Spain’s New University Rulebook: What the BOE‑approved reform does—and why it matters
On 7 October 2025 Spain approved Royal Decree 905/2025, published in the Boletín Oficial del Estado (BOE) on 8 October. The decree revises the framework for creating, recognising and authorising universities and university centres (RD 640/2021), updates the national registry (RD 1509/2008), the degree‑issuance rules (RD 1002/2010), and the organisation and quality‑assurance regime for programmes (RD 822/2021).
Summary
The reform hard‑wires quality, research and scale into the legal definition of “university” in Spain. Ideologically, it elevates universities’ public‑interest role—equity, employability, research‑led teaching—over purely market‑share logics, and moves the system from permissive expansion to curated growth with high transparency. For private universities in particular, the path forward is clear but steeper: build comprehensive portfolios, secure capital and housing, compete for research funding, professionalise online delivery, and grow to critical mass—fast enough to meet the six‑year tests.
Why the reform—and the ideology behind it
Quality and equity as public‑interest goals. The preamble frames higher education as a service of general interest and argues that the system’s “global quality” must be preserved as a pillar of social welfare and equal opportunity. The Government locates its authority in Spain’s Constitution and in the 2023 Framework Law for the University System (LOSU).
Rapid growth and new market dynamics. The decree cites an “exponential” expansion in universities and titles, alongside a surge in online provision (about 26% of students study virtually) and a sharp divergence in research intensity—private universities attracted ~5% of competitive research resources despite accounting for a large share of institutions and students. These trends, the Government argues, require “ordering” growth to ensure quality.
Tighter gatekeeping after uneven approvals. The preamble notes cases where some private universities were recognised despite negative evaluations or after the national policy body (CGPU) issued unfavourable reports—one of the drivers for making quality assessments binding.
Political narrative. In public debate the reform has been presented as a move to “curb an unprecedented expansion” of private provision, a framing that underscores the Government’s normative goal of re‑centring research‑intensive, comprehensive universities over purely market expansion.
Importantly, the decree insists it does not block growth but channels it under stronger quality guarantees.
The main changes at a glance
- A binding quality gate before any university is approved.
Creation/recognition now requires two prior reports:- a preceptive and binding evaluation by ANECA or the relevant regional agency; and
- a second preceptive report prepared by the Ministry and elevated to the General Conference on University Policy (CGPU).
- Minimum academic portfolio and breadth.
Every university must offer at least 10 Bachelor’s, 6 Master’s and 3 Doctoral programmes, with coverage of at least three of the five broad fields (Arts & Humanities; Sciences; Health; Social Sciences & Law; Engineering & Architecture). - Critical mass of students and structure.
The founding plan must forecast >4,500 students in official degrees by year six; after six years, Bachelor’s (including double‑degree itineraries) must account for ≥50% of total enrolment, or ≥35% in institutions where >50% of Master’s students are international. - Research is non‑negotiable (with quantified duties).
Universities must earmark ≥5% of total budget (net turnover for private, total income for public) for internal research/knowledge‑transfer programmes—excluding ordinary PDI salaries and general administration—and capture ≥2% of their annual budget in external, competitive R&D&I funds; persistent shortfalls can lead to corrective plans and, ultimately, revocation. Transition: existing universities have 5 years to meet the 2% capture target; new ones, 10 years. - Faculty, staffing and online‑teaching rules.
The decree redefines staffing baselines (e.g., doctoral‑degree coverage of teaching: ≥50% in Bachelor’s and Master’s; 100% in Doctorate) and bars full‑time public‑sector PDI in active service from holding PDI posts in private universities. For mostly online universities, detailed disclosure of platforms, synchronous/asynchronous format and assessment is mandatory; a four‑year transition applies to comply with the new faculty rules. - Student housing capacity.
New universities must ensure student accommodation equal to at least 10% of planned on‑campus places (operational by year three), directly or via partnerships. Virtual‑model “special‑characteristics” universities are exempt. - Financial solidity and group transparency.
Private initiatives must evidence funding for full third‑year operations and present guarantees (bank guarantees, surety insurance or government debt instruments) deposited in the Caja General de Depósitos (or the regional equivalent). They must also disclose whether they belong to corporate groups or investment funds. - Information, transparency and comparability.
Universities must report granular data to the Integrated University Information System (SIIU)—including average tuition prices (for private), research income, staffing and outputs—and the State will publish a public employability comparator (employment rates, wages and job‑study match at 3/6/10 years). - Limits on programme proliferation.
Active universities may seek verification of no more than 20% of their existing Bachelor’s/Master’s titles per year (for new or substantially modified programmes). A university with one‑third or more of its official titles unaccredited cannot file new titles until this is remedied. - Quality systems and ethics.
Internal quality systems must be certified (design within 1 year, full implementation within 2), and every university must have a research‑integrity/ethics committee (or be covered by an existing regional body). - Diplomas will state the teaching mode.
Official degrees must now indicate whether the programme was taught in‑person, hybrid or fully online. - Centres and networks.
“Centros adscritos” must regularise their status—generally one host university—and foreign university centres in Spain face clearer authorisation, registry, and EQAR‑level quality requirements. - Sanctions and revocation triggers.
Not launching activity within 2 years of authorisation, or failing to reach 70% of the year‑six enrolment threshold thereafter (i.e., below ~3,150 students) can trigger corrective plans and potential revocation. Falling below the minimum 10‑6‑3 portfolio after accreditation renewals can also lead to revocation.
Expected effects on Spain’s university system
System‑wide
- Higher entry bar, slower velocity of expansion. A binding quality gate, portfolio minimums and enrolment/research thresholds will likely reduce “quick‑launch” projects and temper the recent proliferation of titles (the decree notes 9,765 official programmes in 2023–24, up ~1,500 in seven years).
- More transparency and comparability. The SIIU obligations and the public employability dashboard—wages, employment and job‑study match—will tighten information symmetry for families and students, and raise reputational stakes for all institutions.
- A push toward research intensity. The 5% internal/2% external research funding rule, together with publication and project‑submission benchmarks, will tie institutional legitimacy to sustained research performance.
Specific pressure points for private providers
- Scale and breadth. New and small private institutions will need to reach critical mass (4,500 by year six) and maintain a diversified 10‑6‑3 portfolio across three fields—moving away from narrow, Master’s‑heavy models to a comprehensive university profile.
- Capital and liquidity. The Caja General de Depósitos guarantee, the 10% housing capacity, and upgraded labs/CRAI expectations imply up‑front capital plus multi‑year operating buffers.
- Faculty market constraints. The ban on public‑sector full‑time PDI holding PDI posts in private universities narrows the candidate pool and will push private institutions to deepen their own tenure‑track pipelines and international recruitment.
- Online quality and assessment. Providers with large‑scale virtual offerings must document pedagogy, platforms, assessment (including which exams are in‑person) and mentoring, with a four‑year window to meet stricter faculty and delivery standards.
- Programme‑launch discipline. The 20% cap on annual verifications and the “one‑third unaccredited, no new titles” rule will curb rapid product churn and favour consolidation over volume growth.
- Research spend and outputs. The 5% internal/2% external rules—and text that links staff evaluation to publications and externally funded projects—will require significant new investment in research capacity, grant capture and partnerships.
Compliance timelines (selected)
- General adaptation: institutions already authorised to operate have up to 3 years to adapt (5 years if they began activities within the last 3 years); institutions created/recognised but not yet authorised have 5 years from authorisation. Foreign centres in Spain: 3 years.
- External research income (2%): 5 years for existing universities; 10 years for new ones.
- Virtual‑teaching faculty rule: 4 years for universities with predominantly online teaching already in operation.
