With obstacles at various levels of government, multi-level settings provide complex challenges for the implementation of gender mainstreaming. Policy transfer appears to hold some explanatory potential in these sorts of contexts; scholarship however, still tends to focus on single sources of influence – either European or domestic – and potentially misses the broader picture. This article revisits the classic question of who learns what from whom by addressing the implementation of gender mainstreaming in research policies in the Spanish regions through the lens of policy transfer. Measures to tackle gender inequality in science have been developed at the EU, state and regional levels, thus enabling the three regions studied here – Galicia, the Basque Country and the Balearic Islands – to ‘borrow’ good practices from different layers of government. This article suggests that more nuanced frameworks, recognizing that multi-level settings are potential sites for complex lesson-drawing processes, are likely to offer greater explanatory depth.