COREDO > Financial Licence in Spain

Financial Licence in Spain

Spain is one of Europe’s leading fintech jurisdictions, offering transparent regulation, a well-developed financial infrastructure, and access to the EU single market. Spanish financial licences allow companies to provide payment, investment, and other regulated services throughout the EEA under the passporting regime.

Since 2016, COREDO has been assisting clients with obtaining financial licences in Spain, providing full support — from selecting the most suitable licence and preparing documentation to liaising with the regulator and securing authorisation.

Get a Consultation

Cost of the service
from 80 000 EUR

Regulatory Framework

Spain’s financial sector is regulated by three key authorities.

Banco de España — the Central Bank of Spain — is the primary regulator of payment institutions (PI) and electronic money institutions (EMI). It is Banco de España that issues licences, maintains registers of supervised organizations, and carries out prudential supervision.

CNMV (Comisión Nacional del Mercado de Valores — National Securities Market Commission) supervises investment companies (investment brokers, asset managers, forex brokers) operating in accordance with MiFID II (Directive 2014/65/EU).

SEPBLAC (Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias) — a specialized AML/CFT authority at Banco de España. SEPBLAC supervises compliance with anti-money laundering and counter-terrorist financing requirements by all supervised financial organizations.

The legal framework is based on the following acts. At EU level: PSD2 Directive (EU) 2015/2366 on payment services, EMD2 Directive 2009/110/EC on electronic money institutions, MiFID II Directive 2014/65/EU on investment firms, CRD IV Directive 2013/36/EU on banking. At national level: Real Decreto-ley 19/2018 of 23 November 2018 (implementation of PSD2 into Spanish law) and Ley 21/2011 on electronic money institutions.

Types of Financial Licences in Spain

Licence Type	Regulator	Legal Basis	Min. Regulatory Capital	Review Period
EMI — electronic money institution	Banco de España	EMD2 (2009/110/EC)	EUR 350,000	10–18 months
PI — full range of payment services	Banco de España	PSD2 (2015/2366), art. 7(c)	EUR 125,000	10–18 months
PI — payment initiation	Banco de España	PSD2 (2015/2366), art. 7(b)	EUR 50,000	10–18 months
PI — money remittance	Banco de España	PSD2 (2015/2366), art. 7(a)	EUR 20,000	10–18 months
Investment company (MiFID II)	CNMV	MiFID II (2014/65/EU)	from EUR 50,000	12–18 months
Banking licence	Banco de España	CRD IV (2013/36/EU)	EUR 5,000,000	18–24 months

Important: the regulatory capital amounts listed in the table are set by European directives and are minimum mandatory requirements of the regulator. The cost of COREDO’s services for licence support is listed in the “Service Pricing” section below.

Advantages of the Jurisdiction

Passport regime in the EEA.

EMI and PI licensed in Spain have the right to provide services in all 30 European Economic Area states under the notification procedure without obtaining a separate licence in each country. This significantly reduces the regulatory burden for companies with international reach.

High licensing pace.

Banco de España demonstrates one of the highest rates of issuing fintech licences in Europe, outpacing the FCA (United Kingdom) and regulators in Lithuania and Ireland. The regulator actively engages with applicants and has established clear standards for processing applications.

No state fee.

No state fee is charged for reviewing an application for a financial licence in Spain, which reduces initial costs.

Perpetual licence validity.

PI and EMI licences issued by Banco de España are valid indefinitely and do not require periodic renewal.

Fiat and electronic money.

A holder of a Spanish financial licence has the right to work with both fiat and electronic money, which expands the range of available financial products.

Developed infrastructure.

Spain has extensive banking and fintech infrastructure, a strong labour market in compliance and IT, and relatively low operating costs compared to Western European counterparts.

Contact us

General Requirements for Obtaining a Financial Licence

Banco de España and CNMV impose the following requirements on applicants.

Organizational and legal.

The company must be registered in Spain. A physical office in the country is mandatory. At least one director must be a Spanish resident.

Management requirements.

Members of governing bodies must have confirmed experience in the financial sector and meet the fit & proper criteria. Any changes in the composition of qualified participants or management require prior coordination with Banco de España.

Capital and finance.

The company must maintain regulatory capital in accordance with the requirements of the applicable directive (see table above). For PI — the presence of a separate account for storing client funds (safeguarding account) in accordance with PSD2.

AML/CFT.

Development and implementation of anti-money laundering and counter-terrorist financing policies, KYC/KYB procedures, a transaction monitoring programme. SEPBLAC verifies the readiness of AML infrastructure as part of the licensing procedure.

IT and operational security.

A documented IT architecture, ensuring enhanced client authentication (SCA) in accordance with PSD2 and Regulation (EU) 2018/389 (RTS on SCA).

Business plan.

A detailed business plan with financial forecasts for three years, description of products and distribution channels, risk analysis.

Service Pricing

Service	Cost	Source
AEMI licence (PSP/EMI) in Spain	from EUR 80,000 + VAT	Quote

The cost includes a comprehensive package of services: legal analysis and selection of licence type, preparation of corporate structure, development of a regulatory package of documents, business plan and financial forecasts, support in interaction with Banco de España, assistance in responding to regulator requests.

Payment Terms

Work on a financial licensing project in Spain is structured as follows:

First instalment:

EUR 22,000 advance payment — project start, preliminary analysis, preparation of corporate documents.

Monthly payments:

EUR 6,000 per month throughout the entire period of preparation and application support.

The final settlement is determined individually based on the scope of work.

All prices are stated excluding VAT. Exact terms and final budget are agreed upon during the initial consultation.

Document Checklist

To obtain a financial licence in Spain, the following package of documents will be required.

Incorporation documents of the Spanish company (articles of association, certificate of registration, extract from the commercial register).

Documents on persons in the corporate structure: directors, participants, ultimate beneficial owners (UBO).

Detailed business plan: description of services, target markets, client acquisition channels.

Financial plan: P&L forecast, balance sheet statement, cash flow forecast for 3 years.

Description of IT infrastructure and security systems applied.

AML/CFT policy and KYC/KYB procedures.

Internal regulations: risk management, internal control, compliance function.

Documents confirming the presence of a physical office in Spain.

Documents confirming the qualification and experience of directors (CV, letters of recommendation, diplomas).

Certificates of absence of criminal record for directors and UBO.

Description of the client fund protection scheme (safeguarding).

Client complaint review procedure.

Fraud prevention programme.

Operational continuity documentation (BCP/DRP).

Procedure for Obtaining a Financial Licence in Spain

The licensing process includes four main stages and typically takes 10 to 18 months.

Preparation and structuring (1–2 months).

Legal analysis of the suitable licence type based on the client’s business model. Registration of a Spanish company or adaptation of an existing structure. Selection of directors meeting the fit & proper criteria. Preparation of the business plan concept and IT system architecture.

01

Development of regulatory package (2–4 months).

Preparation of a complete set of documentation in accordance with Banco de España requirements: business plan, financial forecasts, AML/KYC policies, IT documentation, description of risk management and internal control systems.

02

Application submission and regulator interaction (6–12 months).

Submission of an application through the Banco de España electronic register. Official review period — 3 months from receipt of a complete document package, however in practice the regulator typically sends several rounds of clarification requests. The COREDO team prepares responses to each request and coordinates the interaction.

03

Obtaining licence and launch (1–2 months).

Receipt of an official authorization decision. Registration in the Banco de España register. Activation of passport in other EEA countries if necessary. Assistance in opening correspondent accounts and safeguarding account for client funds.

04

Our Experts

COREDO has been operating since 2016 and has guided licensing in dozens of jurisdictions. We provide a comprehensive approach: from structure selection to obtaining regulator authorization and subsequent regulatory support.

Pavel Kos

Head of Legal at COREDO. Has been with the company since June 2017, leading the legal team since July 2020. Specializes in financial licensing in EU jurisdictions, structuring regulated companies, and supporting regulator interaction.

Basang Ungunov

Lawyer at COREDO. Has been with the company since June 2022. Specializes in preparing regulatory documentation, legal opinions, and supporting licensing processes.

Frequently Asked Questions

Which regulator issues financial licences in Spain?

The primary regulator of payment institutions and electronic money institutions is Banco de España (Central Bank of Spain). Investment companies (brokers, asset managers) obtain a licence from CNMV (National Securities Market Commission). AML supervision is carried out by SEPBLAC at Banco de España.

How long does it take to obtain an EMI or PI licence in Spain?

On average 10–18 months from the start of document preparation. The official review period by the regulator is 3 months from receipt of a complete package, however in practice Banco de España typically sends several rounds of clarification requests. The time to prepare documents before submission is usually 3–6 months.

Is a physical office in Spain required to obtain a licence?

Yes, having a physical office in Spain is a mandatory requirement of Banco de España. In addition, at least one company director must be a Spanish resident.

What is the minimum capital required for an EMI licence in Spain?

The minimum regulatory capital for a full-fledged electronic money institution (EMI) is EUR 350,000 in accordance with EMD2 Directive (2009/110/EC, art. 4). For payment institutions (PI), the minimum capital varies from EUR 20,000 to EUR 125,000 depending on the type of services provided.

Can I operate in other EU countries with a Spanish licence?

Yes. Full EMI and PI authorized by Banco de España benefit from passport rights in all 30 EEA states in accordance with article 28 of PSD2 and EMD2 Directive. To start operations in another EEA country, it is sufficient to send a notification to Banco de España, which in turn notifies the regulator of the host country.

Is a state fee charged for obtaining a licence in Spain?

No. In Spain, no state fee is charged for reviewing an application for a financial licence. The licence is issued for an indefinite period and does not require periodic renewal.

What is SEPBLAC and what is its role?

SEPBLAC (Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales) — an executive authority at Banco de España carrying out financial intelligence and AML supervision functions. SEPBLAC verifies applicants’ compliance with AML/CFT requirements as part of the licensing procedure and carries out ongoing supervision after licence issuance.

What is the difference between an EMI and PI licence?

An EMI (Electronic Money Institution) has the right to issue electronic money and provide payment services related to it. A PI (Payment Institution) provides payment services but does not have the right to issue electronic money. EMI has a higher minimum capital requirement (EUR 350,000 compared to EUR 20,000–125,000 for PI), but EMI has broader opportunities for building fintech products.

Ready to Begin?

Get a free consultation on financial licensing in Spain. Our experts will help determine the optimal licence type, assess timelines and budget, and develop a project roadmap.