# Revolving doors in Spain: regulatory capture, Warren's old suspicion and how to close the door > Spain's revolving door between government and regulated companies is wide open: from 2006 to 2019 the Office for Conflicts of Interest granted 525 authorisations to 295 former senior officials and issued only 11 incompatibility rulings, and in September 2026 Congress repealed a decree that would have barred ex-officials from lobbying for two years. Donald Warren's Middle American Radicals distrusted big government and big business together, and the radical-centre fix takes both seriously: an independent office, stronger cooling-off rules, a lobbying law passed across blocs, and fewer discretionary rents worth capturing. - URL: https://www.radicalcentre.eu/en/articles/revolving-doors-capture-spain-warren - Language: en - Publisher: radical centre / centro radical - Published: 2026-10-26 - Topic: Democracy & institutions - Author: radical centre - Licence: CC BY 4.0 ## Key points - Spain's Law 3/2015 bars former senior officials for two years from working for companies affected by decisions they took part in, and requires them to notify the Office for Conflicts of Interest. - From 2006 to 2019 the office granted 525 authorisations to 295 former officials and issued 11 incompatibility rulings, according to elDiario.es. - Royal Decree-law 21/2026, which would have barred ex-officials from lobbying their old department for two years, was repealed by Congress on 16 September 2026. - GRECO has asked Spain to strengthen its revolving-door rules and noted weaknesses in the office's independence and resources. - Our plan: an office appointed outside the government, published reasoning for every authorisation, a lobbying law agreed across blocs and fewer discretionary rents. When Miriam González launched Democracia 21 on 10 October, she asked for the bodies that control the government to be independent, with neither politicians nor ex-politicians in them. We've written about [how to appoint those watchdogs](/en/articles/oversight-bodies-without-politicians-spain-proposal). This piece looks at the other side of the same suspicion: the door that lets people move from government into the companies government regulates, and sometimes back. In Spanish it has a vivid name, puertas giratorias, and an old pedigree in radical-centre thinking. ## Warren's suspicion In 1976 the sociologist Donald I. Warren published *The Radical Center*, a study of what he called Middle American Radicals, and we [explained it](/en/articles/donald-warren-middle-american-radicals-explained) earlier in the programme. John Judis, summarising Warren's surveys for the Carnegie Endowment, describes them as the group most distrustful of the national government, convinced that it favoured the rich and the poor at the same time. They were also deeply suspicious of big business and the most likely to say corporations had too much power. And they still backed Social Security, Medicare and job guarantees. Their anger was aimed at concentrated power wherever it sat, and above all at the places where public and private power merge. Economists arrived at a similar worry from the opposite direction. George Stigler's 1971 paper "The Theory of Economic Regulation", summarised by the Concise Encyclopedia of Economics, argued that producers tend to capture the agencies that regulate them and use the rules to keep competitors out. Francis Fukuyama gave the political version in *Political Order and Political Decay*: repatrimonialisation, the slow return of private interests into the heart of the state. Each tradition saw part of the danger. Revolving doors are where those parts meet. ## What Spain's rules say Spain has rules, on paper reasonable ones. Article 15 of Law 3/2015 on senior officials says that for two years after leaving office they may not work for private companies affected by decisions in which they took part, and that former members of regulatory and supervisory bodies may not work for companies they supervised. They must tell the Office for Conflicts of Interest what they plan to do before starting. Breaches are published in the BOE, and the most serious can bring a ban of five to ten years from senior office. The practice is looser. An investigation by elDiario.es, based on a transparency request, found that between 2006 and 2019 the office issued only 11 incompatibility rulings, while 295 former senior officials received 525 authorisations to move into the private sector. Those figures stop in 2019, and nobody has published a fuller official count since. That itself says something about how visible the door is: the data exist only because journalists asked for them. The Council of Europe's anti-corruption body, GRECO, has noticed. In its 2025 compliance review, as reported in August 2025, it said Spain should reinforce its measures against revolving doors, pointed to shortcomings in the independence and resources of the Office for Conflicts of Interest and judged progress on lobbying insufficient. Then came the attempt to fix it. Royal Decree-law 21/2026, of 25 August, created a mandatory public register of lobbyists, run by the Transparency Council, and a two-year ban on former senior officials doing influence work for registered lobbies on matters linked to their old department. Lobbies would have had to publish the names of former public officials on their staff. On 16 September Congress voted to repeal it, three weeks after it was published. ## Closing the door from both sides Each tradition has part of the answer. The left is right that concentrated economic power buys access to the state, and that former ministers on the boards of regulated companies are its most visible channel. The right and the market-liberal tradition, from Stigler on, are right that regulation tends to be acquired by the industry it regulates, so the surest defence is fewer discretionary rents worth capturing and more competition in the sectors where those rents live. Warren's Middle American Radicals, who fit neither camp, distrusted big government and big business together; a design that polices the door between them answers both suspicions at once. In practice that gives five rules. **Take the office out of the government.** The Office for Conflicts of Interest should be appointed the way we proposed for every watchdog: an open call, an independent panel, a parliamentary vote with a deadline and a default, and a single long term. **Publish the reasoning.** Every authorisation for a former official to take a private job should be published with the office's reasons, the company, the post and the decisions the official took that touched it. Sunlight costs almost nothing and makes the 525-to-11 ratio a matter of public debate. **Pass the lobbying law as a law, across blocs.** The content of the repealed decree was sound. A bill co-sponsored by groups from both blocs, along the lines of the [rules that reward agreement](/en/articles/two-iron-blocs-rules-that-reward-agreement) we set out yesterday, would give it the legitimacy a decree-law lacked. **Pay for the cooling-off.** Law 3/2015 already provides post-office compensation and withdraws it from those who break the rules. A longer restriction for the most sensitive posts, such as energy, banking and telecoms regulators, should come with that compensation, so the rule is fair and hard to dodge. **Shrink the prize.** The best protection against capture is a sector where a former minister's phone book is worth little. More competition in regulated markets, simpler rules applied by automatic criteria, and fewer discretionary licences and subsidies reduce the value of the door itself. Warren's radicals would have liked that last rule best. It treats the state and the market with the same healthy suspicion, and lets each keep the other honest. ## FAQ ### What are revolving doors (puertas giratorias) in Spain? The movement of ministers and senior officials into private companies they used to regulate or deal with, and sometimes back again. Spain's Law 3/2015 regulates it with a two-year restriction on working for companies affected by decisions the official took part in. ### Who controls revolving doors in Spain? The Office for Conflicts of Interest (Oficina de Conflictos de Intereses), which manages the incompatibility regime and the registers of activities and assets. GRECO, the Council of Europe's anti-corruption body, has pointed to weaknesses in its independence and resources. ### What is regulatory capture? The idea, set out by George Stigler in 1971, that regulated industries tend to gain control of the agencies meant to regulate them and use the rules to protect themselves from competition. Revolving doors are one of the routes through which capture happens. ### What happened to the 2026 lobbying decree? Royal Decree-law 21/2026 of 25 August created a mandatory lobbying register and a two-year ban on former senior officials lobbying their old department. Congress voted to repeal it on 16 September 2026. ## Sources - [Ley 3/2015, reguladora del ejercicio del alto cargo de la Administración General del Estado](https://www.boe.es/buscar/act.php?id=BOE-A-2015-3444), BOE (2015) - [Resolución de 16 de septiembre de 2026, del Congreso de los Diputados, de derogación del Real Decreto-ley 21/2026](https://www.boe.es/buscar/doc.php?id=BOE-A-2026-19419), BOE (2026) - [La Oficina de Conflictos de Intereses solo ha vetado 11 puertas giratorias](https://www.eldiario.es/economia/Oficina-puertas-giratorias-conflicto-intereses_0_876662862.html), elDiario.es (2019) - [El Gobierno defiende que el informe del GRECO constata que España avanza en prevención de la corrupción](https://www.menorca.info/actualidad/nacional/2025/08/01/2441995/gobierno-defiende-informe-del-grego-constata-espana-avanza-prevencion-corrupcion.html), Menorca.info (2025) - [George J. Stigler](https://www.econlib.org/library/Enc/bios/Stigler.html), Econlib, Concise Encyclopedia of Economics - [The return of the Middle American radical](https://carnegieendowment.org/posts/2015/10/the-return-of-the-middle-american-radical?lang=en), Carnegie Endowment for International Peace (2015)