Spanish authorities have made significant progress in strengthening the cyber resilience of their financial sector, according to a new peer review published by the Financial Stability Board (FSB). The report, released on November 18, 2025, highlights that Spain has implemented several good practices and has focused on preparing for enhanced requirements under the European Union Digital Operational Resilience Act (DORA).
Despite these efforts, the FSB notes that ongoing digitalisation and an evolving cyber risk environment require further improvements. The review recommends that Spanish authorities develop a comprehensive mapping of the cyber threat landscape to better inform decision-making for both industry participants and regulators. It also suggests leveraging best practices to increase consistency and maturity in cyber resilience across agencies, including through cross-sectoral working groups and information-sharing mechanisms overseen by the Spanish Macroprudential Authority.
Other recommendations include conducting a national analysis of existing registers of information to identify critical third-party providers within Spain, assessing concentration risks, and creating strategies to address domestically critical third parties. The FSB also advises establishing a single national channel for incident reporting that automatically shares data with relevant authorities. Additional measures such as intergovernmental working groups, playbooks, and crisis drills are recommended to improve preparedness.
“Cyber incidents can pose systemic risks, disrupting critical financial services and eroding market confidence,” said Jane Magill, Executive Director of General Insurance and Banking at APRA and Chair of the Spain peer review. “Detailed examination of a jurisdiction’s approach provides benefits to all jurisdictions that are constantly looking to enhance their response to this risk.”
The FSB previously published a toolkit in 2023 aimed at improving third-party risk management and oversight. This included recommendations for harmonised incident reporting and information sharing among regulatory bodies. Peer reviews like those conducted in Spain form part of broader efforts by FSB member jurisdictions to periodically assess adherence to international financial standards.
Spain volunteered for this peer review as part of its commitment under the FSB’s regular programme evaluating member countries’ implementation of global standards. A schedule of country reviews and completed reports is available on the FSB website.
The Financial Stability Board coordinates international efforts among national financial authorities and standard-setting bodies with the goal of promoting effective regulation and stability in global finance. Chaired by Andrew Bailey, Governor of the Bank of England, its Secretariat is based in Basel, Switzerland at the Bank for International Settlements.