Spain’s AI bill: current status and proposed penalties

Has Spain passed its new AI law?

As of 20 September 2026, Congress lists bill 121/000096 at the amendments stage, with a published deadline of 23 September at 18:00. Its title is the Organic Law bill for the proper use and governance of artificial intelligence.

The text can change during scrutiny. An amendment deadline is not an effective date.

What penalties does the draft propose?

Article 30 of the June draft sets out these general ceilings:

For companies, the draft refers to the higher amount. These are proposed limits, not automatic fines for using AI. Application requires examining the conduct, responsible party and relevant rules.

The table should not be treated as a direct copy of every EU penalty category. Read the categories and circumstances in each instrument separately.

What should an image or video producer check?

The bill addresses transparency failures involving deepfakes, among other matters. Start by assessing the relevant European obligation, then consider supervision and penalties.

Generated images do not all receive identical treatment. Content, use and the roles of those providing or deploying the system matter. Nor should a producer assume that publication transfers all responsibility to the client.

Our guide to marking and disclosing AI-generated content explains these distinctions.

Track changes without restarting the project

Keep a short record of the intended AI use, participants, generated material and publication decisions. Separate applicable requirements from pending changes.

To update the record, check the parliamentary file, the final approved text and its official publication. A new amendment deadline does not mean that every obligation has changed.

For a specific assignment, this documentation supports legal review and a clear allocation of tasks: checking content, preparing disclosures and approving publication.

For the broader European timetable, see our EU AI Act deadline guide.

To check which obligations affect a live project, tell us what you generate and where it gets published.