This table summarises all completed investigations by Spain’s competition authority (the National Commission on Markets and Competition—the CNMC) into alleged cartels, anti-competitive agreements and abuses of dominant positions (Articles 101/102 TFEU and national equivalents) since 2018. Note—only investigations that have been made public are included in this table. 2026 Investigations under Article 101 TFEU/Article 1 of the Spanish Competition Act Case name, companies under investigation and industry Issues Developments Professional hairdressing products• I.C.O.N Restrictive agreements—price fixing • Infringement decision announced—12/01/2026; fines totalling €1.2m imposed Investigations under Article 102 TFEU/Article 2 of the Spanish Competition Act Case name, companies under investigation and industry Issues Developments Automotive fuels• Repsol Comercial de Productos Petrolíferos•Solred • Campsa Estaciones de Servicio Concerns the Repsol Group abused its dominant position through their pricing policy that squeezed the margins of independent low-cost gas stations • Infringement decision announced—03/02/2026; fines totalling €20.5 imposed 2025 Investigations under Article 101 TFEU/Article 1 of the Spanish Competition Act Case name, companies under investigation and industry Issues Developments Travel agencies• Nautalia, SL• Viajes El Corte Inglés• Ávoris

Law360: Spain can't use state immunity to escape enforcement of a €101marbitral award issued in adispute over slashed economic incentives for renewable energy, after a London appeals court ruled 22 October 2024 that an exception was triggered when Madrid signed an underlying treaty.

Law360, London: Spain has failed in its latest attempt to enforce an €855m Spanish judgment against maritime insurers over a huge oil spill off its coast, as an appeals court found on 12 December 2024 that it was prevented from doing so by English arbitration.

Law360: Spain cannot rely on state immunity to overturn a translator's harassment and discrimination claim, the Court of Appeal has ruled, finding that the conduct complained of was not part of a governmental activity.

NOTE—to see whether notification thresholds in Spain and throughout the world are met, see further: Where to Notify. 1. Have there been any recent developments regarding the Spanish merger control regime and are any updates/developments expected in the coming year? Are there any other ‘hot’ merger control issues in Spain? On 28 April 2021, Royal Decree-Law 7/2021 of 27 April (RD 7/2021) was published to amend the Spanish Competition Act (Law 15/2007, of 3 July 2007, on the Defense of Competition, or LDC). RD 7/2021 had the aim of transposing into Spanish legislation a number of EU directives, including Directive (EU) 2019/1 of the European Parliament and of the Council of 11 December 2018 (Directive 2019/1) to empower the competition authorities of the Member States. However, the amendments included in the LDC by RD 7/2021 did not have a significant impact on Spanish merger control rules. The only amendment that affects merger control rules is the one that relates

Law360: A federal judge in Washington, DC, on 12 August 2025 enforced a €59.6m arbitral award against Spain in a dispute over revoked incentives for renewable energy projects, ruling that the award is entitled to full faith and credit and that international comity does not preclude its enforcement.

Law360: Spain told an appeals court on 29 October 2024 that arbitration proceedings cannot block it from enforcing an €855m Spanish judgment against marine insurers over a huge oil spill off the coasts of Spain and France.

Law360: Spain has told the DC Circuit that its announcement of withdrawal from the Energy Charter Treaty does not show it recognises that it is still bound under the international agreement, contrary to what investors owed about US$386m argued earlier this week.

Loan market and developments Please provide a brief overview of the current state of the loan markets in your jurisdiction and any significant recent market developments Consumer credit to the Spanish private sector has shown a consistent trend, with consumer credit standing at €181.46bn as of December 2024. This remains close to the historical average of €187.53bn from March 2007 to December 2024, reflecting a stable yet dynamic loan market. This figure is expected to experience strong growth in 2025 and 2026, supported by Spain’s economic expansion. The country showed a 3.2% GDP increase, which benefits from its services-driven economy, a low reliance on energy-intensive industries and a recovering tourism sector. The market share of credit financial institutions continues to rise, particularly in Buy Now Pay Later (BNPL) services. The BNPL market in Spain, which experienced robust growth from 2021 to 2024, is expected to grow by 11.6% annually in 2025, reaching US$8.91bn. Between January and March 2025, credit granted by financial institutions has remained stable, with fixed interest rates increasing due to evolving monetary

Arbitration analysis: An English justice delaying ruling on Spain’s application to set aside the High Court of Justice’s registration of an International Centre for Settlement of Investment Disputes (ICSID) award against it worth more than €33m pending an appeal on the related issue of whether Spain is bound to an arbitration agreement with a citizen of a European Union state despite EU law prohibiting intra-EU arbitrations.

EU Law analysis: The High Court of Justice of Galicia, Spain (the ‘High Court’) has ruled in favour of residents and consumer associations in a landmark environmental case (Judgment 313/2025). The High Court declared that the Xunta de Galicia and the Confederación Hidrográfica del Miño-Sil (CHMS), violated fundamental rights, including the right to life, health, private life, and access to clean water, due to their inaction over severe water contamination in the Limia basin and As Conchas reservoir. The contamination, linked to intensive livestock farming, caused chronic pollution exceeding legal thresholds for human consumption. Importantly, the High Court recognised the standing of local residents and associations to defend collective rights, ordered immediate remedial measures to restore water quality, and mandated state accountability in environmental protection. Practitioners in environmental, human rights, and administrative law should take note: this judgment strengthens the enforceability of environmental rights through fundamental rights litigation, and reinforces administrative liability for environmental neglect. Written by Joe Tirado, International arbitrator, mediator and ADR consultant at TiradoADR Limited in London, and Elisa Vicente Maravall, International Arbitration counsel and arbitrator, and adjunct Spaniprofessor at IE University in Spain.

The Criminal Chamber of the Supreme Court of Spain has upheld the conviction of lawyer, Gonzalo S.C. for the offence of disobedience, confirming a six-month prison sentence and a one-year disqualification from acting as an arbitrator. The conviction stems from his failure to comply with a July 2021 order from the High Court of Justice of Madrid, which instructed him to cease his role in an arbitration between the State of Malaysia and the heirs of the Sultan of Jolo concerning territory in northern Borneo. Despite the order, Gonzalo S.C. continued the arbitration process, relocating its seat to Paris and issuing a final award in February 2022 that required Malaysia to pay $15bn. The High Court of Justice of Madrid had previously annulled his appointment due to procedural irregularities, specifically the violation of summons guarantees for foreign states. The Supreme Court rejected his appeal, dismissing claims of jurisdictional interference and improper conduct by the Lawyer of the Administration of Justice, and concluded that the appellant knowingly disregarded a binding judicial mandate, thereby attempting to override judicial authority.