Creditors' Concourse Agreement 2026: what data does the Government share and how it affects your company

Key data

The Ministry of Economy, Trade and Business has had direct access since June 26, 2026 to the microdata from the Public Insolvency Register Portal, thanks to an agreement signed with the College of Registrars for a maximum amount of €600,000. The Resolution of June 23, 2026 from the Under-Secretariat formalizes this agreement and publishes it in the BOE.

The stated objective is to improve the cyclical and structural analysis of the Spanish economy, especially in crisis contexts, and to evaluate the effectiveness of the current insolvency framework. For companies in financial difficulties, this means that their procedural and economic data will form part of a systematic analysis by the Government.

What does this regulation establish?

The agreement regulates the periodic supply of microdata from the College of Registrars to the Ministry of Economy. Below are all the key elements of the agreement:

The Monitoring Committee is a relevant element: its mandate to expand data fields and adapt to legislative changes indicates that the scope of the agreement may grow over time, incorporating new variables about debtors or proceedings.

Economic and operational impact

For companies in creditors' concourse, the direct impact is zero in terms of cost: there is no fee, payment obligation or additional procedure derived from this agreement. The data already exists in the Public Insolvency Register and the agreement only regulates its transfer between public bodies.

However, there are operational and strategic implications worth considering:

• Greater statistical scrutiny: The data from your insolvency proceeding will be systematically analyzed by the Directorate General of Economic Policy. This may influence future reforms of the insolvency framework.
• Evaluation of the legal framework: The Government will use this data to evaluate the effectiveness of the current Insolvency Law, which may result in regulatory changes affecting future proceedings.
• Confidentiality guaranteed: The express prohibition on publishing the data in any format protects the identity of debtor companies against third parties.
• Cost to public funds: The agreement represents up to €600,000 in public spending, financed by the Ministry of Economy.

Who does it affect?

• Companies in creditors' concourse: Their procedural and economic data will be included in the microdata supplied to the Ministry.
• Companies in pre-insolvency proceedings: They are also within the scope of the agreement, not just formally declared insolvencies.
• Insolvency administrators: They must know that the information of the proceedings they manage will feed government analyses.
• Financial advisors and restructurers: Systematic data analysis may anticipate changes in the insolvency legal framework that affect their strategies.
• Directorate General of Economic Policy: Recipient of the data and responsible for its analysis and custody.
• College of Registrars: Data provider, will receive up to €600,000 for the supply.

Practical example

Imagine an industrial company based in Valencia files for creditors' concourse in September 2026. All information registered in the Public Insolvency Register Portal — characteristics of the proceeding, debtor data, type of concourse — will become part of the microdata that the College of Registrars periodically delivers to the Ministry of Economy in encrypted Excel format.

The company will receive no additional notification, will not pay any new fees and will not need to complete any specific procedure derived from this agreement. Its data will be protected by the strict confidentiality obligations of the agreement and by the express prohibition on publication in any format. The Ministry will use that information in aggregate form to evaluate, for example, whether the number of insolvencies in the industrial sector has increased compared to previous quarters or whether pre-insolvency proceedings are being effective in preventing liquidation.

If the Monitoring Committee decides to expand the data fields collected — something the agreement expressly allows — additional information could be incorporated about the company's liabilities or the duration of the proceeding, always under the same confidentiality guarantees.

What should companies do now?

1. Verify if you are in an active insolvency or pre-insolvency proceeding: If your company is listed in the Public Insolvency Register, your data already forms part of the universe of microdata that will be transferred to the Ministry. No action is required, but it is good to know.
2. Inform your legal and financial advisor: Insolvency administrators and restructuring advisors must know about this agreement to anticipate possible regulatory changes resulting from government analysis.
3. Monitor the activity of the Monitoring Committee: This committee may expand the data fields collected. Any change in the scope of the agreement could be published in the BOE as a modification or amendment.
4. Do not complete any additional procedures: This agreement does not generate direct obligations for affected companies. There are no adaptation deadlines or sanctions for non-compliance applicable to debtors.
5. Anticipate possible reforms of the insolvency framework: The stated objective of the agreement is to evaluate the effectiveness of insolvency regulations. If your company operates in sectors with high insolvency rates, it is advisable to closely monitor the Ministry of Economy's legislative initiatives in the coming months.

Official source

Consult complete regulation in official source

Notice: 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-2026-13923