On 4 April 2025, the Spanish data‑protection authority AEPD published official guidance against unsolicited advertising. It clarifies that Lista Robinson is Spain’s statutory public opt‑out database for advertising. The list is managed by Adigital (Spanish Digital Economy Association) and endorsed under AEPD supervision. Regulations oblige enterprises to validate mobile numbers against this filtering database via API or monthly bulk‑file checks prior to sending marketing‑purpose A2P SMS and marketing outbound voice calls.
Effectiveness rule for registrations: a user’s entry becomes valid starting the second month after registration. Companies must keep complete logs of every filtering check for AEPD compliance audits. Starting in 2025, AEPD also recognises the supplementary StopPublicidad opt‑out list as valid supporting compliance evidence.
This filtering obligation applies exclusively to commercial marketing messages. Transactional A2P traffic including OTP codes, billing notices and logistics alerts is exempt from database checks. Beyond black‑list screening, the guidance reaffirms that marketing communications need explicit, active user consent, and SMS / voice calls must offer simple, cost‑free opt‑out mechanisms. Non‑compliance with filtering duties may result in penalties under the GDPR and Spain’s LOPDGDD data‑protection legislation.
