Introduction to Sustainable Finance Law in Spain

Several professionals from RocaJunyent — Iñigo Cisneros, Xavier Foz, Jordi Bermúdez, Berta Bastardas and Marta Pérez-Marsá — have recently contributed to the drafting of this article published on Lexology, the leading global legal intelligence platform used by in-house counsel and legal practitioners worldwide.

The article provides a systematic analysis of the regulatory framework governing sustainable finance in Spain, covering both EU legislation (the Taxonomy Regulation, SFDR and CSRD) and national laws, the available market instruments, and the supervisory role of the CNMV and the Bank of Spain. It also examines the sustainable finance instruments currently present in the Spanish market (including green bonds, social bonds, and sustainability-linked loans), as well as public incentives channelled through the Recovery, Transformation and Resilience Plan and the ICO financing programmes.

The analysis concludes that Spain has developed a robust institutional and regulatory infrastructure aligned with its climate‑neutrality commitments, while also identifying several significant challenges that remain:

• Regulatory fragmentation and the speed of legislative developments at EU level create uncertainty in relation to compliance.
• The availability and reliability of Scope 3 emissions data continue to hinder effective transition planning.
• Physical climate risks — particularly water stress, extreme heatwaves and coastal erosion — highlight the need for more mature and comprehensive adaptation frameworks.

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