Crypto License Spain: CNMV CASP Authorization Under MiCA

A crypto license in Spain is, in legal terms, a CASP authorisation. The Comisión Nacional del Mercado de Valores (CNMV) authorises and supervises crypto-asset service providers under MiCA Title V. Minimum capital runs from EUR 50,000 to EUR 150,000 by service class, and an authorised firm can passport across the European Economic Area.

If you have been searching for how to get a crypto license in Spain, you are really asking how to obtain a CASP authorisation from the CNMV under the EU's Markets in Crypto-Assets Regulation. Spain sits inside the EU single market, so a Spanish CASP authorisation is not a national-only permit. It is an EU-wide gateway. This guide explains who regulates what, the capital you need, the application process, the disputed transition deadline, and how a single Spanish licence unlocks the whole EEA. Everything here is anchored to CNMV, ESMA and MiCA primary sources, and read alongside the full MiCA regulation guide it gives founders and compliance officers a clear, lawyer-grade picture of the Spanish route.

Quick answer: how to get a crypto license in Spain

To get a crypto license in Spain you obtain a CASP authorisation from the CNMV under MiCA Title V. You set up an EU legal entity, hold permanent minimum capital of EUR 50,000, 125,000 or 150,000 by service class, meet governance and AML rules, then file electronically with the CNMV. MiCA has applied since 30 December 2024.

That short answer hides several moving parts. The legal term is CASP authorisation, not "license," and the precise capital figure depends on which crypto-asset services you intend to provide. The MiCA capital floors come from Annex IV [S3, S8], and the regulation has applied across the EU since 30 December 2024 [S1]. The rest of this page expands each of those points so you can scope a realistic application.

Who regulates crypto in Spain? CNMV vs Banco de España

Spain splits crypto supervision between two authorities, and conflating them is the single most common error. The CNMV authorises and supervises crypto-asset service providers under MiCA Title V. The Banco de España supervises issuers of e-money tokens and asset-referenced tokens. They cover different parts of MiCA, and only one of them issues your CASP licence.

CNMV: competent authority for CASPs (Title V)

The Comisión Nacional del Mercado de Valores is Spain's national competent authority for authorising and supervising CASPs under MiCA Title V [S1, S2]. If you run an exchange, a custodian, a broker, an advisory firm or a trading platform for crypto-assets, the CNMV is the body you apply to and the body that supervises you afterwards. It also publishes the official applicant guidance that anchors a serious application, described in the process section below.

Banco de España: EMT and ART issuers (Titles IV and III)

The Banco de España supervises issuers of e-money tokens under MiCA Title IV and issuers of asset-referenced tokens under MiCA Title III [S1, S2]. These are token-issuance roles, not crypto-service roles. If your business model is to issue a euro stablecoin (an EMT) or a basket-backed token (an ART), your supervisor is the central bank, not the CNMV. Most service firms looking for CASP authorisation under MiCA deal only with the CNMV, but founders combining issuance with services should plan for both authorities.

The closed Law 10/2010 AML registry at the Banco de España

Before MiCA applied, firms offering virtual-currency exchange and wallet-custody services in Spain had to register with the Banco de España's virtual-asset AML registry, established under Law 10/2010 on the prevention of money laundering and terrorist financing [S1]. Since 30 December 2024 no further persons or entities may be entered in that registry. It persists only for informational purposes [S1]. This is an AML registration, not a banking approval, and it is now closed to new entrants. New providers seek CASP authorisation from the CNMV instead.

What is a CASP authorisation under MiCA?

A CASP authorisation is the formal permission, granted under MiCA Title V, that lets a firm provide crypto-asset services in the EU. CASP stands for crypto-asset service provider. The authorisation is tiered by service class, carries minimum-capital and governance obligations, and once granted can be passported across the European Economic Area. It is the precise legal status behind the everyday phrase "crypto license."

Crypto license vs CASP authorisation: the terminology

People say "crypto license Spain"; the regulation says "CASP authorisation." The two describe the same outcome, the legal right to provide crypto-asset services, but only the second term appears in MiCA, in CNMV documents and on the ESMA register. Keeping the mapping clear matters, because the requirements, deadlines and passporting rights all attach to the formal CASP status under Regulation (EU) 2023/1114, not to any informal "license." For the distinction between the older VASP world and the new CASP framework, see VASP vs CASP under MiCA.

Which crypto services need a CASP licence in Spain

MiCA defines a set of crypto-asset services, and providing any of them in Spain requires CASP authorisation from the CNMV. The covered services map directly to the capital classes below [S3, S8]:

• Reception and transmission of orders for crypto-assets
• Execution of orders on behalf of clients
• Placing of crypto-assets
• Providing transfer services for crypto-assets
• Advice on crypto-assets
• Portfolio management of crypto-assets
• Custody and administration of crypto-assets on behalf of clients
• Exchange of crypto-assets for funds or for other crypto-assets
• Operation of a trading platform for crypto-assets

The bundle of services you choose decides your capital class, which is the next thing to plan.

Minimum capital for a Spanish CASP: MiCA Annex IV classes

MiCA Annex IV sets three permanent-minimum-capital classes for CASPs: EUR 50,000, EUR 125,000 and EUR 150,000, depending on the crypto-asset services provided [S3, S8]. The class is not chosen freely. It is determined by the most capital-intensive service you intend to offer. On top of the class floor, Article 67 imposes an own-funds rule based on your overheads. The table below maps services to classes.

Class 1: EUR 50,000

Class 1 carries a permanent minimum capital of EUR 50,000 [S3, S8]. It covers reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice on crypto-assets and portfolio management. This is the lightest tier, suited to brokerage, advisory and order-routing models that do not take custody of client assets or run an exchange.

Class 2: EUR 125,000

Class 2 carries a permanent minimum capital of EUR 125,000 [S3, S8]. It covers everything in Class 1, plus custody and administration of crypto-assets on behalf of clients, plus exchange of crypto-assets for funds or for other crypto-assets. Most exchange and wallet-custody operators sit in Class 2, because both holding client assets and running an exchange service fall here.

Class 3: EUR 150,000

Class 3 carries a permanent minimum capital of EUR 150,000 [S3, S8]. It covers all Class 1 and Class 2 services, plus operation of a trading platform for crypto-assets. If you intend to run a matching venue where third parties trade, you are in Class 3, the top tier. Note the distinction MiCA draws between an exchange service (Class 2) and operating a trading platform (Class 3); they are not the same activity.

Own funds: the higher of minimum capital or one quarter of fixed overheads

The class floor is a minimum, not the whole story. Under Article 67, a CASP must hold own funds at least equal to the higher of (a) the permanent minimum capital for its class under Annex IV, or (b) one quarter of the preceding year's fixed overheads [S3, S8]. For a firm with high fixed costs, the overhead-based figure can exceed the class floor, so the true capital requirement scales with the size of your operation. The exact own-funds article cross-reference is flagged for confirmation against EUR-Lex before publishing (see Open questions).

Legal entity, substance and governance requirements

A Spanish CASP applicant must be a properly constituted EU legal entity with real substance, fit-and-proper management and a working AML/CFT function. MiCA does not mandate a specific corporate form, but it does require genuine establishment in the Union, sound governance and people of good repute running the business. These requirements are qualitative rather than numeric, and the CNMV assesses them as part of the authorisation.

EU legal entity and registered office

The applicant must be a legal entity duly constituted and registered in an EU Member State, with a registered office in the EU and effective management or central administration in the Union [S3, S8]. In Spain, a Sociedad Limitada is the common practical vehicle, but it is typical rather than MiCA-mandated; any qualifying EU legal entity can apply [S3, S8]. The point MiCA cares about is real establishment and management inside the Union, not the specific company type. Whether the CNMV mandates a particular Spanish form or accepts any EU entity is flagged for confirmation (see Open questions).

Fit-and-proper management and shareholders

The management body and qualifying shareholders must be fit and proper, meaning good repute, knowledge and experience [S8]. Applicants provide certification that relevant individuals have no convictions related to money laundering or terrorist financing [S8]. The CNMV scrutinises who controls and runs the firm, so directors and significant shareholders need clean records and demonstrable competence in financial services or crypto operations.

AML/CFT obligations under Law 10/2010

AML and KYC obligations flow from Law 10/2010 on the prevention of money laundering and terrorist financing [S1, S8]. A CASP must run customer due diligence, transaction monitoring and risk management, with documented policies and procedures [S1, S8]. Spain's AML supervision sits within the Law 10/2010 framework; the specific naming of SEPBLAC as the supervisor is flagged for confirmation (see Open questions). For a deeper treatment of these controls, see our AML/KYC compliance requirements guide.

How to get a CASP licence in Spain: step-by-step process

Getting a CASP licence in Spain follows a clear sequence: build the entity and capital, assemble the documentation pack, file electronically with the CNMV, pass the CNMV's assessment, then collect the authorisation and passport across the EEA. The CNMV's official applicant Manual is the reference document throughout. The steps below set out what each stage involves.

Step 1: Establish the entity and capital structure

Set up an EU or Spanish legal entity, commonly a Sociedad Limitada, with a registered office, share capital matching your intended Annex IV service class, fit-and-proper directors and a compliance and AML function [S1, S8]. This is the foundation: the entity, its capital and its people must all line up with the class of services you plan to offer before you draft any application.

Step 2: Prepare the documentation pack

Assemble the application file: a programme of operations or business plan, AML and KYC policies, governance and risk documentation, IT and security descriptions, and shareholder and beneficial-owner disclosures, all per the CNMV CASP authorisation Manual [S1, S8]. The CNMV has published a "Manual para la solicitud de la autorización de proveedores de servicios de criptoactivos" as the document of record for applicants [S1, S2]. Building this pack to the Manual's standard is where most of the preparation time goes.

Step 3: Submit the application to the CNMV

File the application electronically with the CNMV [S8]. The submission bundles the full documentation pack from Step 2. From our practice, a clean, complete submission that mirrors the Manual's structure moves through the early completeness review far more smoothly than a partial file that triggers requests for more information.

Step 4: CNMV assessment and decision

The CNMV runs a completeness check, then a substantive assessment of the application, and may request additional information during the process [S5]. MiCA sets statutory review windows for CASP authorisation, but the often-quoted "3 to 6 months" is a practitioner estimate, not a statutory figure. The exact MiCA Article 63 timelines should be confirmed against EUR-Lex before relying on any specific duration (see Open questions), so plan for a multi-month assessment rather than a fixed date.

Step 5: Authorisation, ESMA register and passporting

On authorisation, the CASP is entered in the ESMA register and may passport its services across the EEA [S5]. This is the payoff: a single Spanish authorisation becomes an EU-wide operating right. The passporting mechanics are covered in detail in the dedicated section below.

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When does Spain's MiCA transition period end?

Spain's MiCA transition date carries a genuine source conflict that should not be flattened. Spain first set a shortened transition period, then extended it. The CNMV states the period ends on 1 July 2026, while ESMA's grandfathering list shows 30 June 2026. The two dates differ by one day, and both are later than the originally announced shortened date of around 30 December 2025. Anyone relying on the deadline should check both authorities.

The grandfathering rule under MiCA Article 143(3)

Under MiCA Article 143(3), entities that provided crypto-asset services under prior national law before 30 December 2024 may continue until 1 July 2026, or until their MiCA authorisation is granted or refused, whichever comes first; Member States may shorten this window [S5]. This is the EU-wide default. It is why pre-existing Spanish providers were not forced to stop on the MiCA application date, and why the national transition arrangement matters so much. For the EU-wide picture, see the MiCA transition timeline.

Spain shortened, then extended its transition

Spain initially set a shortened transition, originally announced to end around 30 December 2025 [S6, S7]. It then extended that period. The CNMV's own MiCA page states the Spanish transitional period ends 1 July 2026 [S1, S2], while ESMA's grandfathering list, published 1 December 2025, and secondary reporting show 30 June 2026 [S6, S7]. The exact ESMA Spain-row date should be re-verified before publication (see Open questions). The page presents both authority statements rather than asserting one uncontested date. For how this affects firms already operating, see what MiCA changes for existing licensees.

EU passporting: one Spanish CASP licence, the whole EEA

The decisive advantage of a Spanish CASP authorisation is EU passporting. Once the CNMV authorises you and ESMA enters the firm in its register, you can provide your crypto-asset services across the European Economic Area without a separate licence in each country [S5]. One authorisation becomes a multi-market operating right. The mechanics work as follows:

• The CNMV authorises the CASP under MiCA Title V [S1, S2].
• ESMA enters the authorised firm in the EU-wide CASP register [S5].
• The firm notifies the host Member States where it intends to operate.
• It then provides the authorised services across the EEA under the single MiCA authorisation [S5].

This is why jurisdiction choice inside the EU is about fit, substance and support rather than market access; every MiCA authorisation reaches the same EEA. For the mechanics in depth, see single EU licence passporting.

The Article 60 shortcut for already-authorised financial entities

Not every firm needs a full CASP authorisation. Under the Article 60 notification regime, certain already-authorised financial entities can notify the CNMV that they intend to provide crypto-asset services, rather than apply for a fresh CASP authorisation [S1, S2]. The CNMV has published a notification model for this route [S1, S2]. If your firm already holds an EU financial licence, for example as a credit institution or investment firm, the notification path can be materially faster than a standalone application. This option was absent from older Spanish guidance, and it can change the entire project plan for established financial groups entering crypto.

Cost and feasibility: is Spain the right CASP base?

Spain is a credible MiCA base, and its feasibility turns on capital, substance and support rather than any headline fee. The hard floor is the Annex IV class capital: EUR 50,000, 125,000 or 150,000 [S3, S8]. Beyond that, costs scale with the substance you build and the professional support you engage. We do not publish a price list; the right figure depends on your service class and business model, which is exactly what a scoping conversation establishes.

What drives the cost of a Spanish CASP authorisation

Three factors drive the real cost of a Spanish CASP authorisation. First, capital class: a trading platform (Class 3, EUR 150,000) commits more than an advisory firm (Class 1, EUR 50,000) [S3, S8]. Second, substance: registered office, management presence, compliance and AML staffing, and IT and security arrangements all carry ongoing cost. Third, professional support for drafting the Manual-grade documentation pack and managing the CNMV assessment. These are ranges and drivers, not fixed prices, and they vary with your model.

Spain compared with Germany, Ireland and other EU routes

Because every MiCA authorisation passports across the EEA, choosing between Spain and other Member States is about local fit, not market reach. Germany's authorisation runs through Germany's BaFin CASP route, and Ireland's through Ireland's CBI CASP route. Each authority has its own assessment style, timelines and documentation expectations. To weigh Spain against the field on substance, language, talent and supervisory approach, compare the best countries for a crypto licence.

Why work with Crypto Valley Partners on your Spanish CASP licence

A CASP authorisation is a regulated financial-services project, and the gap between a complete, Manual-grade application and a partial one shows up directly in CNMV assessment time. Crypto Valley Partners AG, based in Zug, Switzerland, advises founders, exchange operators and compliance officers on MiCA authorisations across the EU, including the Spanish CNMV route. From our practice, the firms that move fastest are those that match their capital class, substance and documentation to the regulator's expectations from day one, rather than discovering gaps mid-assessment. We help structure the entity, scope the right Annex IV class, build the documentation pack and engage with the CNMV, all anchored to primary sources, not marketing claims. If Spain is on your shortlist, the next step is a scoping conversation about your specific service mix and timeline.

By Magnus Müller · Reviewed by Magnus Müller · Last updated: 2026-06-14