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Licence guide

Spain electronic money institution licence.

Spain is the EU base for payment groups that look to Latin America, with no application fee and one authorisation covering e-money and every payment service across the EU.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
Banco de EspañaRegulator
€350,000Initial capital
NoneApplication fee
6 to 8 monthsOur realistic timeline
EU and EEAPassporting

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 8 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for directors in Spain and a customer service head, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. The permissions and the own funds are confirmed in a written proposal the same day, and the optional pre-application form and preliminary meeting with the Banco de España are used 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 are arranged through the firm’s relationships before the decision, 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.

Key people, banking and technology

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

Key peopleThe firm introduces candidates for directors in Spain and a customer service head from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • A Spanish EMI issues e-money and provides payment services across the EU and EEA on one authorisation from the Banco de España.
  • Initial capital is €350,000; own funds are the higher of that and 2% of average outstanding e-money over the prior six months, adjustable by 20%.
  • There is no application fee or deposit.
  • Three months from a complete file by statute; silence is refusal.
  • Registered office, central administration and effective management in Spain.
  • There is no small EMI regime in Spain.

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, and the firm’s trade payments work in Brazil, Argentina and Colombia pairs with Spanish authorisations. 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

RequirementAmount
Initial capital€350,000
Ongoing own fundsHigher of €350,000 and 2% of average outstanding e-money (prior six months)
AdjustmentUp to 20% either way
Unrelated payment servicesMethod A, B or C

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

Timing

FigureValueSource
Statutory decision period3 months from a complete file; silence is refusal; the clock stops during information requestsLaw 21/2011 and Royal Decree 778/2012
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Application feeNoneNo fee or deposit
Annual supervisory feeNone publishedThe Banco de España publishes no annual authorisation fee
Initial capital€350,000Held before authorisation
Professional feesFixed, in writingQuoted after scoping

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.

Banking

An EMI needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Spain and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

How long does a Banco de España EMI authorisation take?

Three months from a complete file by statute, with silence treated as refusal and the clock stopping during information requests. The firm plans for six to eight months after submission.

Is there an application fee in Spain?

No fee and no deposit.

Must the application be in Spanish?

Yes. The Banco de España lists documents not in Spanish as a cause of delay; the firm prepares the file in Spanish.

Is there a small EMI regime?

No. Every issuer holds the full authorisation.

Can a Spanish EMI serve Latin America?

The EU authorisation covers the EU and EEA. Latin American operations are licensed locally; the firm advises on both and runs trade payments in Brazil, Argentina and Colombia through Helm.

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

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.