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| Dimension |
Pinned 🇵🇹 Portugal partly open Verified 2026-08-15
|
🇪🇸 Spain
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. | MiCA CASP Authorisation granted by the Comisión Nacional del Mercado de Valores (CNMV); Banco de España separately supervises stablecoin (ART/EMT) issuance |
| Regulator | Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.) | Comisión Nacional del Mercado de Valores (CNMV) - lead CASP authority; Banco de España co-supervises stablecoin issuers |
| Capital requirement | Portugal capital requirement is included in the £349 pass. | Spain capital requirement is included in the £349 pass. |
| Timeline to authorisation | Portugal timeline to authorisation is included in the £349 pass. | Spain timeline to authorisation is included in the £349 pass. |
| Local substance | Portugal local substance is included in the £349 pass. | Spain local substance is included in the £349 pass. |
| Application cost | Portugal application cost is included in the £349 pass. | Spain application cost is included in the £349 pass. |
| Ongoing cost | Portugal ongoing cost is included in the £349 pass. | Spain ongoing cost is included in the £349 pass. |
| Passporting | Portugal passporting is included in the £349 pass. | Spain passporting is included in the £349 pass. |
| MiCA CASPs approved | Portugal mica casps approved is included in the £349 pass. | Spain mica casps approved is included in the £349 pass. |
| Key restrictions | Portugal key restrictions is included in the £349 pass. | Spain key restrictions is included in the £349 pass. |
| Recent changes | Lei 69/2025 (MiCA) and Lei 70/2025 (Travel Rule) published 22 Dec 2025, about a year late. The legacy-VASP transitional window closed 1 Jul 2026. Bison Bank became Portugal's first MiCA-authorised CASP in late Jun 2026, following approval from Banco de Portugal and the CMVM. | The CNMV's own register shows a bank-led adoption pattern: home-authorised providers include BBVA, CaixaBank, Cecabank, Kutxabank, Open Bank and Renta 4 alongside fintechs such as Bit2Me, Criptan Trade and Crossmint Europe, 10 in total by late Jun 2026. CNMV published updated MiCA Q&A guidance in Dec 2025 ahead of full application from 1 Jul 2026. |
| Difficulty rating | Portugal difficulty rating is included in the £349 pass. | Spain difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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