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Garrigues Sustainable Newsletter – April 2026

Spain - 

In this newsletter we compile the most relevant legal news on ESG matters in Spain, published by Garrigues and G-advisory.

Publication of Directive (EU) 2026/470 simplifying the corporate sustainability reporting (CSRD) and due diligence (CSDDD) rules

The new directive substantially amends the scope of reporting and due diligence obligations, reducing the administrative burden on companies.

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Spain’s Royal Decree-Law 7/2026 drives electrification and accelerates the rollout of renewables

The measure, already ratified by the Congress of Deputies, introduces a broad set of regulatory measures in Spain to streamline energy projects, strengthen public participation, and facilitate access to and connection to the grid, on both the generation and demand sides.

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Sustainable mobility: keys to complying with new legal obligations

Law 9/2025 requires mobility plans to be negotiated with workers’ representatives. With the deadline ending in December 2026, many companies are already receiving applications to start negotiations. In this post we offer keys to the new legal obligations.

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The EU revs up its defence industry with a €1.467 billion plan for 2026–2027

The European Commission is launching the first calls under the European Defence Industry Programme, setting out priorities, budgets and support mechanisms to strengthen production capacity, cooperation in procurement, and security of supply in an especially demanding geopolitical context.

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Economy Ministry initiates public consultation on preliminary bill transposing EU corporate sustainability due diligence directive (CS3D)

The Spanish Ministry of Economy, Trade and Business has opened the public consultation on the draft bill to implement Directive (EU) 2024/1760 on corporate due diligence into Spanish law.

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News

EU strengthens water quality regulatory framework with new obligations on pollutants

Directive (EU) 2026/805 introduces relevant changes to European water regulations to update environmental quality standards, expand control over pollutants –including emerging pollutants– and strengthen monitoring and reporting mechanisms, in line with the European Green Deal and the Zero Pollution Action Plan.

The Spanish Government shortens the time period for implementing sustainable mobility to work plans which will end on December 5, 2026, and adopts provisions prohibiting dismissal

Qualifying companies will need to have their sustainable mobility to work plan by December 5, 2026, and beneficiary companies of direct support will not be able to dismiss until June 30, 2026.

These are the tax and corporate measures adopted in response to the crisis in the Middle East

Royal Decree-Law 7/2026 once again introduces, with some variations, certain tax measures from those approved in December 2025 and February 2025 and subsequently repealed, as well as new tax measures relating to other taxes, aimed at reducing the costs associated with the use of different energy sources. In addition, it again includes the extension of the suspension of the dissolution regime due to losses until the close of the financial year beginning in 2026, granting a new deadline for the restatement of the annual accounts corresponding to the 2025 financial year.

The Spanish Government promotes the future Organic Law on Public Integrity with significant amendments to public sector procurement

The draft bill establishes a new nationwide framework to prevent corruption and strengthens transparency, oversight and the professionalisation of public procurement, subsidy and public management processes.

The new coastal regulations may put an end to the extensions of maritime-terrestrial concessions

Extensions of concessions along the Spanish coastline are under European pressure. Following several rulings inspired by the case law of the European Court of Justice and infringement proceedings brought by the European Commission, the Spanish Government is preparing to reform the coastal regulations to require prior tendering for their award and extension.

Alcohol and drug controls at work: the tool that can protect employees by reducing accidents

In certain jobs, occupational accidents can be related, in a high percentage, to the consumption of alcohol and drugs. Adequate monitoring by the company can prevent or reduce them. Determining when and to what extent such monitoring is possible is crucial for the proper implementation of protocols for the control of the use of these substances.

The public CbC: first application in Spain of the new obligation of “corporate transparency”

The obligation to publish the so-called “country-by-country report” (known as “public CbCR”) affects multinational groups and independent companies whose consolidated revenues exceed 750 million euros in each of the last two consecutive years. Spain has some relevant peculiarities in the transposition of this obligation that should be considered in its first application.

The use of AI in people management requires new guarantees to avoid gender bias

Artificial intelligence (AI) applied to people management (selection, hiring, promotion, and remuneration) can perpetuate and amplify gender biases if algorithms learn from historical data with inequalities. In application of European and Spanish regulations, organizations can reduce this risk by auditing their AI systems, integrating the gender perspective, guaranteeing human supervision and training their teams to ensure that technology does not compromise equality in the workplace.

Pay equity: the path towards eliminating gender pay gaps

Every February 22, Equal Pay Day is commemorated in Spain. Multiple actions deployed at the international, European and Spanish levels promote the equalization of working conditions between both sexes. In this post we review the most recent and outstanding ones, focusing on Directive (EU) 2023/970, of May 10, pending transposition.

Spain’s Draft Bill on the National Health System safeguards public management and limits private collaboration through strengthened controls

The bill redefines the organisational model of the healthcare system, prioritising direct public management as the general rule, restricting indirect management to exceptional circumstances to be assessed by expert committees, and repealing Law 15/1997, a cornerstone of the current public‑private partnership framework.

The new Customer Service Law reshapes consumer protection: what’s changing and how to prepare

In sectors where the customer experience is built on dozens of micro-interactions, the quality of customer service can make all the difference. Law 10/2025 establishes, for the first time in Spain, a comprehensive framework for how companies must organize, provide, and demonstrate the quality of their customer service. Adapting to these new obligations poses significant challenges that must be addressed as a cross-functional initiative involving operations, sales, legal, quality, and technology departments.

Madrid’s 2025 ordinance regulating the waste management service fee is declared null and void

According to the Madrid High Court of Justice (TSJ of Madrid), the city council failed to comply with its obligation to publish in full the Technical and Economic Report supporting the ordinance during the public consultation process.

The Supreme Court sets criteria on the overlap of the weekly rest with a holiday

The Employment Chamber of the Spanish Supreme Court rules on how to deal with certain cases in which the weekly rest coincides with a holiday. Below, we break down the keys to the most relevant rulings in this regard and their practical implications.

Castile and León rolls out new regulations redefining the direct sale of agri‑food products

The new regulation, in force since 10 February, sets out the conditions, limits and obligations applicable to producers using alternative marketing channels.

What is a sustainable workplace mobility plan and why is it important for family‑owned businesses?

The new Sustainable Mobility Act introduces an obligation for companies with workplaces employing more than 200 workers, or 100 per shift, to implement sustainable workplace mobility plans, which affect labour management and collective bargaining in family‑owned businesses.

Latin America

Energy: the regulatory landscape of ancillary services in Latin America

One of the areas that has seen the greatest regulatory change and sparked the most debate in Latin America with respect to electricity generation and transmission is the inclusion, regulation and remuneration of ancillary services –also known as auxiliary or related services– as essential tools to ensure the reliability and security of the power system. We analyse how this concept is addressed in Chile, Colombia, Mexico and Peru. (Read here the latest issue of our Newsletter on the energy market in Latin America.)

Impact of minimum wage increases in Latin America

Recent minimum wage increases in Chile, Colombia, Mexico and Peru are reshaping the region’s labour landscape. Beyond the direct rise in wages, these changes affect business costs, statutory benefits, social security contributions and compensation schemes. In a dynamic regulatory environment, companies must anticipate the impacts, adjust budgets and review internal strategies to maintain efficiency and compliance.

Mexico: The Federal Electricity Commission presents a portfolio of 58 Electric transmission projects and announces new bids

Against the backdrop of the country’s growing electricity demand, the Federal Electricity Commission (CFE) seeks to promote the development of multiple projects as part of its 2025–2030 Expansion Plan.

Chile: Labour Directorate sets a new standard for exemption from working hours and clarifies the implementation of the 42‑hour workweek

Chile’s Labour Directorate has updated the key criteria on working‑time exemptions and the reduction to a 42‑hour workweek. The new guidance redefines when working time is deemed to be monitored, introduces greater flexibility in scenarios without an agreement, and establishes clear rules for applying the reduction in hours, with a direct impact on work organisation.

Peru redefines its nuclear framework and enables the incorporation of atomic power generation under new environmental and regulatory standards

The legislation seeks to diversify the country’s electricity mix in response to growing demand and the need to progressively move away from fossil fuels. To this end, it promotes the safe and sustainable use of nuclear energy, leveraging the uranium reserves available within national territory.

Mexico: The CNE strengthens the interconnection and connection agreement by imposing greater planning and coordination requirements on applicants and authorities of the electrical system

Through a preliminary draft resolution, the National Energy Commission (CNE) updates the agreement model for electrical interconnection and connection, incorporating new rules on deadlines, extensions and coordination with authorities.

Peru: Labour measures in response to the LPG supply crisis

Following the leak and subsequent deflagration in the Camisea gas transportation system in Cusco, a nationwide liquefied petroleum gas (LPG) supply crisis has emerged. This situation is expected to affect transport, logistics and, more broadly, the continuity of business operations. In this context, it is particularly relevant to analyse the labour measures that companies may adopt to deal with this situation.

Mexico continues the legislative process toward the reduction of the 40-hour working week

The constitutional reform sets a gradual reduction until 2030, maintains wages and benefits, and redefines overtime limits, forcing companies to reorganize shifts and processes to sustain their productivity.

Chile advances several amendments to the banking framework to strengthen corporate governance, risk management and recovery planning

The Financial Market Commission (CMF) has proposed a key update to modernise banking corporate governance and strengthen integrated risk management in line with international standards. The initiative formally incorporates recovery plans and promises greater resilience, transparency and responsiveness for financial institutions.

Mexico publishes new provisions on the Social Impact Statement in the Energy Sector and raises social obligations for energy projects

The Ministry of Energy published the new provisions that regulate the Social Impact Statement (MISSE) for energy projects, a framework that raises technical and human rights standards in the sector. These rules require planning social management from early stages, strengthening community participation and justifying social investment budgets.

Chile: Ministry of Energy resubmits previously withdrawn power‑sector decrees to the Comptroller General for review

Chile’s Ministry of Energy has resubmitted to the Office of the Comptroller General of the Republic a series of regulatory decrees relating to the electricity sector, noting primarily formal amendments. These include the texts amending Supreme Decree No. 125 and Supreme Decree No. 88, in which specific adjustments can be identified based on a preliminary review of the resubmitted versions.

Mexico: The Federal Electricity Commission published its guidelines for joint development, which establish the rules for private participation in joint schemes

These guidelines provide further details on the scope of private sector participation in those modalities that allow them to partner or share costs, expenses, investments, and risks of the activities and projects they carry out. These schemes must always be subject to the binding planning programs issued by the Ministry of Energy (SENER).

Peru: Labour benefits for workers with cancer are expanded

On the occasion of World Cancer Day, observed on 4 February, we review the legislation that in recent years has expanded workers’ access to certain labour benefits and workplace accommodations for employees diagnosed with cancer.

With the new General Law on Circular Economy and various environmental reforms, Mexico consolidates a new regulatory framework for the transition to circularity

Mexico takes a decisive step towards a more sustainable production model with the new Circular Economy Law, which redefines how companies should design, produce and manage their waste. The regulation promotes innovation, extended producer responsibility and the transition to more efficient and regenerative processes, opening up new obligations and also opportunities for business competitiveness.

Garrigues Sustainable

G-advisory marks its 25th anniversary with an event held at the corporate headquarters

G-advisory celebrated its 25th anniversary yesterday with an event at our corporate headquarters in Torres de Colón. Garrigues’ energy and sustainability consulting team brought together clients and colleagues for an event to reflect on the key milestones achieved over the years.

Garrigues’ revenues grow 9.51% in 2025, to €527.69 million

With an increase of €45.84 million over the year, the firm sets a new record and marks its 12th consecutive year of growth.

G-advisory strengthens its presence in Latin America with an office in Bogotá

The technical, economic, and strategic consulting arm of the Garrigues group, which is celebrating its 25th anniversary, establishes a base in Colombia to respond to the growth of the energy market and strengthen its local services offer.

Garrigues promotes 16 new equity partners in 2026

These appointments bolster the firm's commitment to internal talent and the generational balance.

Garrigues integrates Chilean firm Barros, Silva, Varela & Vigil (BSVV)

This transaction will strengthen Garrigues’ position in Chile and solidify its leading position in Latin America.