Executive Summary
The year 2025 was legally transformative in the employment and technological sphere. The **reduction of the maximum working week to 37.5 hours** was the most relevant structural change in Spanish employment law since the 1994 reform, affecting millions of workers and generating an intense adaptation task for HR departments and law firms. Simultaneously, the **AI Act** began deploying its first effective obligations, transforming the relationship between companies and their artificial intelligence tools. And the **CSRD's** second wave extended the universe of sustainability reporting obligations.
At BMC, the legal department experienced one of its most active years, with working week adaptation projects, AI system audits and advice on CSRD report preparation as the flagship services of the year.
Key Highlights
The 37.5-hour working week, approved through amendment of the Workers’ Statute and the Basic Public Employee Statute, entered into force with a gradual staggered implementation. The sectors with the greatest impact were those where the conventional standard working week was 40 hours — manufacturing, construction, retail — while professional services, technology and banking sectors were in many cases already below the new limit. Adaptation required collective bargaining in numerous agreements, modification of time-tracking systems and review of work organisation models.
The AI Act began its effective application with the February 2025 prohibitions and the transparency obligations for general-purpose AI systems from August 2025. At BMC, we completed more than 90 audits of AI systems in use by clients, identifying systems subject to specific obligations, evaluating their compliance and designing the necessary action plans. HR systems with AI components — candidate evaluation, absenteeism analysis, performance management — were the most frequently identified as high-risk.
The CSRD’s second wave incorporated large non-listed companies (more than 250 employees and €40 million turnover) into the universe of obliged entities reporting on the 2025 financial year. This significant expansion of the scope brought a massive wave of demand for materiality assessment and sustainability report preparation services, with many companies addressing these requirements for the first time.
Practice Area Analysis
Employment law post-working week: The working week reduction generated a set of new legal questions: treatment of employees with part-time contracts proportional to the new limit, regulation of compensatory work in shift-working sectors, management of negative hour balances in time banks, and compatibility of the new working week with remote working modalities that had been operating with more flexible schedules. Courts began accumulating the first disputes arising from interpretation of the regulation.
AI and privacy compliance: The intersection between the AI Act, the GDPR and the Organic Data Protection Act created a complex regulatory ecosystem for companies using AI in personal data processing. Data protection impact assessments (DPIAs) had to be updated to incorporate AI Act-specific risks, and Data Protection Officers expanded their functions to the AI governance sphere.
Insolvency and restructurings: The 31% increase in processed restructuring plans reflected the combination of maturing pandemic-era financial debt, the impact of higher interest rates on financing costs and the normalisation of inspection and judicial activity after the moratorium years. The Consolidated Insolvency Act proved its robustness as a reference framework for preventive restructurings.
Regulatory Changes
The CS3D (Corporate Sustainability Due Diligence Directive) began its application for large European companies, requiring identification and mitigation of human rights and environmental risks in the global value chain. Spanish companies exposed to international supply chains had to begin risk mapping and establishing continuous due diligence procedures.
Our employment and technology law team positioned itself as a reference in managing the most complex regulatory challenges currently facing companies, combining legal specialisation with deep business understanding.
Outlook
The horizon for 2026 includes the consolidation of the reduced working week in sectors with the greatest resistance to change, the full operability of AI Act obligations for high-risk systems (August 2026) and the extension of CSRD to a wider universe of companies. Corporate compliance will continue to be an area of growing demand, driven by regulatory density and the increasing expectations of stakeholders regarding corporate responsibility.
At BMC, we continue building the team and capabilities to be the reference legal partner for companies seeking to navigate this environment with legal certainty and competitive advantage.
