Transparency in Navarra 2026: what companies with public contracts must do

Key data

Companies that work with the Navarrese administration—whether through public contracts or subsidies—have new transparency obligations since the publication of Ley Foral 3/2026, of March 23, in the BOE on April 25, 2026. This regulation modifies two regional laws from 2018 and tightens the control framework over how public and private organizations manage their relationship with the public sector in Navarra.

This is not just an internal reform of the administration. If your company invoices Navarrese public entities or receives regional funds, this law requires greater transparency in that relationship. And if you do not comply, the Anti-Corruption Office now has more tools to investigate and sanction you.

What does this regulation establish?

Ley Foral 3/2026 simultaneously reforms two regulations that have been in force since 2018 in Navarra:

In practice, the two axes of the reform are:

• Greater active publicity: Regional public sector entities must publish more information proactively, without waiting to be asked.
• More power for the Anti-Corruption Office: The Office of Good Practices and Anti-Corruption of Navarra strengthens its capacity to investigate and sanction breaches, both in the public sphere and in the relationship of private companies with the administration.

Economic and operational impact

The regulation does not establish specific penalty amounts in the published data, but the strengthening of the Anti-Corruption Office's sanctioning powers implies a real risk for companies that do not adapt their procedures.

The operational impact is concentrated in two areas:

• Review of internal procedures: Regional public sector entities and private companies linked to contracts or subsidies in Navarra will have to review how they manage and publish information related to their activity with the administration.
• Greater exposure to inspections: With strengthened investigative powers, the Office of Good Practices and Anti-Corruption can initiate investigations with greater scope. This increases the risk of audits for companies that do not have their transparency processes in order.

For private companies, the most relevant change is that it is no longer enough to comply with contract or subsidy requirements: the relationship with the Navarrese administration must be transparent as a whole, and that transparency can be subject to scrutiny by the Office.

Who does it affect?

• Regional administration of Navarra: All bodies and departments of the Government of Navarra must expand their active publicity.
• Regional public sector entities: Autonomous bodies, public companies and entities dependent on the Navarrese administration must adapt their internal transparency procedures.
• Private companies with Navarrese public contracts: Any company that has or has had contracts with the regional administration of Navarra falls under the scope of greater scrutiny by the Anti-Corruption Office.
• Companies benefiting from regional subsidies: Those that receive subsidies from the Government of Navarra or from Navarrese public entities must comply with greater transparency requirements in their relationship with the public sector.
• Citizens and entities requesting public information: The mechanisms for access to information are improved, which facilitates requests and increases the obligation of administrations to respond.

Practical example

A technology services company based in Pamplona that provides services to the Government of Navarra through a public contract and has also received a regional subsidy for an innovation project is at the center of the scope of this law.

Before Ley Foral 3/2026, its transparency obligations were limited to what was stipulated in the contract and subsidy conditions. With the new regulation, the Office of Good Practices and Anti-Corruption can investigate this company's relationship with the Navarrese administration with expanded powers, and the company must be able to demonstrate that its actions comply with the new transparency standards required. If it does not have its procedures documented and updated, it exposes itself to a formal investigation by the Office.

What should companies do now?

1. Identify if you are within the scope of application: Check if your company has or has had active contracts with the Navarrese regional administration or if you have received subsidies from the Government of Navarra or from Navarrese public entities.
2. Review internal transparency procedures: Document how you manage information related to your relationship with the Navarrese administration. Ensure that this documentation is accessible and up to date.
3. Check the entry into force date: The regulation was published on April 25, 2026 but the entry into force date has not been specified. Consult the official source in the BOE to confirm when the compliance obligation begins.
4. Assess the risk before the Anti-Corruption Office: With the new investigative and sanctioning powers of the Office of Good Practices and Anti-Corruption of Navarra, assess whether your company could be subject to an investigation and what documentation you would need to provide.
5. Seek advice from a specialist in public procurement or regulatory compliance: If your company has a relevant relationship with the Navarrese administration, it is advisable to review compliance with a professional before the regulation enters into full application.