According to Spain’s National Police, the arrests have been carried out in at least 12 Spanish cities.
All of the accused had access to footage of young girls under the age of 13 through Peer to Peer file sharing.
Two men are thought to have filmed the majority of the footage after installing hidden cameras in women’s toilets.
One device was placed in a leisure centre and another one in a physiotherapy practice by the medical professional in charge.
Police are currently investigating the file sharing network to determine if there are any other suspects involved.
Ten of the men already arrested were also regular users of international paedophile-themed chatrooms, online daily Canarias 7 reported.