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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
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 and cryptoasset firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenMacmillan Cancer SupportRoyal College of MusicStaysureOval 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 to decision.

Day oneReady to trade

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

Your teamKey people in place

We assemble your team: directors in Spain and a customer service head.

Same dayWritten proposal

The licence, the requirements, the cost and the timing for your business.

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.

Key peopleWe assemble your team: directors in Spain and a customer service head.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, opened alongside the application.
TechnologyWhite-label technology for accounts, payments, wallets and card programmes, ready to go live with the licence.

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

The licence in detail

Requirements, capital, timing, fees and common questions, drawn 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. 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 submissionOur own figure, from the regulator’s published data and our applications

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes 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 feesFixedQuoted 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.

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

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. We plan 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; we prepare 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; we advise on both.

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 builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.

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

How we work.

  • Senior-ledThe same senior team handles your application from the first call to approval, including every question the regulator raises.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceDocuments, regulator questions, messages and progress in a shared client workspace, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have run regulated payment businesses, held regulator-approved roles and licensed payment firms in more than 60 countries since 2013.
  • One teamOne in-house team runs the whole programme, from the application to the day you go live.
  • ArrangedBank and safeguarding accounts, card issuing and payment processing, arranged directly through our relationships with banks, card schemes, issuers and processors.

Apply for this licence.

The licence, your team, banking and technology, delivered as one programme.