Analysis of antitrust trends in Spain in 2025 and what to expect in 2026

5 March 2026

Spain has consolidated its position as one of the leading European jurisdictions in competition law, with the CNMC pursuing a particularly intense agenda both nationally and internationally.

This year, attention has focused in particular on complex sectors such as digital and the energy industry, as well as on other areas where competition is weakened as a result of structural or conjunctural factors.

The following developments stand out:

• More sophisticated competition analyses incorporating novel theories of harm have introduced a greater degree of uncertainty for market operators.
• The CNMC’s use of artificial intelligence–based tools has expanded the CNMC's detection capabilities for anticompetitive conduct and/or gun jumping, and has also enhanced the effectiveness of dawn raids through Open Source Intelligence techniques.
• The strengthened cooperation with contracting authorities facilitated by the fast-track procedure under the Public Sector Procurement Law has been key to improving the detection of bid-rigging practices.
• The first debarment decisions imposed by the CNMC have become a powerful deterrent tool, in particular, for companies contracting with the Public Administration in Spain.
• There has been a significant increase in fines stemming from monitoring proceedings related to compliance with previous CNMC decisions.
• Spain has seen a marked increase in damages claims arising from breaches of competition law, the emergence of litigation funding in this area, and heightened activity by claimant associations promoting such actions. This introduces additional complexity and risk in the competition law landscape.

To read the full report, please contact any of our key contacts or register your interest here.