Spain
Overview
Spain splits MiCA supervision. The Comisión Nacional del Mercado de Valores (CNMV) authorises and supervises CASPs; the Banco de España supervises issuers of asset-referenced and e-money tokens. SEPBLAC, the financial intelligence unit, retains AML/CFT supervision. Law 6/2023 on securities markets designates the CNMV as the CASP competent authority.
Spain used the full EU transition. The window closed on 1 July 2026; providers without CNMV authorisation, or a valid passport from another Member State, had to cease. New entrants apply directly for MiCA authorisation.
Regulatory framework
MiCA (Regulation (EU) 2023/1114) is directly applicable. The CNMV is the CASP authorisation and conduct authority; the Banco de España covers the Title III/IV issuer regimes; SEPBLAC supervises AML/CFT under Law 10/2010. Crypto-assets that are financial instruments remain in the MiFID II perimeter.
Certain financial entities can use the Article 60 notification route. Third-country firms can use the Article 60 own-initiative route only where the client approaches them; reverse solicitation is narrow. A Spanish authorisation passports across the EEA after the Article 62 notification.
Licensing & authorisation
Route and clock. Apply to the CNMV (MiCA Arts 62–63). The authority acknowledges within 5 working days, assesses completeness within 25 working days and decides within 40 working days of a complete file; the clock stops for information requests. The CNMV publishes MiCA application guidance and common-obligations material; the statutory clock is not an end-to-end promise.
Charges. CNMV fees are set under Spain’s public fee framework. At the 24 October 2026 check we found no standalone flat CASP application tariff in the published English materials; confirm the current fee with the CNMV before filing.
Own funds. MiCA Art 67 and Annex IV set the minimum at €50,000 (Class 1), €125,000 (Class 2) or €150,000 (Class 3), plus one quarter of the previous year’s fixed overheads, held continuously. The class follows the services authorised.
Substance and passport. MiCA Art 59 requires the registered office and head office in Spain. Plan for a Spanish entity (commonly an SL or SA), Spanish-resident management, a local AML officer and outsourcing/ICT arrangements that meet CNMV and DORA expectations. Once authorised, notify under Art 62 to passport into the EEA.
AML & Travel Rule
The EU Transfer of Funds Regulation (TFR, (EU) 2023/1113) has applied since 30 December 2024. CASP-to-CASP transfers must carry originator and beneficiary information from the first euro; transfers to or from self-hosted wallets above €1,000 require verification of the counterparty.
SEPBLAC is Spain’s financial intelligence unit and AML/CFT supervisor; the CNMV supervises conduct and prudential requirements. DORA has applied since 17 January 2025, and the EU AML Regulation (AMLR) applies from 10 July 2027.
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