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 CASP Licensing in Spain
To operate as a Crypto-Asset Service Provider (CASP) in Spain, companies must obtain authorization under the Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114). Licensing and oversight are jointly managed by the National Securities Market Commission (CNMV) and the Bank of Spain, depending on the nature of services offered.
A Spanish-registered company is required to apply for a CASP license. The minimum share capital must align with MiCA thresholds—ranging from €50,000 to €150,000, based on the type of services provided. This capital must be fully paid before submitting the application to CNMV and the Bank of Spain.
The company must appoint a director who is a resident of the EU or a Spanish national. This individual must demonstrate relevant qualifications and experience to oversee crypto-asset operations in compliance with MiCA.
All licensed CASPs must implement strong AML/KYC/CFT procedures, as mandated by both Spanish national legislation and EU-level MiCA rules. These obligations support financial transparency, consumer protection, and risk management. Regulatory authorities retain full rights to access business records and monitor ongoing compliance.
The supervisory structure in Spain is split between the CNMV and the Bank of Spain. The CNMV is primarily responsible for investor-facing services such as custody and trading, while the Bank of Spain handles oversight of services related to payments and electronic money.
Existing companies already registered as Virtual Asset Service Providers (VASPs) in Spain benefit from a transitional period to adapt to MiCA. This period expires in December 2025, by which time all existing VASPs must upgrade their license to a MiCA-compliant CASP license.
More information available at the CNMV official website.
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 will be permitted to continue benefiting from their existing status, while adapting to the new MiCA regulations.
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
Timeframe to obtain a CASP licence in Spain
Business name verification
1-3 days
Company formation
up to 2 weeks
Documents review and analysis
1-3 weeks
Development of required policies and compliance documents
3-4 weeks
Increase of required share capital
2 weeks
Filling out the structured application and submission to the National Securities Market Commission or Bank of Spain
1 week
Ongoing communication and license approval process
up to 3-5 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
Initial Setup
18000 EUR
- Company registration in Spain
- Legal address provision for 1 year
- Standard AML/KYC policy (MiCA-aligned)
- Preparation and submission of CASP license application to CNMV or Bank of Spain
- Drafting of corporate documentation
- Regulatory communication and representation
- Due diligence and guidance on documentation
- Legal support throughout the process
This package covers the minimum legal and compliance requirements for starting the CASP licensing procedure in Spain.
Advanced Compliance Package
- Development of internal policy set (AML, risk management, cybersecurity, customer safeguarding)
- Tailored business plan preparation based on operational model and license scopeAdvise on regulatory strategy and MiCA compliance recommendations
Preparation of key personnel for compliance assessment - Advisory on MiCA compliance and regulatory expectations in Spain
- Fit and Proper documentation and training for key personnel
- Legal opinion on regulatory readiness and operational structure
- Pre-meeting preparation and representation before CNMV or Bank of Spain
- Assistance with increasing share capital in line with MiCA class requirements
- Support in appointing local staff to meet Spanish operational obligations
Ideal for companies seeking comprehensive compliance support to meet both MiCA and national requirements.
Ready-Made VASP Solution
Fast track – Price on request
- Pre-registered Spanish company
- Active VASP license (MiCA transition-ready)
- Legal address for 1 year
- No debts or liabilities
- Registered share capital: €5,000 (additional required for CASP application)
- Corporate document transfer and regulatory compliance review
- Assistance with company ownership transfer and filings
This is a fast-track option for businesses looking to acquire a Spanish-licensed crypto entity and begin operations quickly.
Eriks Fijalovs
Head of 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 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.
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. How to get a cryptocurrency license in Spain?
The process begins with registering a company (usually a limited liability company) in Spain, depositing and registering the share capital, setting up necessary compliance infrastructure (AML/KYC/CFT policies), appointing the required local staff (if applicable), and obtaining authorization for cryptocurrency-related activities under the Comisión Nacional del Mercado de Valores (CNMV) or SEPBLAC (depending on the scope of activities).
2. How long does it take to obtain a cryptocurrency license in Spain?
The licensing process involves multiple steps and direct communication with the regulator. Based on our experience:
• A ready-made company with a license can be transferred to new ownership within 1-2 months.
• The full process from scratch typically takes approximately 2-3 months.
• Approval times for a new CASP license under MiCA are currently estimated at 3-5 months after submission to the CNMV or SEPBLAC.
3. Can a foreigner get a cryptocurrency license in Spain?
Yes, a foreigner can be a shareholder in a Spanish crypto company. However, there is a mandatory requirement for the company director to be either a Spanish or EU citizen.
4. What is the share capital requirement for a crypto company in Spain?
• The minimum share capital for a limited liability company (SL) in Spain is typically 3,000 EUR, although higher amounts may be required depending on the type of services offered.
• Under MiCA, additional capital is required before applying for a CASP license, depending on the license class (starting from 50,000 EUR for Class 1 CASPs).
5. How to open a bank account for a Spanish crypto company?
6. What companies must adapt to MiCA regulations?
All Virtual Asset Service Providers (VASPs) that provide exchange, custody, or other virtual asset services must apply for the new CASP license supervised by the CNMV or SEPBLAC in accordance with MiCA regulations.
7. When should a company apply for a CASP license under MiCA?
• The application period for the new CASP license under MiCA started on December 30, 2024.
• When submitting a CASP license application, the company must already meet all MiCA requirements (including governance, capital, and compliance obligations).
8. What documents are required for CASP licensing under MiCA?
In accordance with Regulation (EU) 2023/1114 (MiCA), companies must prepare a set of policies and manuals before the application. The full list can be requested from Legalaes.
9. Is a business plan required for MiCA licensing?
Yes, MiCA requires companies to submit a detailed Business Plan (Programme of Operations) to the CNMV or SEPBLAC. This document outlines:
• Business activities and services provided under the CASP license.
• Financial projections and capital requirements.
• Governance, operational structure, and risk management framework.
10. How long does it take for the CNMV or SEPBLAC to approve a CASP license?
• There is currently no exact timeframe for CASP license approvals under MiCA.
• Based on similar regulatory processes, the CNMV or SEPBLAC is expected to review applications within 3-5 months.
11. Does a CASP license require a physical office in Spain?
• No, physical office space is not required at the moment.
• A legal address is sufficient for company registration and licensing.
• However, some payment gateways and financial institutions may require a virtual office with a lease agreement, which Legalaes can arrange.
12. Is an AML Compliance Officer required?
• Yes, an AML officer is mandatory for CASP licensing.
• The AML officer can be from any EU country, but a local Spanish AML officer is recommended for effective communication with regulators.
• Legalaes can provide a local AML officer upon request.
Each of our projects receives unique and tailored solutions in accordance with the initial objectives and vision of the shareholders.
May also interest you
