Spain’s Competition Regulator Refreshes Its Compliance Benchmark

Key Takeaways

• Public Consultation Timing: Feedback is open through January 20, 2026.
• Compliance Benchmark: The 2020 guide is a widely used standard for assessing competition compliance programs in Spain.
• Purpose of Update: The revision reflects legislative changes and experience gained over the past five years.

Deep Dive

The National Markets and Competition Commission (CNMC) of Spain has opened a public consultation to update its widely used “Guide to Compliance Programs in Relation to Competition Law.” First rolled out in 2020, the document quickly became a go-to reference for companies designing and evaluating internal controls to prevent antitrust violations.

Five years on, the CNMC says the landscape has shifted. Regulatory expectations have evolved, compliance strategies have matured, and businesses have learned a great deal from real-world implementation. The review aims to capture all of that, adapting the guide to today’s economic and legal reality and strengthening the criteria used to assess corporate compliance efforts.

The consultation is open to anyone with a stake in competition compliance, including companies, industry associations, legal teams, consultants, and others who live and breathe policies and program effectiveness. Interested participants have until January 20, 2026, to provide feedback.

While the main message largely remains the same, but the CNMC appears keen to ensure its guidance remains more than a static document. By filtering in experience from the past five years, the regulator hopes to reinforce the incentives for businesses to stay above board and keep programs aligned with best practices.

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