Crypto License in
Spain 2025
Spain, as a leading economy within the Eurozone, fulfils a regulatory function within the cryptocurrency market. The Bank of Spain (Banco de España) and the National Securities Market Commission (CNMV) are responsible for the establishment and enforcement of the legal framework governing cryptocurrency services, as outlined in the new CASP (Crypto-Asset Service Provider) licence.
In accordance with a forward-looking approach, Spain’s legislative framework not only encourages the development of technology, but also introduces strict regulatory measures to ensure the protection of the financial system from potential threats, including fraud, money laundering and the manipulation of financial markets.
At Legalaes, we provide comprehensive legal and compliance support for obtaining a CASP licence in Spain. Our services include company registration, preparation of regulatory documentation, development of a business plan, compliance policies, representation before the authorities and assistance in opening a bank account. We ensure a smooth licensing process and help your cryptocurrency business operate in full compliance with MiCA regulations.
Regulations for Crypto license in Spain
In order to obtain a licence as a Crypto-Asset Service Provider (CASP) in Spain, a local company offering cryptocurrency services must be established under the Markets in Cryptoassets Regulation (MiCA). In order to meet the regulatory requirements for a CASP licence, a company must include a set minimum amount of share capital, the amount of EUR 50,000 to EUR 150,000, depending on the services provided (CNMV). Prior to submitting an application for a CASP licence with the National Securities Market Commission (CNMV) and the Bank of Spain, in accordance with prevailing regulations, companies are obligated to increase their capital.
One of the key requirements for companies is to appoint a director who has either EU or Spanish nationality.
All cryptocurrency companies must comply with strict anti-money laundering (AML) and Know Your Customer (KYC) requirements under Spanish national law and EU MiCA regulations.These measures ensure company transparency and consumer protection, while regulators retain the right to access corporate and financial data for supervisory purposes.
The responsibility for the supervision of CASP-licensed companies in Spain is divided between the CNMV and the Bank of Spain, who are charged with the regulation and compliance of these entities. In order to obtain and maintain their CASP license, applicants are required to meet governance, capital and operational requirements.
Existing Virtual Asset Service Provider (VASP)-licensed companies in Spain are granted a transition period in which to comply with the recently implemented MiCA regulations. This transition period is scheduled to conclude by December 2025, necessitating all VASPs to upgrade to the CASP license by that date.
More details from: https://www.cnmv.es/Portal/home?lang=en
Types of CASP licensing in Spain
The introduction of the Markets in Cryptoassets Regulation (MiCA) has prompted Spain to transition to a novel licensing system for Crypto Asset Service Providers (CASPs). The National Securities Market Commission (CNMV) and the Bank of Spain have been designated as the authorities responsible for the issuance of CASP licences. Companies that have previously obtained Virtual Asset Service Provider (VASP) licences from the Spanish Financial Intelligence Unit (SEPBLAC) will be permitted to continue benefiting from their existing status, while adapting to the new MiCA regulations.
Before the introduction of the CASP (Crypto-Asset Service Provider) licence in Spain under MiCA, there was no specific cryptocurrency licence system in the jurisdiction. Rather, cryptocurrency service providers, such as crypto exchanges and wallet providers, were required to register with the Spanish Financial Intelligence Unit (SEPBLAC) to ensure compliance with anti-money laundering (AML) and counter-terrorist financing (CFT) regulations.
The regulatory framework was principally focused on the monitoring of such enterprises with regard to their compliance with AML/CFT standards. However, a separate licensing structure for cryptocurrency exchanges or wallets was not established, in contrast to the licensing structures common in other countries. In order to operate legally within the country, companies were required to adhere to Spain’s broader financial legislation.
Following the introduction of MiCA, Spain is moving towards a CASP licensing regime, providing more specific guidelines and requirements for cryptocurrency companies operating within the EU.
MiCA CASP License Classes
Under MiCA, crypto businesses must now obtain a CASP license under one of three classifications, depending on the scope of services provided:
| Description of services | Share Capital | |
|---|---|---|
| Class 1 – Limited CASP |
| 50,000 EUR |
| Class 2 – Standard CASP |
| 125,000 EUR |
| Class 3 – Full CASP |
| 150,000 EUR |
Legalaes assists businesses in both acquiring existing licensed entities and navigating the transition to MiCA-compliant CASP licenses, ensuring a seamless regulatory approval process in Spain.
Overview of requirements to obtain CASP License in Spain
- Provide desired company names for registration
- Submit copies of passport and proof of address for future shareholders and directors
- Provide a non-criminal record for shareholders and directors
- Appoint a director with Spain or EU citizenship
- Company must have AML/KYC policies
- Registered share capital of 3,000 EUR (at company registration)
- Fulfillment of structured application
Additional requirements:
- Develop internal policies in line with MiCA and EU requirements, including anti-money laundering, risk management, cybersecurity and other compliance standards.
- Submit a business plan outlining operations and financial projections
- Conduct preliminary meeting with the National Securities Market Commission (CNMV) or the Bank of Spain (advisable)
- Perform Fit and Proper check for key management members
- Obligation to store client data and report suspicious transactions (red flags)
- Additional capital must be deposited before the CASP license application, based on the regulatory class of the license
- Corporate bank account recommended, but not required for initial registration
Estimated time frames
Gathering documents
1-2 weeks
Company formation
up to 2 weeks
Documents preparation
1-2 weeks
License Issuance*
3 months
*The timeline may vary based on the completeness of documentation and the responsiveness of the Bank of Spain.
Legal services for obtaining CASP License in Spain
Basic Package
18000 EUR
Ideal for startups and businesses looking to register a company and initiate the CASP licensing process in Spain.
Includes:
- Company formation and legal entity registration
- Provision of a legal address for 1 year
- Standard AML/KYC policy framework
- CASP license application submission to the National Securities Market Commission (CNMV) or the Bank of Spain
- Corporate documents preparation
- Regulatory representation and communication with authorities
- Legal support throughout the process
- Guidelines on documentation
- Due-Diligence
Advanced Compliance Package
Price on Request
Designed for businesses requiring comprehensive compliance documentation, legal structuring, and regulatory preparation for a CASP license under MiCA.
Includes all services from the Basic Package, plus:
- Developing the necessary internal policies (AML/KYC, risk management, cybersecurity, customer protection, etc.) in accordance with MiCA requirements
- Preparation of a business plan taking into account the company’s operations and licensing requirements
Advise on regulatory strategy and MiCA compliance recommendations
Preparation of key personnel for compliance assessment - Legal opinion from a qualified lawyer on regulatory and operational compliance issues
- Pre-meeting with the CNMV or Bank of Spain – preparation and representation for meetings with the regulators on your behalf
- Assistance in increasing share capital prior to applying for a CASP licence to comply with MiCA requirements
- Provision of local staff to meet operational and regulatory obligation.
These services are designed to guide your business through the process of obtaining a CASP licence in Spain, ensuring compliance with MiCA requirements and specific Spanish regulations.
CAN ALSO ADD ANY OF:
- Accounting services and tax compliance
- Corporate bank account assistance (current and safeguard accounts)
- Apostilled corporate documents
- Legal opinion for regulatory compliance
- Custom legal framework for launching crypto projects
- AML/CFT training and governance structuring
Ready-Made CASP Solution
18890 EUR
A fast-track solution for businesses needing an operational company with a pre-existing crypto license.
Includes:
- Pre-registered company with an active license
- Legal address for 1 year
- No debts or liabilities – clean company
- Registered share capital of 5,000 EUR (additional capital must be deposited before CASP application)
- Corporate documents transfer and regulatory compliance review
- Assistance with ownership transfer and regulatory filings
Eriks Fijalovs
Head of Blockchain and Crypto
Requirements for CASP Licensing in Spain
In order to obtain a Crypto-Asset Service Provider (CASP) licence in Spain under the Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114), companies are required to meet specific legal, regulatory and operational requirements.
The following documents are required:
- Power of Attorney (PoA): A public document notarised by a public notary, allowing Legalaes to act on behalf of a company or individual for company incorporation and CASP license application.
- AML/KYC/CFT Policy: A set of compliance documents outlining procedures for Anti-Money Laundering (AML), Know Your Customer (KYC), and Countering the Financing of Terrorism (CFT). It ensures client verification, risk evaluation, and suspicious activity reporting.
- Application Form: A structured document submitted to the National Securities Market Commission (CNMV) or Bank of Spain, detailing the company’s business model, primary and secondary activities, and operational scope.
- Memorandum and Articles of Association (MAA): A legal document created during company incorporation, serving as the company’s charter and defining its operational structure.
- Business Plan: It is a comprehensive plan that outlines the company’s business model, revenue streams, risk management approach, and operational structure, and is required for the CASP license application.
- Internal Policies and Procedures: Development of regulatory documents in compliance with MiCA, including AML/KYC, risk management, cybersecurity, client safeguarding, and governance policies.
- Key Personnel Documentation: Fit and Proper assessments, director credentials, and compliance officer qualifications, demonstrating competency and regulatory adherence.
Business Premises Requirements
- Physical office premises in Spain are not required at the moment for CASP licensing.
- A legal address in Spain is sufficient for company registration and regulatory compliance.
- Some payment gateways or digital banks may require a virtual office with a lease agreement, which can be arranged by Legalaes upon request.
Share Capital and Government Fees
- Minimum Share Capital:
- The minimum share capital for an LLC (Sociedad Limitada – SL) in Spain is 3,000 EUR.
- For larger entities (Sociedad Anónima – SA), the minimum share capital is 60,000 EUR.
- Under MiCA, additional capital may be required before applying for a CASP license, depending on the license class.
- Government Fees:
- LLC Incorporation Fee (SL): Typically around 200-300 EUR, depending on specific administrative costs.
- JSC Incorporation Fee (SA): Around 1,000 EUR for registration, depending on the complexity of the corporate structure.
Personnel Requirements
- AML Compliance Officer:
- The presence of an AML officer is mandatory for CASP licensing.
- The AML officer can be from any EU country; Spanish residency is not required.
- However, for effective communication with Slovak regulators, appointing a local AML officer is strongly recommended.
- Legalaes can provide a local AML officer upon request, ensuring compliance and smoother interactions with authorities.
- Director:
- Must be a Spanish or EU citizen.
- If the director is an EU resident, documents must be translated and certified in Spanish.
- Depending on the business model and operational complexity, the regulator may require additional risk management,or operational personnel to be part of the company.
- Legalaes is ready to handle staffing solutions, ensuring that all regulatory requirements are met efficiently.
Roadmap for Obtaining a CASP License in Spain
Any financial operation in Spain is typically subject to obtaining a trade license and undergoing AML supervision as per the applicable laws, governed by the Financial Intelligence Unit (SEPBLAC).
The SEPBLAC controls compliance with AML/CFT obligations for all obligated entities, as outlined in the relevant Spanish regulations.
Spanish legislation allows foreign entities to conduct business activities in Spain under the same conditions as Spanish entities.
Eriks Fijalovs
Head of Blockchain and Crypto
Documents Collection & Company Formation
The process begins with the collection of all required documentation, including a valid passport, proof of address (e.g. utility bill or bank statement) and a detailed description of the business model. Clients provide three preferred company names, which are verified and reserved through the Registro Mercantil ( Commercial Register). A Power of Attorney (PoA) is then drafted and notarised, authorising our team to process the company incorporation remotely on behalf of the client. The company is registered as either a Sociedad Limitada (SL) or Sociedad Anónima (SA) and the company details are officially entered into the Registro Mercantil (Commercial Register).
Business Plan & Preliminary Regulatory Meeting
A full business plan is reviewed, analyzed, or drafted to comply with MiCA regulatory requirements. Legalaes provides expert comments and suggests necessary improvements to ensure compliance and viability. A preliminary meeting with the National Securities Market Commission (CNMV) or the Bank of Spain is highly recommended. During this meeting, the proposed business model will be presented and key aspects such as governance, AML/CFT procedures, prudential safeguards and capital requirements based on the chosen CASP licence class will be discussed.
CASP License Application & Compliance Documentation in Spain
After approval of the business plan, Legalaes assists in increasing the company’s share capital according to the selected CASP license category, in line with MiCA requirements. AML/CFT and KYC policies are tailored to the company’s cryptocurrency operations and specific risk profile, ensuring full compliance with Spanish regulations. A Spanish or EU-based director is appointed to align the company with local governance standards. Once all the documentation has been prepared, the CASP licence application is submitted to the National Securities Market Commission (CNMV) and SEPBLAC. Legalaes manages all communication with the Spanish authorities and handles any requests for follow-up or clarification throughout the review process.
Banking & Corporate Account Setup (Optional, Recommended for Operations in Spain)
The opening of a corporate account, although optional, is highly recommended to support future operations. Legalaes assists in the collection and preparation of the necessary legal and corporate documentation for submission to Electronic Money Institutions (EMIs) or banks in Spain. Suitable financial service providers are evaluated based on the company’s business model and regulatory obligations. Legalaes negotiates with the selected institution and guides the client through the onboarding process. If necessary, a secured client fund account is also opened to ensure compliance with MiCA regulations.
Regulatory Approval & Post-Licensing Compliance
Once the CASP licence has been obtained, Legalaes continues to support the client through the post-licensing obligations. This includes maintaining regular communication with the National Securities Market Commission (CNMV) and the Financial Intelligence Unit (SEPBLAC), assisting with audits and ensuring timely responses to any regulatory enquiries. Internal policies and governance structures are updated as necessary to reflect ongoing regulatory developments and operational changes. Legalaes ensures long-term compliance with MiCA by monitoring ongoing obligations and providing tailored support for sustainable operations in Spain.
Timeframe to obtain a CASP licence in Spain
1. Business name verification
Estimated Time Frame: 1-3 Days
2. Company formation
Estimated Time Frame: up to 2 weeks
3. Documents review and analysis
Estimated Time Frame: 1-3 weeks
4. Development of required policies and compliance documents
Estimated Time Frame: 3-4 weeks (if applicable)
5. Increase of required share capital
Estimated Time Frame: 2 weeks (if applicable)
6. Filling out the structured application and submission to the National Securities Market Commission or Bank of Spain
Estimated Time Frame: 1 week
7. Ongoing communication and license approval process
Estimated Time Frame: up to 3-5 months
Advantages of the CASP License in Spain
01
Fully Remote Process
The entire company registration and CASP licensing process in Spain can be completed remotely via a Power of Attorney (PoA), eliminating the need for physical presence in Spain.
02
Set-Up Timeframes
Spain offers a streamlined licensing process, allowing companies to set up efficiently. A ready-made licensed company can be transferred within one to two months, enabling a quick market entry.
03
Moderate Maintenance Fees
Spain offers moderate regulatory and operational costs, making it a cost-effective jurisdiction for maintaining a CASP license compared to other EU countries.
04
Flexible Staffing and Office Requirements
There is no requirement for a physical office in Spain. A legal address is sufficient for company registration and licensing. AML officers can be appointed from any EU country, offering flexibility in structuring the company’s personnel.
05
Broad Scope of Crypto Services
The CASP license in Spain allows businesses to engage in a wide range of crypto services, including exchange, custody, portfolio management, and advisory services, providing versatility and scalability for businesses.
06
No Cap on the Number of Licenses Issued
Spain has no limit on the number of CASP licenses that can be granted, ensuring open market access without regulatory restrictions on the number of approved businesses.
07
Cooperative Regulatory Environment
The National Securities Market Commission (CNMV) and SEPBLAC provide a structured yet business-friendly approach to CASP licensing, ensuring an efficient and transparent application process.
Links for legislation related to Crypto business in Spain
The Bank of Spain oversees the regulation of financial institutions in Spain, including those involved in cryptocurrency operations. It ensures compliance with national and EU financial regulations, focusing on stability and security within the financial system.
The CNMV is responsible for supervising and inspecting Spain’s securities markets, including cryptocurrency-related activities. It ensures transparency and proper market functioning, safeguarding investor interests.
SEPBLAC is Spain’s Financial Intelligence Unit responsible for preventing money laundering and terrorist financing. It monitors financial transactions and enforces AML regulations for businesses, including those in the cryptocurrency sector.
The Spanish Commercial Registry is essential for business registration and compliance. All companies, including crypto businesses, must be registered here to operate legally in Spain. The registry provides transparency and legal recognition of business activities.
The Markets in Crypto-Assets (MiCA) Regulation is an EU-wide legal framework designed to regulate the cryptocurrency market. It sets out clear rules for crypto asset issuers and service providers, aiming to enhance consumer protection and ensure market integrity across the European Union, including Spain.
VI. Agencia Tributaria
Spanish Tax Agency, is responsible for enforcing the tax laws and ensuring compliance with the Spanish tax system. The agency also provides guidelines and resources for businesses to understand their tax obligations, particularly in the context of emerging financial sectors like cryptocurrency.
European Securities and Markets Authority (ESMA) – Markets in Crypto-Assets Regulation (MiCA)
Provides guidance on MiCA, the regulation governing crypto-asset markets across the EU.
FAQ about Crypto license in Spain
1. What is a VASP license in Spain?
A VASP license allows companies to engage in virtual asset activities like exchanging digital assets or safeguarding them for clients. While the license covers a range of services, it doesn't strictly categorize them. The main focus is on compliance with anti-money laundering (AML) and counter-terrorist financing (CFT) regulations, ensuring these activities adhere to stringent legal standards
2. How do i apply for a VASP license in Spain?
To apply for a VASP license, you must submit an application to the Bank of Spain through their Electronic Registry. The application process involves providing detailed documentation on your business model, compliance procedures, and security measures.
3. What are the key requirements for obtaining a VASP license in Spain?
Key requirements include incorporating your business in Spain, meeting any minimum share capital requirements, establishing comprehensive AML/KYC procedures, and appointing a local compliance officer. Additionally, a physical office or at least a legal address within Spain may be required, depending on the nature and scope of your business operations.
4. What are the benefits of having a Spain VASP License?
The benefits include regulatory compliance, enhanced credibility, access to banking services, and increased trust from investors and customers, which can help expand your business within Spain and across the European Union.
5. How long does it take to obtain a VASP license in Spain?
6. What is a CASP lincese in Spain?
CASP stands for Crypto Asset Service Provider, a license that will be introduced in Spain under the EU's MiCA regulations. It will replace the current VASP (Virtual Asset Service Provider) license, aligning Spain with the broader EU regulatory framework for crypto assets. The transition to this new type of licence will take place in December 2024.
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