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End of 2019: The Ministry of Culture opened a first round of Public Consultation. There was no text proposal from the Ministry and the call was for organizations and civil society to submit their approach and concerns towards the CDMS directive.
A text proposal for transposition should be made available by the Ministry of Culture. Once the text is public there will be a second round of Public Consultation to submit feedback.
May 2020: The Ministry of Culture has stated that a draft text for transposition will be made public once the State of Alarm due to sanitary crisis is over. Most likely, the draft will be ready around late June-mid July. There will be a second round of public consultation for organizations and civil society to send feedback on the legal text.
July 2020: The Ministry of Culture is supposed to provide a draft text to the other ministries for the inter-ministerial consultation. This should happen soon, but is delayed by new state of emergency measures. After the ministries had their chance to provide feedback there will be another public consultation round.
November 2021: The Spanish government approved a Royal Decree (‘Real Decreto Legislativo’) transposing the CDSM directive. The Parliament has 30 days to reject or approve it.
Intellectual Property Law after the DSM implementation: https://www.boe.es/buscar/act.php?id=BOE-A-1996-8930
Spain implementation structure