Adaptation of 18 Public Bodies to Law 40/2015: What Changes in 2026

Key data

Eighteen state bodies—with an adaptation deadline that expired in October 2024—are finally aligned with the Law 40/2015 on the Legal Regime of the Public Sector thanks to Royal Decree 466/2026, published in the BOE on June 12, 2026 and in force from that same date. The delay of almost two years with respect to the legal deadline makes this regulation a de facto regularization of a situation of structural non-compliance.

The decree does not create new bodies or eliminate existing ones: it formally adapts them, updating names, governance structure, personnel regime, contracting, economic-financial management and budget control modalities.

What does this regulation establish?

Law 40/2015 established a new legal framework for the state public sector and set a deadline for existing bodies to adapt to its provisions. That deadline expired in October 2024 without most of those affected having completed the adaptation. Royal Decree 466/2026 executes that adaptation in a centralized manner for the 18 bodies that still had it pending.

The affected bodies, differentiated by type, are as follows:

The specific matters that are modified in each body are:

• Organizational structure: updating of governance and management bodies in accordance with the models of Law 40/2015.
• Names: standardization of names and legal categories.
• Personnel regime: adaptation of internal human resources management rules.
• Contracting: alignment with public sector contracting procedures.
• Economic-financial management: updating of internal budgetary and financial frameworks.
• Budget control: regulation of applicable financial control modalities.

The additional provisions of the decree also regulate action plans, management contracts, balanced representation in collegial bodies and the financial control modalities applicable to each type of entity.

Economic and operational impact

The decree does not generate new direct costs for private companies or citizens. Its impact is fundamentally internal to the public sector: the 18 bodies must review and update their bylaws, internal regulations and management procedures to align with the new framework.

For companies and professionals operating as suppliers, contractors or users of these bodies, the practical effects are:

• Public contracting: the procurement procedures of these bodies are standardized, which can simplify participation in tenders.
• Labor relations: the decree does not alter the conditions of public employees in these bodies.
• Services to citizens and companies: no substantial changes are foreseen in the services provided by any of the 18 bodies.
• Transparency and evaluation: the standardization of the regulatory framework strengthens the mechanisms for evaluating results and financial control, which can improve predictability in relations with these entities.

Who does it affect?

• Public employees of the 18 adapted bodies: will experience formal changes in their internal regulatory framework, although without alteration of their current working conditions.
• Supplier or contractor companies of MUFACE, AESA, INTA, National Library, Railway Safety Agency, Digital Administration Agency and Institute of Fiscal Studies: may see updated applicable contracting procedures.
• Civil servants of the State who are MUFACE members: no changes in benefits, but with a renewed institutional framework.
• Aeronautical and railway sector: companies regulated or supervised by AESA and the Railway Safety Agency should be alert to possible procedural updates resulting from internal reorganization.
• Technology and digital administration sector: companies collaborating with the State Agency for Digital Administration may see adjusted contractual relationship frameworks.
• Legal advisors and consultants working with state public sector bodies: must update their knowledge of the statutory framework of each entity.

Practical example

A technology company that regularly bids for contracts with the State Agency for Digital Administration will find that the tender documents and procurement procedures of this agency have been updated to reflect the new framework of Law 40/2015. In practice, this means that the management contracts and action plans of the agency will be formalized in accordance with the standard models of the state public sector, reducing procedural variability compared to other already-adapted bodies. The company does not need to do anything different to participate in tenders, but it is advisable that its legal team review the new published bylaws to identify whether there are changes in the contracting bodies or in the internal approval procedures.

Similarly, a MUFACE member will not see their health benefits or contributions altered: the change is strictly organizational and internal to the functioning of the mutual.

What should companies do now?

1. Identify if your company operates with any of the 18 adapted bodies. If you are a supplier, contractor or have regulatory relationships with MUFACE, AESA, INTA, National Library, Railway Safety Agency, Digital Administration Agency or the Institute of Fiscal Studies, check if there are updates in contracting procedures or in the points of contact.
2. Update your public contracting files. If you have contracts in force or in process with these bodies, verify that the points of contact and internal approval bodies have not changed in name or competencies.
3. Consult the new bylaws of each body. The decree modifies internal bylaws: if your activity depends on authorizations, supervision or certifications issued by AESA or the Railway Safety Agency, verify that the applicable procedures remain the same.
4. If you are a legal advisor in the public sector, update your documentation on the statutory framework of the 18 bodies and communicate to your clients the changes in names and governance structure.
5. No urgent actions are required for citizens or most private companies, given that the decree does not alter services or existing labor relations. The priority is informational and monitoring.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-12711