Spain payment institution licence.

What you get

How the firm obtains the licence

1. Scoping and proposal. The payment services, the capital by service and the choice between full authorisation and low-volume registration are confirmed in a written proposal the same day, with the own funds method set for its three-year period.
2. Application pack. The forms, the business plan on the Banco de España template, the suitability forms and the professional indemnity insurance for payment initiation or account information, all in Spanish, filed through the electronic office.
3. Banking. The safeguarding account and the settlement and operating accounts are arranged through the firm’s relationships before the decision, so the safeguarding method can be disclosed publicly from the first day of trading.
4. Regulator engagement. Each request is answered with the evidence assembled while the statutory clock stops, and the file is kept accurate as the business develops, through the anti-money laundering authority’s report to the decision and registration.

Key people, banking and technology

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

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

Who needs the licence

A business providing a payment service in Spain or, through passporting, in the EU and EEA needs authorisation from the Banco de España. A business that will also hold customer balances applies for an EMI licence instead.

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 by service and own funds thereafter equal to the higher of that and Method A, B or C, chosen for three years and notified each January; at least 75% of Tier 1 in common equity.
• Professional indemnity insurance. For payment initiation and account information services, sized to the European guidelines and running thirteen months after the decision.

Capital

Tier 2 capital is capped at one third of Tier 1.

Timing

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

Low-volume payment institutions

A firm whose monthly average payment volume stays below €3 million, providing services other than payment initiation and account information, with its head office in Spain, registers as a low-volume payment institution through the electronic office. It has no establishment or services rights in other Member States and must apply for full authorisation within 30 days of exceeding the threshold. Account information providers register separately.

Passporting and scope

A Spanish payment institution passports throughout the EU and EEA on notification to the Banco de España. The low-volume registration carries no passport.

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

A payment institution 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

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 736/2019 on payment institutions
7. Banco de España electronic office: low-volume payment institution registration

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.