Spain
Reino de España
Digital transformation leader and AI Supervisory Sandbox pioneer
National Competent Authority
Agencia Española de Protección de Datos (AEPD)
Spanish Data Protection Agency
Spain's AEPD serves as the primary competent authority for EU AI Act implementation, bringing extensive GDPR enforcement experience to AI regulation. The AEPD operates Spain's pioneering AI Supervisory Sandbox (Espacio de Pruebas Controlado de IA), the first regulatory sandbox framework specifically designed for testing high-risk AI systems under controlled conditions before market deployment.
Key Responsibilities
- •AI Supervisory Sandbox administration and oversight
- •High-risk AI system conformity assessment coordination
- •Market surveillance and post-market monitoring
AI Sandbox Innovation
- •First EU AI Sandbox: Launched Q1 2023 ahead of AI Act
- •Controlled Testing: Healthcare, finance, and public service AI
- •Model Framework: Template for other EU member states
National AI Strategy & Digital Agenda 2026
Spain's National Artificial Intelligence Strategy (Estrategia Nacional de Inteligencia Artificial) focuses on positioning Spain as a leading AI hub in Southern Europe through the €600 million investment in research infrastructure, talent development, and SME digitalization. The strategy emphasizes trustworthy AI aligned with European values and strong public-private partnerships.
Research & Talent
- €600M Strategic Investment:
Comprehensive funding for AI research centers, workforce training programs, and digital infrastructure through 2026.
- Ellis Unit Barcelona:
European AI research network node focused on machine learning, computer vision, and natural language processing.
- Barcelona Supercomputing Center:
MareNostrum 5 supercomputer providing computational infrastructure for European AI research.
Digital Transformation
- España Digital 2026:
€140 billion digital transformation plan integrating AI across public administration, healthcare, and education.
- SME Digitalization:
Targeted support for small and medium enterprises adopting AI technologies, with subsidies and training programs.
- AI Ethics Charter:
National framework emphasizing transparency, accountability, and non-discrimination in AI systems.
EU AI Act Implementation Timeline
Phase 1: Immediate Compliance
ActiveFebruary 2025 – August 2025
- ✓Prohibited AI practices (Art. 5) enforced through AEPD
- ✓AI Supervisory Sandbox expanded capacity for testing
- ✓Industry guidance published in Spanish and Catalan
Phase 2: GPAI Model Compliance
UpcomingAugust 2025
- •General Purpose AI model transparency requirements enforced
- •Systemic risk protocols for large-scale foundation models
Phase 3: High-Risk System Compliance
2026August 2026
- •Full conformity assessment regime for high-risk AI systems
- •Spanish Notified Bodies designated for third-party audits
- •Market surveillance integrated with sandbox learnings
Priority Sectors
Healthcare
AI diagnostic tools, telemedicine platforms, and electronic health records systems under strict data protection and clinical validation requirements.
Financial Services
AI-powered risk assessment, fraud detection, and algorithmic trading systems regulated by AEPD and Banco de España coordination.
Education
Adaptive learning platforms, automated assessment tools, and educational data analytics with strong student privacy protections.
Implementation Challenges
Regional Coordination
Spain's autonomous communities have varying levels of digital readiness, creating coordination challenges for national AI strategy implementation and enforcement consistency.
Mitigation: Regional AI hubs and federated governance frameworks with AEPD oversight.
Brain Drain
Despite world-class research centers, Spain continues to lose AI talent to higher-paying markets in the US, UK, and Germany, limiting innovation capacity.
Mitigation: Enhanced research funding, startup ecosystem support, and competitive retention packages.
Need Spain-Specific AI Compliance Guidance?
Our legal practice specializes in EU AI Act implementation across member states, with expertise in navigating Spain's AI Supervisory Sandbox and AEPD regulatory framework.