Key data
| Regulation | Resolution of October 6, 2026, from the Bank of Spain, publishing the sanctions imposed for serious breach against CBNK Banco de Colectivos, SA, and members of its board of directors |
|---|---|
| Official Gazette Publication | October 15, 2026 |
| Entry into force | Not specified (informational publication) |
| Direct affected parties | CBNK Banco de Colectivos, SA and four members of its board of directors |
| Indirect affected parties | Credit institutions with executives and remuneration policies |
| Category | Business Regulation — Banking supervision |
| Fine to the entity | €300,000 (after 40% reduction) |
| Fines to board members | Between €10,800 and €30,000 per board member (after 40% reduction) |
| Reduction applied | 40% for voluntarily accepting the reduction provided in Law 39/2015 |
| Breached regulation | Law 10/2014, on the organization, supervision and solvency of credit institutions |
| Proceedings initiated | April 2025 |
| Proceedings resolved | March 2026 |
| Official Gazette Reference | BOE-A-2026-21520 |
CBNK Banco de Colectivos and four members of its board of directors have been fined by the Bank of Spain for failing to comply with remuneration classification requirements established in the Law 10/2014, on the organization, supervision and solvency of credit institutions. The resolution, published in the Official Gazette on October 15, 2026 with reference BOE-A-2026-21520, makes public sanctions that are now final and affect both the entity and individuals in its governing body.
The ruling does not create new obligations for third parties, but it is a clear signal from the supervisor: the remuneration policy for executives in banking is under scrutiny, and classification errors have direct economic and personal consequences for board members.
What does this regulation establish?
The resolution publishes the final sanctions imposed by the Bank of Spain against CBNK Banco de Colectivos and four board members for a serious breach of banking organization regulations.
The specific non-compliance was as follows: the entity did not classify 100% of extraordinary contributions to executive savings plans as "discretionary pension benefits." This classification is mandatory under Law 10/2014 and is part of the remuneration policies that credit institutions must apply to their executives and board members.
"Discretionary pension benefits" are a specific remuneration category within European and Spanish banking regulation. Classifying them correctly is relevant because it determines how they are computed in the calculation of variable remuneration, what limits apply, and what information must be disclosed. Failing to do so correctly means concealing or distorting the actual structure of executive compensation.
| Sanctioned party | Type of sanction | Amount (with 40% reduction) |
|---|---|---|
| CBNK Banco de Colectivos, SA | Serious breach — entity | €300,000 |
| Board member 1 | Serious breach — natural person | €30,000 |
| Board member 2 | Serious breach — natural person | Between €10,800 and €30,000 |
| Board member 3 | Serious breach — natural person | Between €10,800 and €30,000 |
| Board member 4 | Serious breach — natural person | €10,800 |
Note: The resolution does not publish the names of the sanctioned board members. Individual amounts range between €10,800 and €30,000, all already with the 40% reduction applied for voluntarily accepting early payment provided in article 85 of the Law 39/2015.
Economic and operational impact
The direct economic impact of this resolution falls exclusively on CBNK and its four board members. However, the operational impact for the banking sector in general is significant:
- Personal responsibility of board members: Fines are not only for the entity. Four members of the board of directors have been sanctioned individually, with amounts up to €30,000 per person. This makes oversight of remuneration policy a personal and direct responsibility of governing bodies.
- Total cost of proceedings: Adding the fine to the entity (€300,000) and the four individual sanctions (between €10,800 and €30,000 each), the total cost of the proceedings exceeds €340,000 even after applying the 40% reduction.
- Deterrent effect: Publication in the Official Gazette serves as supervisory transparency. The entity's name is recorded publicly, with consequent reputational impact.
- Duration of proceedings: The process extended from April 2025 to March 2026, nearly a year, with the legal and compliance management costs that this entails.
Who does it affect?
- CBNK Banco de Colectivos, SA: Directly affected with the €300,000 sanction.
- The four sanctioned board members: Personal economic responsibility of between €10,800 and €30,000 each.
- Spanish credit institutions with executives: Any bank, savings bank or credit cooperative that has savings or pension plans for executives must review whether it correctly classifies contributions as "discretionary pension benefits."
- Boards of directors of financial entities: Board members are individual responsible parties for compliance with remuneration policy. It is not just an obligation of the compliance department.
- Human Resources and Compliance Directors in banking: Responsible for designing, documenting and correctly applying executive remuneration policy in accordance with Law 10/2014.
Practical example
Suppose a mid-sized bank makes extraordinary contributions to its chief executive officer's savings plan in the amount of €150,000 annually. If the bank classifies them as "fixed remuneration" instead of "discretionary pension benefits," it is breaching Law 10/2014, exactly as CBNK did.
In that scenario, the Bank of Spain could initiate sanctioning proceedings. Based on the CBNK precedent, the entity could face a fine of €300,000 (or higher, depending on severity and entity size), and each board member involved in approving that remuneration policy could receive individual sanctions of between €10,800 and €30,000. If the proceedings also extend for a year, legal and internal management costs must be added.
The 40% reduction for voluntary payment (Law 39/2015) only applies if the entity and board members expressly accept it, as CBNK did. Without that reduction, the amounts would be significantly higher.
What should companies do now?
- Review the classification of contributions to executive savings plans: Verify that 100% of extraordinary contributions to pension or savings plans for executives and board members is correctly classified as "discretionary pension benefits" under Law 10/2014.
- Audit the current remuneration policy: Commission an internal or external review of the executive remuneration policy to detect possible deviations before the supervisor does.
- Involve the board of directors: Ensure that board members understand their individual responsibility in approving and overseeing remuneration policy. Personal sanctions of up to €30,000 are a clear incentive.
- Document and update compliance procedures: Maintain documentary evidence that remuneration classification is reviewed periodically and complies with current regulations.
- Evaluate acceptance of reductions in case of proceedings: If notification of sanctioning proceedings is received, evaluate with legal advice the advisability of accepting the 40% reduction provided in article 85 of Law 39/2015, as CBNK and its board members did.
Frequently asked questions
How much was the fine to CBNK Banco de Colectivos by the Bank of Spain?
CBNK Banco de Colectivos was fined €300,000. This amount already includes the 40% reduction applied for voluntarily accepting early payment provided in article 85 of Law 39/2015. Without that reduction, the original sanction would have been higher.
What sanction did CBNK's board members receive individually?
The four sanctioned board members received individual fines of between €10,800 and €30,000 each, also with the 40% reduction already applied. The resolution does not publish the names of the board members, but it does publish the amounts of each sanction.
What specific error did CBNK make in its remuneration?
CBNK did not classify 100% of extraordinary contributions to executive savings plans as "discretionary pension benefits," as required by Law 10/2014 on the organization, supervision and solvency of credit institutions. This incorrect classification distorts the actual structure of executive variable remuneration.
What is the 40% reduction for Law 39/2015 in banking sanctions?
The Law 39/2015 on Common Administrative Procedure provides in article 85 for a reduction in the sanction amount when the offender voluntarily acknowledges responsibility and/or pays in advance. CBNK and its four board members accepted this reduction, which resulted in a 40% savings on the original sanction amounts.
Which banks should review their remuneration policy after this sanction?
All Spanish credit institutions that have savings or pension plans for executives should review whether they correctly classify contributions as "discretionary pension benefits." The CBNK resolution is a clear precedent that the Bank of Spain actively supervises this aspect and that responsibility also extends to board members individually.
Official source
View complete regulation at official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-21520
