The Consejo de Transparencia y Buen Gobierno (CTBG) ordered the Ministerio de Asuntos Exteriores, Unión Europea y Cooperación to disclose reliable, non-personal statistics on citizenship granted under the Ley de Memoria Histórica of 2007 and the Ley de Memoria Democrática of 2022. The decision followed a complaint by a member of the public: after submitting an information request in October 2025 and receiving no response, the applicant filed a complaint with the CTBG in May 2026.
The Transparency Council requires a breakdown by country and stage of proceedings, covering applications received, approvals, refusals and pending cases. The request expressly includes the additional provision commonly known as the ley de nietos , in Ley 20/2022, which facilitates access to Spanish citizenship for descendants of exiles. The CTBG bases the disclosure requirement on the right of access to aggregated information of public interest, which allows democratic scrutiny without disclosing personal data.
The order has practical significance beyond this individual case. Previous CTBG decisions had already clarified the Foreign Ministry’s obligation to publish internal guidelines and consular practices. Repeated disputes over access to information show that the department is regularly called upon to clarify the scope of transparency rights. Under the new order, the authorities must provide the requested data in aggregated form; the ministry could in principle take legal action against the decision, but has not announced that it will do so.
Politically, the decision comes at a time of increased judicial scrutiny of the application of the Ley de Memoria Democrática. In early September 2026, the Tribunal Supremo ordered precautionary measures that include provisionally affecting the registration in the overseaselectoral register of certain people granted citizenship under the ley de nietos. The Junta Electoral Central In this context, it pointed to the need for reliable data to assess eligibility to vote. The statistics requested by the CTBG address precisely this gap: they are intended to show the scale of the proceedings and clearly distinguish between pending, approved and rejected cases.
It remains unclear how long the Foreign Ministry will take to provide the information, and whether it will be possible to compile the data consistently going back to 2007. What is clear, however, is that the transparency requirement will improve the data available to electoral authorities and courts dealing with ongoing disputes over registration and the exercise of political rights.
Editor: Mira Cadena (Article created with AI assistance).