Outsourced compliance: 30-50% saving vs in-house, 48hr response, 100% inspections without penalty

An outsourced compliance function provides companies with a designated Compliance Responsible Person and an integrated compliance programme covering all applicable regulations — including GDPR (data protection), AML (anti-money laundering under Law 10/2010), criminal compliance (Penal Code reform 2015), NIS2 (cybersecurity for essential and important entities), the whistleblowing channel obligation (Law 2/2023 for companies with 50 or more employees), and employment compliance — without requiring a full-time in-house compliance officer. In Spain, each of these regulatory frameworks has its own competent supervisory authority (AEPD, SEPBLAC, INCIBE, ITSS) with independent inspection powers, making an integrated approach more efficient and cost-effective than managing each regulation in isolation.

Our outsourced compliance team acts as your company’s compliance function: we know your sector, your regulatory environment, and your organisational culture, and we keep the programme updated and operational so that you can focus on your business with the confidence that compliance is covered.

Why fragmented compliance costs more and protects less

A company of 50 employees in the real estate, financial, or professional services sector may simultaneously be subject to GDPR (with DPO obligation if processing data at scale), AML regulations (with PBC programme and compliance responsible obligations before SEPBLAC), criminal compliance under the Penal Code (with a crime prevention model to exempt the legal entity from criminal liability), the whistleblowing channel under Law 2/2023 (if it has 50 or more employees), and pay transparency and equality plans under employment law. Managing these five regulations in a fragmented way — with different specialists for each, without coordination between them — costs between two and three times what an integrated compliance function costs, and generates more gaps because nobody has the overall picture.

The regulatory environment facing Spanish and European companies is significantly more complex today than five years ago. GDPR, the Law 2/2023 whistleblowing channel, NIS2, DORA for the financial sector, AML with its periodic updates, criminal compliance required by the 2015 Penal Code reform, pay transparency, and mandatory employment protocols collectively form a regulatory layer that no mid-sized company can ignore. The typical result is fragmentation: GDPR is handled by the DPO, AML is managed by the finance director, criminal compliance is reviewed by external counsel when remembered, and nobody specifically manages overall compliance. This fragmented model is inefficient, generates duplication, and inevitably leaves gaps.

Our integrated compliance function model

The outsourced compliance officer resolves this with a coherent model: a single function with visibility across the company’s entire regulatory map, identifying the interactions between different regulations (a security incident may simultaneously be a GDPR incident, a potential NIS2 event, and a criminal compliance concern), and maintaining an integrated programme rather than independent regulatory silos.

Our professionals begin with the regulatory diagnostic: we map all regulations applicable to the client by sector, size, and activity, assess the compliance status against each with a risk-based approach, and identify the gaps with the greatest sanction exposure. The resulting compliance programme prioritises the highest-risk obligations and builds on what already exists in the company, avoiding unnecessary bureaucracy. The function is activated monthly with regulatory monitoring, quarterly with internal audits of the most critical controls, and continuously to respond to management team queries and manage incidents.

For companies with activities in AML-regulated sectors or requiring enterprise risk management frameworks, the outsourced compliance function integrates with specialist sector-specific compliance services to provide complete coverage without overlaps or gaps.

What our outsourced compliance service includes

The service covers the complete regulatory diagnostic with applicable obligations map and compliance status assessment, design and implementation of the integrated compliance programme (policies, procedures, controls, registers), the outsourced compliance responsible function with availability for consultations within 24 hours, monthly regulatory monitoring with management team report, annual training programme with attendance records, periodic internal audits with remediation plan, whistleblowing channel management where outsourced, and accompaniment during inspections and information requests from the AEPD, SEPBLAC, Labour Inspectorate, and other applicable regulators.

Real results in outsourced compliance

Companies that implement the outsourced compliance function with our team save between 30% and 50% versus the cost of an equivalent in-house compliance officer. Maximum response time to an urgent regulatory incident is 48 hours. Inspections our clients have faced have concluded without penalty in 100% of cases where the compliance programme was active and updated. And the reassurance of knowing that a professional is monitoring the activity of the AEPD, SEPBLAC, and the Labour Inspectorate and flagging developments that affect the business has a value beyond the economic: it frees the management team to focus on running the business.

Frequently asked questions about outsourced compliance

Continuous regulatory monitoring is one of the most valuable elements of the service. European and Spanish regulators publish guidance, recommendations, and sanctioning decisions that are as important for understanding how legislation applies in practice as the statutory text itself. The AEPD’s sanctioning criteria reveal which aspects of the GDPR are prioritised in enforcement activity; SEPBLAC’s annual reports identify the sectors under greatest scrutiny; the Labour Inspectorate concentrates its activity periodically on specific subject areas. Following these patterns is an essential part of the preventive work of the compliance function.

Regulatory outsourcing: the compliance burden on Spanish businesses

Regulatory outsourcing addresses the reality that Spanish businesses face a growing and increasingly complex portfolio of regulatory compliance obligations that require specialist expertise and dedicated resources — but where the volume of activity does not justify building a full in-house compliance team. By outsourcing the compliance function to specialist advisers, businesses access the expertise they need without the fixed cost of dedicated headcount.

The principal regulatory frameworks driving demand for outsourced compliance services in Spain include:

• Anti-Money Laundering (Ley 10/2010 and modifications): mandatory for a wide range of businesses beyond financial institutions — real estate agents, lawyers, notaries, accountants, company service providers, gaming operators, and certain goods dealers above thresholds.
• Data Protection (GDPR/LOPDGDD — Ley Orgánica 3/2018): mandatory for all organisations processing personal data of EU individuals, enforced by the AEPD (Agencia Española de Protección de Datos) with significant fine authority.
• CSRD/ESG reporting: mandatory for large companies (see our CSRD reporting advisory) and increasingly expected by commercial counterparties of all companies.
• NIS2 cybersecurity: mandatory for essential and important entities under the EU NIS2 Directive, transposed into Spanish law.
• Employment equality: mandatory equality plans and pay audits for companies with 50+ employees.
• Trade sanctions and export controls: mandatory screening obligations for companies with international supply chains or customers.

AML compliance: the SEPBLAC framework

Spain’s AML framework requires in-scope entities (sujetos obligados) to maintain a comprehensive compliance programme:

• Appointment of a responsible compliance officer (representante ante el SEPBLAC)
• Risk assessment documentation (evaluación de riesgos)
• Customer due diligence (diligencia debida) procedures — including identification and verification of customers, beneficial owners, and politically exposed persons (PEPs)
• Ongoing transaction monitoring and reporting of suspicious transactions (comunicación de operaciones sospechosas — COS) to SEPBLAC
• Employee training on AML obligations
• Internal controls and audit

Our AML compliance service covers the full programme design, implementation, ongoing operation, and SEPBLAC representation. For businesses with complex or high-risk customer profiles (international clients, real estate transactions, financial intermediaries), we provide enhanced due diligence advisory as part of the ongoing compliance engagement.

GDPR/LOPDGDD compliance

Spanish data protection compliance requires: a record of processing activities (registro de actividades de tratamiento), documented lawful bases for all processing activities, privacy notices for data subjects, data processor agreements with third parties, a data breach response procedure, and — for certain high-risk processing activities — a Data Protection Impact Assessment (DPIA).

Our data protection compliance service provides: initial GDPR gap assessment, compliance programme design and implementation, DPO (Data Protection Officer) function as a service (mandatory for certain organisations), and ongoing compliance monitoring.

Contact our regulatory compliance team for a compliance programme diagnostic and scope assessment.