Executive Summary
The year 2025 was one of strategic reconfiguration of the Spanish investor environment. The **abolition of the Golden Visa** in April closed a chapter of the foreign real estate investment attraction policy, opening the debate on alternative models for attracting capital and talent. The entry into force of the first **AI Act** obligations transformed digital transformation agendas with a previously absent regulatory component. And the **ZEC** (Canary Islands Special Zone) gained unprecedented strategic prominence, with the registration deadline closing at end-2026 and a 4% corporate tax rate that no other European regime can match.
The Spanish market once again demonstrated its resilience: GDP grew an estimated 2.8%, foreign direct investment reached a new historical maximum of €38.5 billion and M&A recovered dynamism with 461 completed deals.
Key Highlights
The abolition of the Golden Visa (effective from 3 April 2025) transformed the high-end real estate market in areas of greatest concentration of international investors: Madrid, Barcelona, Malaga, Marbella and the Balearic and Canary Islands. The effect was dual: in the short term, the weeks prior to abolition generated a last-minute application peak; in the medium term, demand reorients towards non-real estate assets and residents with other ties to Spain. Alternative strategies — digital nomad visa, Beckham Law, ZEC — gained prominence as complementary instruments.
The ZEC emerged as the major fiscal opportunity of the year for international groups seeking a competitive regime within the European framework. With a corporate tax rate of 4% — versus the general 25% and the Pillar Two minimum 15% — and a registration deadline closing 31 December 2026, BMC developed a specific ZEC eligibility evaluation and structuring service that generated extraordinary demand. ZEC is compatible with Pillar Two provided the effective rate of the Canary Islands entity reaches 15% considering the full set of taxes paid; activities with intensive value creation (R&D, technology services, industry) with significant labour costs in the Canary Islands facilitate meeting this threshold.
AI Act obligations began materialising in the first legal and strategic agendas. The prohibition of unacceptable-risk AI practices — subliminal manipulation, social scoring, unauthorised biometric identification in public spaces — was effective from February 2025. Companies had to audit their AI systems in use to identify possible incompatibilities with the prohibited categories.
Sector Analysis
Infrastructure and energy: Investment in renewable energy infrastructure continued to be the most active M&A sector, with Spain consolidated as a European reference market for solar, wind and storage assets. The entry of the green hydrogen market generated the first significant transactions in this emerging subsector.
Technology and AI: Generative AI and sector AI applications were the epicentre of technology investment activity. Software companies incorporating AI capabilities natively recorded the highest valuation multiples in the market. Technology M&A oriented towards acquiring AI capabilities rather than traditional market share.
Tourism and hospitality: The tourism sector completed its full recovery and began facing the challenges of success: tourist saturation at iconic destinations, more restrictive holiday rental regulation and the need for diversification towards higher value-added segments.
Regulatory Changes
The 37.5-hour working week, definitively approved in 2025, began implementing gradually. Adapting collective bargaining agreements, managing new overtime thresholds and the technology of time control were areas of intense activity in HR and operations departments.
Strategic planning integrated with ZEC evaluation consolidated as one of the highest value-added services for international groups with presence or interest in Spain.
Outlook
The horizon for 2026 included preparation for extending CSRD obligations to mid-sized companies, advancement of AI Act obligations for high-risk systems (August 2026) and the definitive closing of the ZEC registration deadline in December. Companies with strategic transformation agendas had to take advantage of the window of opportunity offered by this regulatory context before access to the most advantageous regimes closed.
Our strategy and corporate advisory team continued being the reference partner for clients in identifying and materialising the opportunities offered by the dynamic Spanish and European business environment.
