ES-Listed Companies
Regulator: CNMV.
Directors' dealings in Spain: the CNMV notification register
One electronic procedure, published on receipt
Spanish managers and their closely associated persons report transactions to the Comisión Nacional del Mercado de Valores (CNMV) through the NOD procedure (notificación de operaciones de directivos) on its electronic office. The CNMV opened NOD in April 2018 for executives who do not sit on the board, and directors of companies traded on multilateral trading facilities used it too. The CNMV publishes notifications on its website as soon as it enters them in its official register.
Why board members changed channel in March 2020
Spanish directors (consejeros) used to work under an older and stricter duty. Article 125.5 of the Securities Market Law and article 31 of Royal Decree 1362/2007 made them report the share of voting rights they held after each purchase or sale, with no minimum amount, on form II of CNMV Circular 8/2015.
In February 2020 the CNMV announced that it would treat that duty as met by the MAR article 19 notification. From 2 March 2020 directors, and closely associated persons whose voting rights belong to the director, file through NOD only, and the CNMV withdrew form II. Directors who are also significant shareholders must additionally file significant holding notifications. The 2015 Securities Market Law has since been replaced by Ley 6/2023, in force since 7 April 2023.
Threshold and what the Spain hub shows
Spain does not appear on ESMA's list of regulators that changed the threshold (version of 21 May 2026), so the EU default applies: the duty starts once a person's transactions reach 20,000 euros in a calendar year, counted without netting. Before 4 December 2024 the figure was 5,000 euros.
The Spanish feed on this site is per-trade and comes from the CNMV directors' notifications. Each card links to the CNMV document when the source provides one, and the company hub ranks issuers by number of insider filings, 50 per page. The methodology covers how the filings are processed.