Key data
| Regulation | Order ITU/920/2026, of 27 August |
|---|---|
| Modified regulation | Royal Decree 768/2025, of 2 September (Annex I) |
| BOE Publication | 3 September 2026 |
| Entry into force | 4 September 2026 |
| Direct stakeholders | Hisdesat Servicios Estratégicos, SA; INTA; Ministry of Defence |
| Category | Grants and Subsidies — National Defence |
| Total loan amount | €1,011.85 million (no change) |
| 2026 annuity increase | +€65,775,300 |
| 2029 annuity reduction | -€65,775,300 |
| Legal basis | Article 346 of the TFEU (exclusion of state aid regime for defence) |
Hisdesat Servicios Estratégicos, SA will receive €65.7 million additional in 2026 thanks to the modification of the disbursement schedule of the public loan approved by Royal Decree 768/2025. Order ITU/920/2026, published on 3 September 2026, adjusts Annex I of that royal decree following the request submitted by the company in April 2026, citing cash flow problems arising from the gap between the original payment schedule and the actual costs of the PAZ 2 programme.
The PAZ 2 programme aims to develop two Earth observation satellites with SAR radar technology (Synthetic Aperture Radar) intended primarily for military use by the Ministry of Defence, in collaboration with the National Institute of Aerospace Technology (INTA).
What does this regulation establish?
Order ITU/920/2026 modifies exclusively Annex I of Royal Decree 768/2025, which sets out the schedule of annual disbursements of the loan granted directly to Hisdesat. It does not alter any other condition of the loan: neither the total amount, nor the interest rate, nor the repayment conditions.
The specific change in the annuity schedule is as follows:
| Annuity | Original amount | Modified amount | Change |
|---|---|---|---|
| 2026 | ~€179,800,000 | €245,575,300 | +€65,775,300 |
| 2029 | Original amount (not published in summary) | Reduced by €65,775,300 | -€65,775,300 |
| Other annuities | No changes | No changes | €0 |
| Total loan | €1,011.85M | €1,011.85M | €0 |
The justification for the change is technical and financial: Hisdesat demonstrated in April 2026 that the actual payment rate of the programme did not match the disbursement schedule approved in 2025, creating liquidity pressures that compromised project execution.
From the perspective of European law, the operation is supported by Article 346 of the Treaty on the Functioning of the European Union (TFEU), which allows Member States to exclude from the general state aid regime measures linked to national security and defence. This means that the European Commission has no competence to review this financing as state aid.
Economic and operational impact
The net budgetary impact for the State is zero: the advance of €65.7M in 2026 is fully offset by the reduction in the 2029 annuity. There is no additional expenditure or modification of the total loan amount.
For Hisdesat, the effect is significant from the perspective of cash flow management: having €65.7M additional in 2026 allows it to align loan income with actual programme payments, avoiding the need to resort to short-term private financing to cover the gap.
From an industrial policy perspective, the PAZ 2 programme represents one of the largest public investments in defence space technology in Spain. The loan of €1,011.85 million is granted directly (without competitive bidding), reflecting the strategic nature of the project and the application of Article 346 of the TFEU.
Who does it affect?
- Hisdesat Servicios Estratégicos, SA: direct beneficiary of the loan and responsible for developing the PAZ 2 programme. Receives the advance of €65.7M in 2026.
- National Institute of Aerospace Technology (INTA): technical collaborator in the SAR radar satellite programme.
- Ministry of Defence: primary operational user of PAZ 2 satellites once deployed.
- Ministry for Digital Transformation and Public Function (ITU): body that signs the amending order.
- Suppliers and subcontractors of the PAZ 2 programme: companies in the aerospace and defence sector working for Hisdesat on this programme whose payment chain is indirectly affected by the company's liquidity.
Practical example
Hisdesat submitted in April 2026 a request to modify the disbursement schedule arguing that actual payments of the PAZ 2 programme were concentrated in 2026 more than foreseen in the original schedule approved in September 2025.
Under the original schedule, Hisdesat was to receive approximately €179.8 million of the loan in 2026. However, the actual payment commitments of the programme in that fiscal year exceeded that figure. The difference, €65,775,300, had to be covered somehow: either with private financing (more expensive and complex for a classified defence programme), or by requesting the advance from the State.
With the modification approved by Order ITU/920/2026, Hisdesat will receive €245,575,300 in 2026, exactly covering its cash needs for that fiscal year. In return, the 2029 annuity is reduced by the same amount, so the State does not disburse an extra euro in total.
What should companies do now?
- Suppliers and subcontractors of Hisdesat in PAZ 2: verify that their contracts and payment schedules are aligned with the new loan disbursement schedule. Hisdesat's liquidity in 2026 improves significantly with this advance.
- Companies in the aerospace and defence sector: take note of the mechanism used (request to modify annuities due to cash flow gap) as a reference for similar programmes financed with direct public loans.
- Advisors and CFOs of companies with direct public financing: review whether their loan contracts with the State contemplate the possibility of requesting adjustments to the disbursement schedule in case of gaps between the financial plan and actual execution. Order ITU/920/2026 is a relevant precedent.
- Compliance teams: record the entry into force on 4 September 2026 and update any internal documentation referring to Annex I of RD 768/2025.
Frequently asked questions
How much money does Hisdesat receive in total for the PAZ 2 programme?
Hisdesat receives a public loan of €1,011.85 million granted directly by the State under Royal Decree 768/2025. Order ITU/920/2026 does not modify this total amount: it only redistributes the annuities, advancing €65,775,300 from 2029 to 2026.
Why are funds advanced to 2026 and what happens with 2029?
Hisdesat requested the change in April 2026 citing cash flow problems: actual programme payments in 2026 exceeded the originally planned annuity (~€179.8M). With the modification, the 2026 annuity rises to €245,575,300 (+€65,775,300) and the 2029 annuity is reduced by exactly the same amount. The State does not disburse more money in total.
Why is this loan not subject to European state aid rules?
Because it is supported by Article 346 of the TFEU, which allows Member States to exclude from the general state aid regime measures linked to national security and defence. As it concerns radar observation satellites for primarily military use by the Ministry of Defence, the operation is outside the competence of the European Commission on state aid matters.
What are the PAZ 2 satellites and what are they used for?
PAZ 2 is a programme to develop two Earth observation satellites with SAR radar technology (Synthetic Aperture Radar). Their use is primarily military, under the operation of the Ministry of Defence, in collaboration with INTA (National Institute of Aerospace Technology). SAR technology allows obtaining high-resolution images regardless of weather conditions or light.
When does Order ITU/920/2026 enter into force?
Order ITU/920/2026 was published in the BOE on 3 September 2026 and entered into force the following day, 4 September 2026. The new annuity schedule of Annex I of RD 768/2025 is applicable from that date.
Official source
Consult full regulation at official source (BOE-A-2026-18566)
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-2026-18566
