Spain electronic money institution licence.

What you get

How we get you licensed and live

1. Scoping and proposal. We confirm the permissions and the own funds in a written proposal, and use the optional pre-application form and preliminary meeting with the Banco de España to agree the scope before filing.
2. Application pack. The application forms, the business plan on the Banco de España’s spreadsheet template, the annex templates and the suitability forms, with every key document in Spanish as the applicant guide expects, filed through the electronic office.
3. Banking. The segregated safeguarding account, or low-risk asset arrangement, and the operating accounts, opened alongside the application, with the safeguarding method ready to disclose publicly as Spanish rules require.
4. Regulator engagement. Information requests are answered in full and any change to the business reported at once, keeping the file accurate while the anti-money laundering authority prepares its report, until the decision and entry in the special register.

Your team, banking and technology

You will need directors and senior managers who run the business from Spain, and an independent head of customer service.

One programme, from scoping to launch. Speak to an expert about this licence.

Who needs the licence

A business issuing stored value in Spain or, through passporting, across the EU and EEA needs authorisation from the Banco de España. Spain is a gateway to Latin America for payment groups. An EMI may provide every payment service under the same authorisation.

What the Banco de España requires

• Legal form and location. A company with its registered office, central administration and effective management in Spain, carrying on part of its activities in Spain.
• Governance. Fit and proper questionnaires for directors and managers; shareholders at 10% or more assessed; clear reporting lines; an independent customer service function; an external auditor named; a security policy and a continuity plan with key-person succession.
• Safeguarding. Segregation in a separate account or investment in low-risk assets; an insurance policy or comparable guarantee only with the Banco de España’s authorisation; the method disclosed publicly.
• Application pack. An optional pre-application form and preliminary meeting, then the file through the Banco de España’s electronic office: the application forms, the business plan on the Banco de España’s spreadsheet template, the annex templates and the suitability forms, in Spanish; a report from the anti-money laundering authority forms part of the assessment.
• Capital. Initial capital of €350,000 and own funds thereafter equal to the higher of that and 2% of average outstanding e-money over the preceding six months, with a 20% adjustment at the Banco de España’s discretion; unrelated payment services under Methods A, B or C.

Capital

Spain did not adopt a small EMI waiver; only limited-network exclusions apply.

Timing

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.

Fees and costs

Passporting and scope

A Spanish EMI passports throughout the EU and EEA by branch, agent or cross-border services on notification to the Banco de España.

Why applications are delayed

The Banco de España’s applicant guide lists the causes of delay.

1. A business plan that lacks detail.
2. Incomplete documentation that prevents verification.
3. Information not kept accurate, and changes not reported, during the assessment.
4. Key documents not provided in Spanish.

Your bank accounts

An EMI needs a safeguarding account, an operating account and settlement accounts in the currencies it serves. We open each alongside the application, so you trade from authorisation. See banking and payment processing.

Common questions

References

1. Banco de España: informative guide for applicants
2. Banco de España electronic office: EMI authorisation
3. Banco de España electronic office: payment institution authorisation
4. Royal Decree-Law 19/2018 on payment services
5. Law 21/2011 on electronic money
6. Royal Decree 778/2012 on electronic money institutions

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.