Lobbying Law 2026: what companies and associations must do before the AGE

Key data

If your company, association or law firm speaks with senior officials, cabinet members or public employees of the central Administration to influence normative, regulatory or public policy decisions, the Royal Decree-Law 21/2026 makes you an interest group subject to mandatory registration. The regulation entered into force on the same day of its publication in the BOE, August 26, 2026, without an adaptation period.

This decree responds to commitments made by Spain in the Recovery Plan (Milestone CID 432) and recommendations from international organizations such as GRECO and the OECD, in addition to aligning with European standards on institutional transparency.

What does this regulation establish?

RDL 21/2026 creates a comprehensive regulatory framework for lobbying activities before the General State Administration (AGE) and the state institutional public sector. The pillars of the new framework are:

• Public and mandatory registry of interest groups: any entity conducting influence activities before the AGE must register before initiating those activities.
• Interconnection with regional registries: the state registry will connect with interest group registries already existing in autonomous communities, avoiding duplicities but requiring compliance at the state level.
• Conduct rules for lobbyists: relations between those exercising lobbying and senior officials, cabinet members and public employees are regulated, with the aim of preventing conflicts of interest.
• Declaration of actions: registered entities must declare their contacts and interactions with the Administration, providing public traceability to influence activities.
• Sanctioning regime: non-compliance with registration and declaration obligations entails sanctions. The regulation does not specify the exact amounts of sanctions in the summary, but expressly establishes that a sanctioning regime applies.

Economic and operational impact

The impact is not a published fee or fine figure: it is the cost of operational adaptation and the sanctioning risk for non-compliance. Affected organizations must assume:

• Internal compliance cost: identifying what activities constitute lobbying under the new definition, designating responsible parties, establishing procedures for registration and declaration of meetings and contacts.
• Registration and maintenance cost: registration in the public registry, periodic updating of data and declarations of actions before the AGE.
• Reputational risk: as it is a public registry, information about who conducts lobbying and before whom will be visible to media, competitors and citizens.
• Sanctioning risk: operating without registration or without declaring actions activates the sanctioning regime provided for in the decree, with economic consequences and restrictions on access to the Administration.

For public affairs law firms, the impact is especially direct: their main activity is regulated and their relationship with clients must be adapted to ensure that actions taken on behalf of third parties also comply with the framework.

Who does it affect?

The regulation affects any entity—public or private, for-profit or non-profit—that conducts influence activities before the AGE and the state institutional public sector. Specifically:

• Public affairs law firms and consultancies specialized in relations with the Administration.
• Companies with institutional relations or public affairs departments that contact the central Administration.
• Business federations and business associations that convey sectoral positions to ministries or state agencies.
• NGOs and third sector organizations that impact public policies at the state level.
• Federations, professional associations and chambers that interact with the AGE to influence regulation.
• Think tanks and research centers that conduct advocacy activities before the central Administration.

It does not affect relations with regional or local administrations, which are governed by their own regulatory frameworks, although the state registry interconnects with existing regional registries.

Practical example

An energy sector business federation holds periodic meetings with technicians and senior officials of the Ministry for Ecological Transition to convey its position on the draft of a new renewable energy regulation. Until now, these meetings did not require any formal procedure before the AGE.

With RDL 21/2026 in force as of August 26, 2026, this federation must:

1. Register in the public registry of interest groups before continuing with those meetings.
2. Declare each influence action carried out before the AGE (meetings, communications, submitted documents).
3. Ensure that its representatives know and comply with the conduct rules established for relations with senior officials and public employees.

If it continues operating without registering, it incurs the sanctioning regime of the decree. If it registers, its actions will be publicly visible in the registry, which requires a communication strategy consistent with that transparency.

What should companies do now?

1. Audit influence activities: identify whether your organization conducts contacts with senior officials, cabinets or employees of the AGE with the aim of influencing normative or public policy decisions. If the answer is yes, you are required to register.
2. Register in the public registry of interest groups: complete the registration before continuing with any lobbying activity before the AGE. Do not wait: the regulation applies immediately as of 26/08/2026.
3. Establish an internal declaration procedure: document and declare influence actions carried out before the AGE according to the decree's requirements.
4. Train institutional relations teams: the conduct rules for relations with senior officials and public employees must be known by all those exercising these functions.
5. Review contracts with external law firms: if you hire a public affairs law firm to act on your behalf before the AGE, verify that the law firm also complies with the required registration and declarations.
6. Consult the interconnection with regional registries: if you are already registered in a regional registry, verify whether that registration covers the state level or if you must complete an additional procedure before the state registry.

Official source

Consult complete regulation in official source

Notice: This article is merely informative in nature 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-2026-18148