Short answer: Spain's new housing decree-law closely describes the kind of buyer Indemo's model relies on: entities that buy unpaid mortgage loans far below the value of the property. Indemo's CEO has answered in a letter to the community, rating the overall impact on the product as low. We checked it against the official text: his argument on the 70% purchase limit is consistent with the BOE wording, but the letter does not say whether Indemo's partners fall within the category hit by the uncompensated eviction suspension to 2030, and its figures cannot be verified independently. Our reading: manageable, but not yet proven.

Editorial analysis, not legal or investment advice. Based on the official text of Real Decreto-ley 29/2026, on Indemo's public pages as read on 12 October 2026, and on a letter from Indemo's CEO to its community (PDF dated 9 October 2026; we did not find it on Indemo's blog). Where we infer rather than quote, we say so.

What changed in Spain

  • 23 September 2026: an 87-year-old woman is evicted from her Madrid home after a steep rent rise; nationwide protests follow.
  • 29 September: the government approves two housing decree-laws (RDL 26/2026 and 27/2026).
  • 2 October: Congress rejects them (178–172 and 184–166). Pedro Sánchez then calls a snap general election for 29 November.
  • 6 October: the cabinet re-approves the package with changes as RDL 28/2026 (rental contracts) and RDL 29/2026 (social function of housing), published in the BOE on 7 October.
  • 8 October: RDL 29/2026 enters into force. With parliament dissolved, it needs validation by the Diputación Permanente (the Congress standing committee) within 30 days of adoption; the PNV has said it will back RDL 29 and reject RDL 28. We have not seen the vote result.
  • 9 October: Indemo's CEO and co-founder addresses the community in a letter (the PDF we reviewed is dated 9 October) rating the overall impact on the product as low.

These are decree-laws, not ordinary statutes: they apply immediately but remain provisional until validated, and the parliament elected on 29 November could amend or repeal them.

What RDL 29/2026 says about buyers of unpaid mortgages

The final text drops the phrase “vulture funds” and defines its target by activity: any entity “dedicated to acquiring properties or portfolios of unpaid mortgage loans for a price clearly below their appraisal value”, plus large property holders. Three provisions matter for NPL investors:

  • Article 1 – purchase limit until 31 December 2030. Those entities may not acquire a home for less than 70% of its market value, set by an independent appraiser registered with the Bank of Spain. Exceptions include affordable or social housing and buyers that adhere to a Código de Buenas Prácticas (code of good practice) that the cabinet has yet to approve. Acquisitions through court or mortgage enforcement are exempt only for entities that prove adherence to that code, and the BOE text says the code-based exceptions do not apply until the code is in force. Press summaries of the first draft described enforcement awards as simply exempt; the published text is stricter. Transfers already executed in a public deed before 8 October are outside Article 1.
  • Article 2.1 – eviction suspension until 31 December 2030. Where the claimant is such an entity (acting to maximise returns through rents, resale prices or non-residential use), the court must suspend the case if the defendant is vulnerable and has no alternative housing, even after judgment as long as the eviction has not been carried out. These claimants get no compensation; other landlords receive capped compensation and a maximum three-year suspension. We see no grandfathering for Article 2 – on our reading, it can reach cases already in court.
  • Article 5 – more paperwork at the start. A mortgage foreclosure claim must now state whether the property is the debtor's main home and whether the claimant is a large holder, with a Land Registry certificate if it says it is not.

What the text does not say: it does not ban buying a loan as such – the operative limit refers to acquiring a home – and it gives no numeric test for “clearly below” appraisal value. It does define the consideration for that limit broadly, counting assumed debts and other benefits, not only cash paid. Whether a servicer's vehicle holding a claim on a home falls into the targeted category will be decided case by case. The decree also partially transposes EU Directive 2021/2167 on credit servicers and credit purchasers.

Why Indemo is in the frame

Indemo sells Notes linked to “Discounted Debts”: Spanish mortgage claims bought by servicing partners at a deep discount. Its current listings show how deep. Asset P117, a house in Guillena (Sevilla) at “Step 17, auction assignment”, has a claim of €111,928, an appraised value of €133,877 and a purchase price of €64,850 – a price-to-value of 48.4%. That is the debt's price against the property's value, and it is the kind of “clearly below appraisal value” purchase the decree uses to define its target category.

Indemo is open about how recoveries happen: out-of-court settlements (a house in Aznalcázar, sold with the debtor's help, about 15–18% a year), enforcement through to auction, possession and resale, and sales of claims to institutional NPL buyers (apartment A98 in Valencia, repaid that way on 12 February 2026). The platform reports a €31 million outstanding portfolio, €4.2 million repaid and 22 repaid assets (17 July 2026). The decree is not aimed at Indemo's investment-firm licence (Latvijas Banka, MiFID II); the exposure lies in recovery timing and exit pricing.

What Indemo's CEO says

  • Process and conclusion. In his letter, CEO and co-founder Sergejs Viskovskis says all five legal teams of Indemo's servicing partners took part in the analysis, from litigation lawyers who handle its cases in Spanish courts to large corporate legal teams, and that it covers the existing portfolio as well as new purchases. His conclusion is that the decrees do not undermine the fundamentals of the product and that their overall impact is low. He adds that the strategy does not depend on the election result and that a scenario in which the rules stay for several years was assessed too.
  • The 70% limit. Indemo buys mortgage debt (claim rights), not homes, and its legal assessment is that the limit applies to acquiring residential property, not to the price paid for debt. If a recovery ends with the creditor taking the property, the rule must be considered, but the relevant value is the whole transaction – debt applied, cash paid, liabilities assumed – not the original debt price or PTV; in many cases, he says, the outstanding debt is already close to or above the property's value.
  • Evictions. The suspension protects occupants who meet vulnerability criteria and have no alternative housing; it is not automatic for anyone who stops paying. Protection for vulnerable mortgage borrowers has existed since 2013 and already ran to 15 May 2028. A suspended eviction does not write the debt off: interest keeps accruing and recoverable costs are added, which he sees as an incentive for debtors to settle.
  • Screening before purchase. Only around 10% of the opportunities its partners review reach acquisition. Partners check whether the home is someone's only home, whether anyone lives there, who the occupants are, on what legal basis and what vulnerability risk exists; deals with an unfavourable combination are filtered out under the partners' social-responsibility policy.
  • After purchase. Partners favour individual solutions and out-of-court settlements; the purchase discount lets them offer compensation, relocation help or even pay for alternative accommodation. Taking ownership is one exit among several – agreement with the debtor, sale of the property as part of a settlement, third-party purchase at court auction, or sale of the debt on the secondary market – and the 70% limit does not apply to the sale price of the debt.
  • Delays and liquidity. Some cases may see delays, extra document requests or legal clarifications while courts adjust; the product model already includes a worst-case scenario with delays. The platform's secondary market is in its final stage of development and, once live, will let investors look for buyers before recovery ends. No launch date is given. The letter closes by saying market changes may also create new acquisition opportunities.

How the letter compares with the BOE text

  • Consistent – the 70% limit. Article 1 limits the acquisition of a home and defines the consideration as the sum of all amounts, assumed debts and other benefits. That fits the CEO's point that the original debt price or PTV is not the yardstick. How a discounted claim applied in a court award is valued remains untested.
  • Consistent – the earlier regime. RDL 1/2024 extended to 15 May 2028 the suspension of evictions from main homes of especially vulnerable households that were awarded in a foreclosure, as the letter says. RDL 29/2026 moves the end date to 31 December 2030 for the entities it targets and defines vulnerability by social-services report or Civil Procedure Act criteria, so for the cases it covers the end date moves out by about two and a half years. Whether the new vulnerability test is wider than the 2013 one is for lawyers to say.
  • Consistent – delays and paperwork. Article 5 adds filing requirements to every mortgage foreclosure claim, in line with the letter's warning about extra document requests.
  • Not addressed – the Article 2.1 category. The letter argues about scope (vulnerable occupants without alternative housing) and mitigation (screening, settlements), but does not say whether Indemo's partners fall within the Article 2.1 definition. If they do, a suspension can run to the end of 2030 with no compensation; the letter's answer is that screening and settlements keep such cases few, which we cannot verify.
  • Not addressed – exit buyers and the code. The CEO notes that the 70% limit does not apply to the sale price of the debt. The letter does not discuss whether institutional buyers will bid as before, or the Código de Buenas Prácticas.
  • Not verifiable – the company's own figures. The five legal teams, the roughly 10% acquisition rate and the “low” impact rating come from Indemo, which has an obvious interest in reassuring investors; we have no independent data. Listings such as P117 do not show occupancy or the result of the screening.

Where the pressure points remain

  • Timeline cushion. Indemo says its price limits assume recovery of up to five years with no alternative exit, with claims growing about 5% a year and collateral about 4%. A suspension to end-2030 is just over four years away – inside that window, but it would use up much of the cushion on an affected asset.
  • Exit buyers. Part of Indemo's repayments come from selling claims to institutional buyers, the group the decree describes. The 70% limit does not apply to the debt's sale price, but if those buyers bid lower or stay away because of uncompensated suspensions, the secondary-sale route gets slower or cheaper. This is our inference, not something the letter addresses.
  • The Código de Buenas Prácticas. If servicers can adhere to it, part of the restrictions may fall away. Whether Indemo's partners will, and on what terms, is unknown until the cabinet publishes the code.
  • Evidence. “Low impact” is an assessment, not a result. Dynamic Portfolio Revaluation, launched in July, and the planned Secondary Market will show whether recovery assumptions and prices move; investors should look for that.

What to watch next

  • Validation: if the Diputación Permanente does not validate RDL 29/2026 within 30 days, it lapses.
  • The 29 November election: the PP and Vox, which voted against the decrees, are pushing faster evictions of squatters; a new majority could amend or repeal RDL 29/2026, but the outcome is open.
  • The Código de Buenas Prácticas: its content decides how hard Articles 1 and 2 bite in practice.
  • First court rulings on what “clearly below appraisal value” means and on the purpose test in Article 2.1.
  • Indemo's follow-up – any further disclosure, the launch of its Secondary Market and any change to the return scenarios in its KID.

What to check in your own Indemo portfolio

  • For each Note: property type, occupancy, whether it is a main residence, legal stage, and purchase price versus appraised value. The CEO says partners screen occupancy and vulnerability before buying, but listings such as P117 do not show the result, so ask Indemo support.
  • Read the KID and asset documents, and ask Indemo support whether the claimant for that asset could fall under Articles 1–2.
  • Treat the 15.1% as a scenario (90% of the debt settled within 18 months), not a forecast, and the 21.6% weighted average as a platform-reported figure, not an IRR.
  • Size positions for a five-year horizon, and remember the €20,000 investor compensation scheme covers the platform failing to return assets, not weak recoveries.
  • Diversify across regions and property types.
  • Treat “low impact” as management's assessment, and look for evidence in repayments and revaluations over the coming quarters.

Our view

The CEO's letter is a substantive reply that engages with the text rather than the headlines, and on the 70% limit it is consistent with the BOE. It is weaker on Article 2.1, the provision that targets buyers of unpaid mortgage loans and gives them no compensation for an eviction suspension that can run to 2030. Spain's NPL stock is also small and shrinking (€68.66 billion, a 2.48% ratio at end-2025, per Drooms), and the decree itself cites court data showing foreclosure-related evictions down almost 70% in 2019–2025 versus 2013–2018, so the political pressure lands on the last step of the chain, where Indemo's recoveries end when a negotiated exit fails.

For investors the question is not platform solvency but asset-level timing and exit pricing. The company says the impact is low and its approach is to screen and settle; the evidence will be in repayments and revaluations. We have not changed Indemo's due-diligence score on the basis of a decree whose effect on recoveries is not yet measurable, and we will update this article after the validation vote, the election and any further Indemo disclosure.

Read our full Indemo review. P2PRadar may earn a commission when you register through links on this site; it does not influence our analysis (see the affiliate disclosure).