The Spanish actress is claimed by the Daily Mail to be in talks to appear in the sequel to Skyfall, currently just known as Bond 24.
And if she lands the role, she is likely to become the oldest Bond girl in the history of the franchise - a distinction currently held by Honour Blackman, who was 39 when she starred in Goldfinger.
Penelope will be 40 next April.
A source told the paper: "The producers have tried to get Penelope before, but she has never been available because of other commitments. The discussions have been going on for some time and they are working out the contract details now.
"She got back into shape fast after the first baby and will no doubt regain her figure quickly this time. She'll be a great Bond girl.
"Bond girls are always brainy as well as sexy, and that's totally Penelope."
Her hubby Javier Bardem played the villain in Skyfall.