The Draft Royal Decree regulating the Strategic Investment Committee and developing the criteria and procedure for declaring Strategic Investment Projects establishes the institutional and operational framework for channeling this type of initiatives. Specifically, it articulates the creation of this coordinating body and details the process of evaluation and recognition of the projects, with the aim of facilitating their processing and reinforcing their impact on the productive fabric.

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Type of projects

In order for a company’s initiative to be considered a Strategic Investment Project (SIP), it must comply with a series of fundamental characteristics defined in the regulations:

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Nature and location

The initiative must consist of investment or reinvestment projects in Spanish territory. These projects may have two legal forms:

• Initiatives of a strictly business nature.
• Public-private collaboration initiatives.

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Central objective

The main purpose of the investment must be to improve the country’ s technological, scientific or productive capacities. These are not maintenance investments, but rather investments with a transformative vocation that modernize the productive fabric.

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General interest

In order to be declared strategic, the initiative must be in the public, social and economic interest for the benefit of the country as a whole. This implies that the project must provide a “return” that goes beyond the private benefit of the company, contributing to aspects such as:

• Economic security and national strategic autonomy.
• The ecological transition and decarbonization of the economy.
• Digital transformation, especially oriented to SMEs.

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Preferred areas of activity

Although the standard allows for the evaluation of diverse projects, priority is given to initiatives in sectors with high resilience capacity, such as:

• Semiconductors and digitization.
• Renewable hydrogen and energy transition.
• Health, biotechnology and agri-food.
• Critical raw materials and aerospace.
• Data processing centers.

Acquisitions of shares or equity interests, as well as capital increases or reductions and structural modifications of companiesare expressly excluded.

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Criteria for qualifying an investment as a strategic investment

The regulations distinguish between initial and detailed valuation criteria:

1. Pre-assessment criteria (initial phase):

The Strategic Investment Committee evaluates the application within one month. During this phase, the minimum requirements, financial solvency and strategic fit of the project are analyzed to provide early guidance to the promoter on its viability.

The company must demonstrate that the project is of sufficient scale and fits within the country’s priorities. The priority criteria are:

• Investment volume: It must be relevant on a national scale or, at least, have a very significant impact on the economy of the specific territory where it is installed.
• Qualified employment: The creation of a relevant volume of highly qualified jobs is required.
• Preferred sectors: Although the list is not closed, priority is given to projects in energy transition, semiconductors, decarbonization, health, biotechnology, agri-food, aerospace, critical raw materials and data processing centers.
• Initial maturity: The Committee will assess that the project is not a mere idea, but that it presents a sufficient degree of maturity to be executable.

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2. Criteria for the definitive declaration (detail phase):

A detailed analysis of the socioeconomic effects and alignment with sectoral policies is carried out. The Committee submits a resolution proposal to the Government Delegate Commission for Economic Affairs (CDGAE), which is the body in charge of issuing the final resolution and granting the definitive declaration. This declaration may include specific support measures and commitments or obligations to be fulfilled by the promoter.

The company should detail how its investment brings value to the country through:

• Sound Business Plan: Scalability, market potential and degree of execution already achieved are evaluated.
• Sustainability and Decarbonization: The company must provide indicators such as carbon footprint or energy efficiency parameters.
• Innovation Effort: Measured through planned R&D expenditure, agreements with research centers or participation in professional training programs.
• Impact on the Value Chain: It is assessed whether the project helps to create or maintain an economic or scientific-technological ecosystem in its environment.
• Cohesion and Equality: The impact on gender equality, social inclusion and employee training/requalification are key evaluation points.

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How do traditional manufacturing sectors fit in?

Although traditional manufacturing sectors do not appear on the standard’s list of priority sectors, this does not exclude them. The key is another question: do any of these priority sectors benefit from the product or technology we manufacture?

If the answer is yes, the argument is sound. It is not a question of forcing a sectoral fit, but of recognizing that, without process machinery, without advanced industrial equipment, without the systems that automate or electrify production, many of these sectors cannot scale, decarbonize or digitize. The contribution to their value chain is real and demonstrable.

The challenge, therefore, is not one of eligibility but of storytelling: can you identify and quantify the impact of your investment in that value chain? If so, the application is worth exploring. The pre-stage has a one-month resolution time and a relatively low administrative burden, allowing you to do that test at low cost.