The event “Sustainable Finance 2026: Toward a New Regulatory and Strategic Balance,” organized by Afi, served as a forum to discuss the sector’s upcoming challenges. With the participation of key representatives from the Treasury, the CNMV, and the Bank of Spain, the central message centered on the need to balance regulatory rigor with simplification and proportionality so as not to hinder the real economy.
Below, we outline the key points from the various institutional statements.
The initiative by the Treasury and the Council on Sustainable Finance
Ana Puente outlined the progress made by the Treasury, highlighting the creation of the Sustainable Finance Council. This public-private partnership, launched in 2025 following the Green Paper, aims to provide concrete solutions for the real economy.
The Council is based on four operational pillars:
- Resource Library and Financial Literacy: Includes practical resources, templates, and an exploration of artificial intelligence as a guidance tool.
- Industry-specific guides: Developed in collaboration with business associations to provide guidance tailored to the challenges of each industry.
- Funding without disproportionate burdens: The goal is to simplify regulations through voluntary, standardized reporting, designed specifically for small and medium-sized enterprises.
- Eco-Lab: A space dedicated to innovation in financial methodologies and solutions.
In addition, the “Eco-track” initiative was highlighted—a tool hosted on the Treasury’s website with 22 information points designed to help small and medium-sized enterprises measure, communicate, and identify their investment needs.
As for the Treasury’s Green Bond program, which focuses exclusively on environmental impact, it has reached a significant milestone: €18.385 billion in outstanding bonds by 2025. The main categories of spending financed through 2024 have been sustainable mobility (€12.992 billion) and water management (€1.519 billion), all under a regulatory framework that already incorporates the EU GBS (in effect since December 2024), directly linking proceeds to the Taxonomy.
The CNMV’s vision: protecting investors during the consolidation phase
Begoña López provided the CNMV’s perspective, describing the current situation in Spain as a “consolidation phase.”
- The annual report shows that funds classified under Articles 8 and 9 of the SFDR continue to grow, confirming that sustainability remains a strategic priority for Europe despite ongoing simplification efforts.
- To streamline the “investor journey,” it is essential to improve data comparability, enabling investors to fully understand the product and make informed decisions.
- Regarding the development of SFDR 2.0 (described in the discussion as a “product-centric” regulation), López urged patience: although large companies are prepared to adopt the new categorization, the market is currently undergoing a transition to an improved framework.
- The CNMV’s immediate priorities include protecting investors through clear and accessible information, financial education, and actively reviewing fund portfolios to verify the consistency of their classifications.
Bank of Spain: Proportionality in Climate Risk Management
The session focused on the Bank of Spain (BdE), featuring María Oroz, director of the Department of Horizontal Functions (General Supervision), centered on the integration of ESG criteria into risk management and capital requirements (ICAP).
- The Bank of Spain has adopted all the guidelines but is actively exploring ways to simplify them in order to avoid unnecessary complications and reduce reporting costs, while always applying the principle of proportionality.
- For the analysis of climate resilience, it was acknowledged that the major challenge remains the availability of information; therefore, the use of proxies based on a hierarchy of data sources is permitted.
- The supervisor expects smaller entities and SMEs to begin implementing the guidelines with a materiality analysis, leading to transition plans that are specifically tailored to those risks.
Reflections from the Roundtable
The event concluded with a panel discussion that yielded several key insights into the future direction of the sector:
- There was some self-criticism regarding the 2018 sustainable finance action plan, noting that it had tried to tackle everything at once (“trying to solve everything everywhere”).
- It was emphasized that reporting should be viewed as a mechanism to facilitate progress, rather than as the industry’s ultimate goal.
- The main consensus theory of change is that sustainable investment must make economic sense to be viable; only then will it be able to drive innovative technologies and create real market opportunities.
