Key data
| Regulation | Royal Decree 519/2026, of June 24 |
|---|---|
| Publication | June 25, 2026 |
| Entry into force | June 25, 2026 (urgent processing) |
| Affected parties | Spanish companies with export or investment projects in Ukraine that request FIEM financing |
| Category | Aid and Subsidies |
| Modified regulation | FIEM Regulation, approved by Royal Decree 1797/2010, of December 30 |
| Reimbursable financing limit | 100 million euros accumulated |
| Non-reimbursable financing limit | 100 million euros accumulated |
| Total available limit | 200 million euros |
Spanish companies with projects in Ukraine have had access since June 25, 2026 to an official financing window with exceptional conditions. Royal Decree 519/2026 modifies the Regulation of the Fund for the Internationalization of the Enterprise (FIEM) to enable up to 200 million euros in financial support linked to Ukraine's reconstruction.
The regulation responds to the strategic opportunity that Ukraine's reconstruction represents for Spanish export and investment sectors, and adapts the FIEM framework—in force since Royal Decree 1797/2010—to a context of elevated country risk that ordinary mechanisms could not cover.
What does this regulation establish?
Royal Decree 519/2026 introduces four specific changes to the FIEM Regulation:
| Change | Previous situation (RD 1797/2010) | New situation (RD 519/2026) |
|---|---|---|
| Guarantee requirements in reimbursable operations | Standard risk levels required | Risk levels higher than usual are admitted for operations with Ukrainian entities |
| Non-reimbursable financing | Limited to consulting and technical assistance | Expanded beyond consulting and technical assistance |
| Authorization of exceptional operations | No specific exceptional regime existed | Require Council of Ministers Agreement or allocation to specific FIEM-Ukraine line |
| Composition of the FIEM Committee | No specific representation for Ukraine | Spanish Office for Ukraine Reconstruction is integrated |
Operations under the new exceptional regime will be channeled through a specific line called FIEM-Ukraine, or will require express authorization through Council of Ministers Agreement. This ensures political control over the use of public funds, without adding additional bureaucracy to requesting companies.
Economic and operational impact
The impact for companies is fundamentally an opportunity to access financing that did not previously exist or was inaccessible due to Ukraine's risk profile:
- Reimbursable financing (loans): up to 100 million euros accumulated for operations with Ukrainian entities, with flexible guarantees. Companies that previously could not access the FIEM due to Ukraine's country risk can now do so.
- Non-reimbursable financing (subsidies/direct aid): up to 100 million euros accumulated, with expanded scope that goes beyond consulting and technical assistance. This opens the door to larger-scale projects: works, supplies, equipment.
- No additional burdens: the regulation was processed urgently and does not impose new administrative obligations on companies.
- Enhanced supervision: the integration of the Spanish Office for Ukraine Reconstruction in the FIEM Committee ensures institutional coordination and agility in management.
Who does it affect?
- Spanish exporting companies with contracts or projects in Ukraine that need official financing.
- Construction, engineering or infrastructure companies interested in Ukrainian reconstruction tenders.
- Consulting, technical assistance and professional services companies with activity in Ukraine.
- Supplier companies of equipment, machinery or materials for projects in Ukraine.
- Financial entities that act as intermediaries in FIEM operations with Ukrainian counterparts.
- Advisors and consultants who accompany companies in internationalization processes towards Ukraine.
Practical example
A Spanish civil engineering company wants to participate in the reconstruction of infrastructure in a Ukrainian city. The contract amounts to 15 million euros with a Ukrainian public entity. Before Royal Decree 519/2026, the FIEM could not finance this operation because the risk profile of the Ukrainian counterpart exceeded usual thresholds and available guarantees were not accepted.
With the new regulation, the company can request FIEM reimbursable financing under the exceptional FIEM-Ukraine regime. The operation is authorized through Council of Ministers Agreement or allocated directly to the FIEM-Ukraine line. The company obtains official financial support to execute the contract, with guarantee conditions adapted to the reconstruction context, within the accumulated limit of 100 million euros enabled for this type of operation.
What should companies do now?
- Evaluate whether you have active or potential projects in Ukraine that may fit within the reconstruction framework: works, supplies, consulting, equipment or technical assistance.
- Contact the State Secretariat for Trade (FIEM manager) to learn about the specific requirements of the FIEM-Ukraine line and application deadlines.
- Review whether your operation requires Council of Ministers Agreement or can be allocated directly to the FIEM-Ukraine line, as the procedure varies.
- Prepare your project documentation: technical description, Ukrainian counterpart, amount, available guarantees and justification of the link to reconstruction.
- Consult the Spanish Office for Ukraine Reconstruction, now integrated in the FIEM Committee, to identify specific tender opportunities aligned with your activity.
- Act quickly: the limits are accumulated (€100M reimbursable + €100M non-reimbursable) and will be exhausted by order of application as operations are approved.
Frequently asked questions
How much money is available in the FIEM for projects in Ukraine?
Royal Decree 519/2026 enables a total of 200 million euros: up to 100 million in reimbursable financing (loans with flexible guarantees) and up to 100 million in non-reimbursable financing (subsidies and direct aid expanded beyond consulting and technical assistance). Both limits are accumulated.
What type of projects in Ukraine can access the FIEM with the new regulation?
Any project linked to Ukraine's reconstruction in which a Spanish company participates: infrastructure works, equipment supply, consulting, technical assistance and, thanks to the expansion of non-reimbursable financing, also activities that were previously excluded. The counterpart can be a Ukrainian public or private entity.
How is an operation authorized under the new exceptional FIEM-Ukraine regime?
Operations under exceptional regime require Council of Ministers Agreement or allocation to the specific FIEM-Ukraine line. Management is the responsibility of the State Secretariat for Trade, and the FIEM Committee—now with the Spanish Office for Ukraine Reconstruction integrated—participates in the evaluation.
What changes regarding the previous FIEM to operate in Ukraine?
Before RD 519/2026, the FIEM required standard risk levels that Ukraine could not meet, which blocked financing. Now risk levels higher than usual are admitted for operations with Ukrainian entities. Additionally, non-reimbursable financing, previously limited to consulting and technical assistance, is expanded to other uses.
Does this regulation impose new obligations or administrative burdens on companies?
No. Royal Decree 519/2026 was processed urgently and does not impose additional administrative burdens on companies. The changes affect the internal functioning of the FIEM and the authorization requirements for exceptional operations, not the procedures that requesting companies must follow.
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-2026-13761