Treasury cancels subsidies to 13 companies: up to €1.85M lost due to non-compliance

Key data

Thirteen companies that had obtained regional incentives under the Law 50/1985, of 27 December, on Regional Incentives, see their right to receive these grants cancelled or reduced. Order HAC/669/2026 formalizes the non-compliance with the conditions that were originally established as binding in the grant, and does so with immediate effect from its publication on 3 July 2026.

The mechanism is clear: if a company fails to meet the commitments assumed upon receiving the grant (investment, employment, deadlines or others), Treasury can withdraw the incentive in whole or in part. In this case, none of the 13 companies had received the amounts, so there is no refund of funds, but there is a definitive loss of the recognized right.

What does this regulation establish?

Order HAC/669/2026 resolves the proceedings for non-compliance with the conditions established in the grant of regional incentives for 13 companies. The procedure has been processed with prior hearing of the interested parties, in accordance with Law 39/2015 on Common Administrative Procedure and Royal Decree 899/2007, which regulates the regional incentives regime.

The result is twofold depending on the degree of non-compliance:

• Total loss (100%): For companies that have fully failed to meet binding conditions. Five companies are in this situation, including Royal Sun Hotel (€1,850,000) and Paalwin Park (€459,798).
• Proportional reduction: For the remaining companies, the reduction is adjusted to the degree of non-compliance detected in the proceedings.

A relevant fact: none of the 13 companies had received the amounts. This means that the resolution does not generate a debt with Treasury nor does it require the return of funds already received. The effect is the extinction of the right recognized in the original grant resolution.

Economic and operational impact

For the affected companies, the impact is the definitive loss of a source of financing that they already had recognized. Although there is no refund of funds, there is an impact on financial planning: investment or expansion projects that were designed counting on these incentives are left without that coverage.

Below is the detail of the two companies with the largest amount affected in the total loss resolution:

The other three companies with 100% loss and the eight with proportional reduction are not nominally identified in the available summary of the order, although all have been individually notified in accordance with the established procedure.

From an operational perspective, affected companies should review whether the cancelled incentive was part of their investment plan or their commitments to third parties (banks, partners, regional administrations), as the loss of the incentive may have cascading effects on those agreements.

Who does it affect?

• The 13 companies directly named in Order HAC/669/2026, which had regional incentives granted under Law 50/1985 and have failed to meet some of its binding conditions.
• Companies in the hotel and tourism sector, as evidenced by the case of Royal Sun Hotel.
• Companies with regional incentives granted but not received that are still in the period of compliance with conditions: this resolution is a direct warning about the consequences of non-compliance.
• Financial and legal advisors managing Law 50/1985 subsidies for their clients: they should review the compliance status of the assumed commitments.
• CFOs and financial directors of companies with pending regional incentives, who must ensure that milestones and binding conditions are being monitored.

Practical example

Royal Sun Hotel had a recognized subsidy of €1,850,000 as a regional incentive under Law 50/1985. The company had not received that amount. After the hearing procedure, Treasury detects full non-compliance with binding conditions (for example, failure to execute the committed investment or failure to maintain the planned employment within the established deadlines).

The result: Order HAC/669/2026 declares the loss of 100% of the incentive. Royal Sun Hotel will not receive the €1,850,000 and permanently loses that right. If the company wishes to challenge this decision, it has one month from notification to file a reconsideration appeal with the Minister of Treasury, or two months to go directly to the National Court via administrative litigation.

If it does not appeal within the deadline, the resolution becomes final and the proceedings are closed without the possibility of reopening the administrative route.

What should companies do now?

1. If you are one of the 13 affected companies: Review the notification received and identify whether the resolution is total loss or proportional reduction. The deadline to appeal starts from the date of individual notification, not from publication in the Official Gazette.
2. Evaluate the appeal route: You have two options: reconsideration appeal to the Minister of Treasury within one month, or administrative litigation appeal to the National Court within two months. Both routes are mutually exclusive: if you file for reconsideration, the litigation deadline is suspended until its resolution.
3. Review the impact on your financial planning: If the cancelled incentive was included in investment projections, bank financing or partner commitments, update those documents to reflect the new situation.
4. If you have other active regional incentives: Audit compliance with all binding conditions before Treasury opens proceedings. It is more efficient to act preventively than to manage a non-compliance resolution.
5. Consult with a specialist in administrative law and subsidies before deciding whether to appeal or accept the resolution, especially if the amount is relevant to your company.

Official source

View 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-2026-14472