Spain's Mandatory 40% Board Gender Quota for Listed Companies (Ley Orgánica 2/2024)

Ley Orgánica 2/2024, de 1 de agosto, de representación paritaria, entered into force on 22 August 2024 and amends Article 529 bis of the Ley de Sociedades de Capital. It legally requires listed companies (sociedades cotizadas) to reach at least 40% representation of the underrepresented sex on their boards of directors, with the 35 largest listed companies by market capitalisation required to comply by 30 June 2026 and all other listed companies by 30 June 2027. Unlike Switzerland's disclosure-only model, non-compliance can be treated as a serious infringement (infracción grave) under Spain's securities-market law, giving the CNMV a supervisory and potential sanctioning role.
CNMV's 2024 corporate-governance data show IBEX 35 boards reached 41.27% women — the first time the flagship index crossed 40%, and up from roughly 40.1% in 2023, adding 175 women board members (72 more than in 2017). 55 listed companies, including 24 IBEX 35 members, already meet or exceed the legal 40% threshold ahead of their statutory deadlines.
Across the full universe of Spanish listed companies (IBEX plus non-IBEX), the average was 36.58% at end of 2024 — still below the 40% target that applies from 2026–2027, meaning most of the gap remains among smaller and mid-cap listed firms with more time left before their deadline. Separate reporting also finds representation in senior executive management (as opposed to non-executive board seats) lagging well behind, around 27.7% for IBEX 35 senior management even as board seats exceed 40%.
Caveat: the flagship IBEX 35 index has already met the eventual legal target two years early, but the broader listed-company population (36.58%) has not yet reached it, and the quota governs board seats rather than executive management, where the gap remains much larger.

Read the full analysis: https://www.cnmv.es/