Control of foreign investment in Spain in 2025

The Report on the Control of Foreign Investment in Spain 2025, recently published by the General Subdirectorate of Foreign Investment (the "2025 Report"), confirms the consolidation of Spain's review mechanism as a key tool for economic security. In a context of global geopolitical and trade tensions, Spain has positioned itself as the second largest destination in Europe and the fifth in the world for foreign direct investment in greenfield projects, according to data from FDI Markets (Financial Times).

Below is a summary of the key data, events, and trends from the report, as well as practical implications for investors and advisors.

1. Key data and news from the 2025 Report

In 2025, a total of 196 applications for prior authorization were received, representing a 19% increase compared to 2024 (167 applications).

The Foreign Investment Board (JINVEX) met 17 times —four fewer than in 2024—and resolved 186 applications (181 new operations and five extensions). No authorization was denied.

Regarding the results of the 181 analyzed applications:

• 116 were unconditionally authorized (64%), as no risks to public order, security, or health were identified.
• 51 were dismissed (28%), as they were not subject to control.
• 14 authorized subject to investor commitments (8%), as mitigable risks were identified.
• 0 denials (0%).

In summary, no risks were identified in 92% of the analyzed foreign investment applications.

Origin of the ultimate investor (2025): United States (40%), United Kingdom (14%), United Arab Emirates (14%), China (6%), Canada (3%), Japan (3%), Saudi Arabia (3%), Australia (2%), and Singapore (2%). Transactions with US investors grew by 35% compared to 2024. The increase in investment from the United Arab Emirates, Canada, and Saudi Arabia is also noteworthy.

Sectors receiving investment (2025): Information and Communication Technologies (17%), Industry (15%), Automotive and Aerospace (11%), Professional Services (10%), Energy, Mining, and Fuels (9%), Healthcare (8%), Transport and Logistics (4%), Financial Sector (4%), Telecommunications (4%), and Pharmaceuticals and Chemicals (1%). Notably, the energy sector decreased significantly, falling from 20.8% in 2024 to 9% in 2025.

Reasons for control (art. 7 bis): 42% of authorized transactions were based on the fact that the acquired company possessed critical technologies; 22% on its supply of essential inputs; and 19% on its access to sensitive information.

Voluntary consultations: binding voluntary consultations decreased to 36 (28% less than in 2024, when 50 were received), reflecting a greater maturity of the system and a better understanding of the regulations by investors and advisors.

Cooperation mechanism: Spain has consolidated itself as the most active country in the EU cooperation mechanism, representing 23% of shared operations (668 operations in 2025, a 40% increase compared to 2024).

Institutional change: The General Subdirectorate of Foreign Investment has been integrated into the new General Directorate of Commercial Policy and Economic Security, bringing all economic security tools under one organization.

2. Comparison of 2024 vs. 2025 figures: main differences

The following table summarizes the key figures relating to the authorization procedure, comparing the two financial years:

With regard to the sectors, the main difference is the greater prominence of ICT in 2025 (17%) compared to the energy sector, which led in 2024 (20.8%) and falls to 9% in 2025.

Regarding the origin of investors, the United Arab Emirates have doubled their share (from 6.7% in 2024 to 14% in 2025), while China has dropped from 8.7% to 6%.

In terms of procedural efficiency, the average resolution times fell from 84 calendar days in 2023 to 72 in 2024 (65 days for the majority of cases), and the mechanism has continued to improve its efficiency in 2025, although the Report has not yet published the specific figure for the average time for this year.

3. Trends and key messages

A joint analysis of recent reports from the General Directorate of Foreign Investment allows us to identify the following key trends and messages regarding the control of foreign direct investment in Spain:

• An increasingly predictable and proportionate mechanism: 92% of transactions are resolved without risks identified and there have been no denials in 2025. Mitigation measures are gaining importance, although there is often agreement on their scope and intensity.
• Sustained growth in transaction volume: authorization requests have increased from 83 (2022) to 130 (2023), 167 (2024), and 196 (2025), reflecting a continuous expansion of the scope of the mechanism.
• Greater predictability and maturity of the system: the decrease in voluntary consultations (from 174 in 2022 to 36 in 2025) shows that investors and advisors are becoming increasingly familiar with the criteria of the mechanism, enabling them to extrapolate from previous decisions.
• Predominance of the US as the ultimate investor: the United States consistently represents around 40% of transactions, confirming Spain as the preferred destination for North American investment in Europe.
• Diversification of investment sources: there is a growing presence of Middle Eastern investors (UAE, Saudi Arabia), compared to a relative stabilization in China and the UK.
• Focus on technology and data sovereignty: critical technologies are consolidating their position as the main reason for being subject to control (42%), and protection of access to sensitive information is emerging strongly (19%, on the rise).
• Ongoing European harmonization: the political agreement on the new EU Regulation foresees regulatory convergence that will affect all Member States, including the obligation to control intra-community investments when the ultimate beneficiary is from a third country. Spain, as a pioneering and advanced country, is well positioned to address this legislative change.

Informative note from the Competition Law, Foreign Investment and EU practice group