The Group of States against Corruption (GRECO) of the Council of Europe has found that the Spanish authorities should intensify their efforts to implement planned reforms to strengthen anti-corruption mechanisms regarding top executive functions of the central government and law enforcement agencies (National Police and Guardia Civil).
In a follow-up report published today, GRECO concludes that regarding its Fifth Round Evaluation Report, adopted in 2019, Spain has implemented sixteen recommendations partially and has not implemented three.
In its most recent compliance report, adopted during its June 2025 plenary meeting, GRECO notes a lack of decisive action and tangible results regarding the recommendations issued in respect of top executive functions of the central government. While initiatives like the Democracy Action Plan, already adopted, and particularly the Open Administration Law, still to be adopted, propose improvements, their implementation remains outstanding.
The report also highlights that the absence of training for individuals with top executive functions on the Code of Conduct, as well as delays in implementing an integrity strategy, underscore the need for more systematic action.
Transparency measures have improved with the entry into force of the Council of Europe Convention on Access to Official Documents on 1 January 2024 in Spain, but GRECO expresses concern regarding the length of response times and public access. Additionally, the Council for Transparency and Good Governance has gained more independence, although its full sanctioning power is still awaiting legislative approval.
GRECO points out that efforts to regulate lobbying have yet to materialise in practice, and the requirement of agendas’ publication remains a pending matter. Furthermore, post-employment restrictions for political appointees and financial disclosure requirements need further reinforcement, particularly regarding independent oversight and the publication of disaggregated financial data. The Office for Conflicts of Interest continues to lack true independence and its own budget.
Moreover, GRECO notes that no action has been taken to reform the special procedure of the system for criminal responsibility of government members (so-called aforamiento).
Regarding the National Police and the Civil Guard, GRECO concludes that progress in implementing its recommendations has been mixed, with some advancements but persistent shortcomings.
The National Police has undertaken risk assessments and oversight actions, but a dedicated anti-corruption strategy is still lacking. The 2013 Code of Conduct remains without practical implementation measures, and recruitment and discretionary appointments still require greater transparency. GRECO acknowledges regulatory efforts in police training but considers that structural improvements in ethics and integrity remain incomplete.
The Civil Guard has shown more progress, particularly through the development of the Civil Guard Integrity System (SINTEGC) and the Professional Ethics Action Plan (PLAEP). These initiatives introduce risk assessments and structured training, with corruption prevention measures integrated into broader strategies. However, key initiatives, such as the Protocol of Good Practices, are still pending adoption.
The report welcomes improvements in internal reporting mechanisms and whistleblower protection in both the National Police and the Civil Guard but notes that their disciplinary regimes remain inadequate.
GRECO concludes that Spain is not in sufficient compliance with the recommendations and requests that the Spanish authorities provide a report on progress in implementing them by 30 June 2026. Applying its rules of procedure, in the report, GRECO invited the Council of Europe's Secretary General to send a letter to the Minister of Foreign Affairs of Spain drawing attention to the non-compliance with the relevant recommendations and the need to take determined action to achieve tangible progress as soon as possible.
