If your organisation receives public subsidies, contracts with public authorities, or is a foundation, association or cooperative of a certain size, you have active transparency obligations. We help you meet them without unnecessary bureaucracy.
Law 19/2013, of 9 December, on Transparency, Access to Public Information and Good Governance applies not only to public administrations but also to private entities that receive grants or subsidies exceeding €100,000 per year, or where 40% or more of their total income comes from public funds (provided that amount exceeds €5,000). In addition, each autonomous community has developed its own legislation — Castilla y León with Law 3/2015, Canary Islands with Law 12/2014, Catalonia with Law 19/2014 — with thresholds and requirements that in some cases are stricter than the national standard. An SME or entity working with several administrations may unknowingly be subject to obligations arising from multiple regulatory layers.
The specific obligations include active disclosure: budgets and annual accounts, a list of formalised contracts, grants received, remuneration of top executives and information on the organisational structure. This information must be clearly and regularly accessible on the entity's website or transparency portal. Holding it internally is not enough; non-compliance exposes the entity to requests from the Council for Transparency and, at the regional level, to sanctions and the possibility of being barred from future grant calls.
At Summum Consultoria we support foundations, associations, cooperatives, concession holders and regular public-sector suppliers in diagnosing exactly which obligations apply to them, structuring their transparency portal, drafting active-disclosure policies and keeping them up to date year after year. We have been working in regulatory compliance with SMEs and non-profit entities in Castilla y León and the Canary Islands since 2007; we understand the nuances of the regional regulations that affect our clients.
We analyse the entity's funding profile, volume of grants received, contracts with public authorities and applicable regulations (national and regional). We determine what information must be published, how often and in what format.
We define the structure of the portal or transparency section on the website: mandatory content blocks, document templates, update criteria and the internal person responsible. The goal is to make compliance repeatable year after year without extra effort.
We collect and organise information from recent financial years (accounts, contracts, grants, governing bodies) and publish it in the agreed format and channel. We coordinate with the IT team or web provider as needed. Where data governance is involved, we link up with Summum Sistemas.
We carry out an annual review to update published information, adapt the portal to regulatory changes and prepare documentation for potential audits or requests from the Council for Transparency or the equivalent regional body.
The operational detail: what we deliver as part of the work and what we keep alive afterwards.
Personalised regulatory diagnosis
Identification of the applicable layer (Law 19/2013, regional law and sector-specific regulations) and the exact threshold that triggers the entity's obligations.
Inventory of information to be published
Comprehensive list of mandatory active-disclosure blocks: contracts, grants, accounts, governing bodies, remuneration and more.
Transparency portal or section
Design of the web area in line with the standards of the Council for Transparency and Good Governance and regional reference portals.
Templates and internal procedure
Standard documents for accounts, minutes, contract and grant lists, with instructions so the internal team can update them without relying on external consultants each time.
Annual review and update
Maintenance service to ensure published information is renewed within the deadlines set by law and reflects the closed financial year.
Response to information requests
Support in the event of inspections, information requests from the Council for Transparency, regional commissioners or public-access requests.
Transparency does not exist in isolation: it intersects with data protection (GDPR), data governance and contract management — areas in which the Consultoria and Sistemas divisions of Grupo Summum work in a coordinated way.
Active disclosure requires publishing personal data (executives, beneficiaries); the GDPR defines what can be published and how. Both services are coordinated to avoid conflicts between transparency and privacy.
View service → consultoríaKeeping the transparency portal up to date requires information to flow reliably from the entity's systems; Summum Consultoria governs that data flow.
View service → sistemasIf the entity needs to build or adapt its website to host the transparency section, Summum Sistemas leads the technical development.
View service →It depends on your relationship with public funds. Law 19/2013 applies to private entities that receive more than €100,000 in public grants or subsidies in a year, or where those grants account for at least 40% of their annual income (with a minimum of €5,000). Furthermore, if your company regularly bids for public contracts or is linked to a public authority, the regional law in your community may set different or additional thresholds. A preliminary diagnosis is the fastest way to find out where you stand.
For obligated private entities, the minimum active disclosure includes: budgets and annual accounts, contracts formalised with public authorities, grants and subsidies received, remuneration of top executives and the entity's organisational structure. The information must be clear, accessible and up to date on your website or transparency portal; holding it internally is not sufficient.
Non-compliance can lead to formal requests from the Council for Transparency and Good Governance or the equivalent regional commissioner. In practice, the most immediate consequences are typically exclusion from grant calls or the inability to contract with certain public authorities, as well as exposure to public decisions that damage the entity's reputation.
Foundations and associations of public benefit that receive public funding above the legal thresholds have obligations equivalent to those of any other obligated private entity. Some autonomous communities also have specific regulations for the non-profit sector with their own accountability requirements. The regional legislation of Castilla y León (Law 3/2015) and the Canary Islands (Law 12/2014) develop these requirements in detail.
Law 19/2013 establishes that information must be permanently up to date. In practice, the natural cycle is to update annual accounts and financial information after each financial year closes, and to keep contract and grant data current throughout the year. Our annual maintenance service ensures that the portal is always compliant, without requiring you to dedicate internal resources to tracking deadlines.