Key data
| Regulation | Royal Decree 644/2026, of 28 July |
|---|---|
| Modified regulation | Royal Decree 1009/2023, of 5 December (basic ministerial organizational structure) |
| Publication | 29 July 2026 |
| Entry into force | 29 July 2026 |
| Affected parties | Candidates for General Director of the Treasury and Financial Policy; financial supervisory bodies (Bank of Spain, CNMV) |
| Category | Public Sector |
| Year | 2026 |
| Precedent | Similar exception applied in 2005 |
The management of public debt, financial policy, sustainable finance and the prevention of money laundering require a highly specialized technical profile. The Royal Decree 644/2026 recognizes this reality and modifies the basic organizational structure of ministerial departments to include the General Directorate of the Treasury and Financial Policy in the list of exceptions that allow the appointment of its head without proving the status of career civil servant of subgroup A1.
This is not a radical break: there is a direct precedent from 2005 in which a similar exception was applied. What this decree does is update and formalize that possibility within the current regulatory framework.
What does this regulation establish?
Royal Decree 1009/2023, of 5 December, established the basic organizational structure of ministerial departments. Within that structure, the general rule is that heads of general directorates must be career civil servants of subgroup A1. However, the regulation already contemplated a list of exceptions for positions requiring high technical specialization.
Royal Decree 644/2026 incorporates the General Directorate of the Treasury and Financial Policy into that list of exceptions. The specific change is as follows:
| Aspect | Before (RD 1009/2023) | After (RD 644/2026) |
|---|---|---|
| Requirement to be General Director of the Treasury | Career civil servant subgroup A1 (general rule) | Can also be another public employee, without needing to be A1 civil servant |
| Enabled profiles | A1 civil servants of the General State Administration | A1 civil servants + public employees of supervisory bodies (Bank of Spain, CNMV and similar) |
| Regulatory justification | No specific exception applied | High technical specialization in public debt, financial policy, sustainable finance and prevention of money laundering |
| Precedent | — | Similar exception applied in 2005 |
The areas of specialization that justify the exception are, according to the decree itself:
- Public debt management
- Financial policy
- Sustainable finance
- Prevention of money laundering
Economic and operational impact
For most private companies, this decree does not generate direct obligations or immediate costs. Its impact is institutional and strategic: it affects who can lead the State's financial policy and, therefore, the technical quality of decisions that impact public debt, financial regulation and the fight against money laundering.
For supervisory bodies such as the Bank of Spain and the CNMV, the measure opens a real avenue for their employees to access the position without needing to be career civil servants A1 of the General State Administration. This can influence talent mobility between the public financial sector and central administration.
For the private financial sector, the professionalization of the position can translate into greater technical coherence in decision-making on public debt and financial regulation, which has indirect implications for the State's financing costs and the regulatory framework in which banks, asset managers and financial entities operate.
Who does it affect?
- Candidates for the position of General Director of the Treasury and Financial Policy: can now apply for the position without being career civil servants of subgroup A1.
- Public employees of the Bank of Spain: profile expressly contemplated as a potential candidate.
- Public employees of the CNMV: equally enabled by the new exception.
- Other employees of financial supervisory authorities: any public employee of bodies with financial supervision functions may fall within the scope of the exception.
- A1 civil servants of the General State Administration: remain eligible; the regulation expands the profile, does not exclude them.
- Private financial sector (banks, asset managers, financial entities): affected indirectly by the technical quality of leadership in the General Directorate of the Treasury.
Practical example
Imagine a senior technician from the Bank of Spain with 15 years of experience in debt market supervision and implementation of sustainable finance frameworks. Until the entry into force of Royal Decree 644/2026, this professional could not be appointed General Director of the Treasury and Financial Policy because he was not a career civil servant of subgroup A1 of the General State Administration.
As of 29 July 2026, that same profile becomes eligible to hold the position. The Government can assess their practical experience in public debt management, international financial policy and prevention of money laundering without the civil service condition being a formal obstacle. This is exactly the type of profile that the regulation seeks to facilitate, in line with the precedent already applied in 2005.
What should companies do now?
- Supervisory bodies (Bank of Spain, CNMV): review whether the new exception opens opportunities for mobility of senior technical profiles to the General State Administration and assess its impact on internal talent management.
- Private financial entities: monitor who holds the position of General Director of the Treasury, as their technical profile can influence the direction of public debt policy and regulatory development in sustainable finance and money laundering prevention.
- Compliance and regulatory departments: take note of the change as a signal of the direction the Government wants to imprint on financial policy: greater technical weight and practical experience in international financial supervision.
- Advisors and consultants in the public financial sector: update their knowledge about access requirements for senior positions in the Administration, as the list of exceptions to the A1 requirement has been expanded by this regulation.
Frequently asked questions
What exactly changes with Royal Decree 644/2026 for the General Director of the Treasury?
The decree modifies Royal Decree 1009/2023 to include the General Directorate of the Treasury and Financial Policy in the list of exceptions that allow the appointment of its head without being a career civil servant of subgroup A1. As of 29 July 2026, other public employees can also apply for the position, especially from supervisory bodies such as the Bank of Spain or the CNMV.
Are A1 civil servants excluded from the position of General Director of the Treasury?
No. The measure expands the range of candidates, but does not exclude career civil servants of subgroup A1. These remain fully eligible for the position.
Why is this exception justified for the Treasury and not for other general directorates?
The justification is the high technical specialization required in four specific areas: public debt management, financial policy, sustainable finance and prevention of money laundering. These matters require practical experience in the international financial sector that is not always acquired in the traditional civil service career.
Is there any precedent for this exception for the General Director of the Treasury?
Yes. The decree itself recognizes that there is a similar precedent applied in 2005, which makes this measure an update and formalization of a practice already used previously, not an absolute novelty.
When does Royal Decree 644/2026 enter into force?
Royal Decree 644/2026 entered into force on the same day as its publication in the BOE: 29 July 2026. There is no transitional period or adaptation period.
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-2026-16441