
 
 
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. 

7 

 
 
 
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 
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 

its  President48.  According 

the  recent  appointment  of 

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). 

8 

 
 
 
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. 

9 

 
 
 
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.  

10 

 
 
 
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). 

11 

 
 
 
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. 

12 

 
 
 
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. 

13 

 
 
 
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. 

14 

 
 
 
 
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.  

15 

 
 
 
 
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. 

16 

 
 
 
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. 

17 

 
 
 
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.  

18 

 
 
 
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. 

19 

 
 
 
 
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 
https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

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 
https://civio.es/novedades/2025/02/18/regular-el-lobby-sin-un-control-independiente-es-una-
2025, 
oportunidad-perdida/  

Comisión  de  Publicidad  y  Comunicación  Institucional  (2025),  2025  Plan  for  Advertising  and 
Institucional), 
(PLAN  2025  de  Publicidad  y  Comunicación 
Institutional  Communication 
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 

20 

 
 
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, 
(CDL-AD(2024)003). 
normalisation 
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2024)003-e 

of  Catalonia” 

political 

social 

and 

Council of Europe’s platform on the safety of journalists (2024), Draft Decree Risks Weakening the 
Independence 
211/2024, 
https://fom.coe.int/en/alerte/detail/107641658 

Broadcasting 

Public 

Alert 

No. 

of 

– 

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 
content/uploads/2025/03/Defensor-del-Pueblo_Informe-anual-2024.pdf 

(2025),  Annual  Report  2024,  https://www.defensordelpueblo.es/wp-

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 
03/EPPO%20Annual%20Report%202024_2.pdf 

2024  Annual  Report, 

(2025b), 

https://www.eppo.europa.eu/sites/default/files/2025-

European Commission (2024), Rule of Law Report. 

European Commission (2025), EU Justice Scoreboard. 

21 

 
 
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. 

of 

General  Council 
https://www.poderjudicial.es/portal/site/cgpj/menuitem.6d388940a4bbb8815ba9c5c0c684caa0/?vgne
xtoid=3a6d051c8a924510VgnVCM1000006f48ac0aRCRD&vgnextfmt=formato1&vgnextlocale=en
&perfil=3&lang_choosen=en  

Judiciary,  Data 

corruption 

repository 

proceedings, 

the 

on 

GRECO (2014), Fourth Evaluation Round – Evaluation Report on Spain on corruption prevention in 
respect 
prosecutors, 
https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000
016806ca048 

parliament, 

members 

judges 

and 

of 

of 

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. 

22 

 
 
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 
Bribery, 
https://www.oecd.org/daf/antibribery/spain-needs-to-step-up-its-foreign-bribery-enforcement-
without-delay.htm  

Working 

OECD 

Group 

delay, 

says 

the 

on 

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.  

23 

 
 
 
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 
release, 
https://www.consejodetransparencia.es/ct_Home/comunicacion/actualidadynoticias/hemeroteca/2025/
20250227.html 

Council 

(2025), 

Press 

(2022),  Observations  on 

Xnet 
x.net/es/observaciones-regulacion-grupos-interes-lobbies/ 

regulation  of 

the 

interest  groups/lobbies,  https://xnet-

24 

 
 
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 

25 

 
 
 
 
* 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 

26