Spain’s National Markets and Competition Commission (CNMC) has issued a favorable assessment regarding the draft law reforming the Reciprocal Interest Adjustment Agreement (CARI) system, a key public financial instrument designed to support the internationalization of Spanish companies. Revised upon request from the Ministry of Economy, Trade, and Enterprise, the reform aims to clarify institutional roles, improve oversight, and strengthen the overall coordination of state support mechanisms managed by the Official Credit Institute (ICO).
While the CNMC praised the reform for boosting operational transparency and supervision, the regulator highlighted several areas where the framework could be improved to enhance accessibility and efficiency, particularly for small and medium-sized enterprises. The competition authority reiterated its recommendation to establish a single financial portal or “one-stop shop” to centralize information, training, coordination, and advisory services for businesses seeking internationalization support.
From a regulatory and competition standpoint, the CNMC outlined several specific recommendations. It called for clearer identification of target economic sectors—such as green energy and defense projects—to ensure consistency between stated reform goals and practical implementation. The regulator also recommended adding an explicit assessment of the CARI framework’s compatibility with European Union state aid rules under Article 107 of the Treaty on the Functioning of the European Union (TFEU).
Furthermore, the CNMC advised the government to provide clear justification for assigning exclusive roles to public entities, including the ICO, COFIDES, and the Insurance Compensation Consortium, explaining why these assignments are preferable to competitive selection processes. It also urged authorities to define why credit institutions remain the sole potential beneficiaries of interest rate risk coverage and to clarify which entities may access foreign exchange risk coverage. Finally, the watchdog recommended establishing objective, predictable criteria for allocating CARI coverage when annual application volumes exceed set budgetary limits, preventing potential discrimination among applicants or strategic projects.
