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🇪🇸 Spain

Bank-led CASP adoption (BBVA, CaixaBank, Openbank) under CNMV, with a sharply disputed headline CASP count and an approaching 1 July 2026 hard deadline.

Crypto (CASP / VASP) E-money (EMI)
Last verified 2026-08-15 Next review 2026-08-29

Data verified: oldest cell 46 days ago (verified 2026-07-02). Individual cells show their own verification date below.

Capital requirement Capital requirement is included with access. Included with access Timeline to authorisation Timeline to authorisation is included with access. Included with access Application cost Application cost is included with access. Included with access Passporting Passporting is included with access. Included with access

Licence type

Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier.

Verified 2 days agoSource: Current national regulator authorisation material: https://sedeelectronica.bde.es/sede/es/tramites/autorizacion-entidades-dinero-electronico-p221.html

Regulator

Banco de Espana (Bank of Spain)

Verified 2 days agoSource: Current national regulator authorisation material: https://sedeelectronica.bde.es/sede/es/tramites/autorizacion-entidades-dinero-electronico-p221.html

Recent changes

Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Verified 2 days agoSource: https://data.consilium.europa.eu/doc/document/ST-8222-2026-INIT/en/pdf ; https://data.consilium.europa.eu/doc/document/ST-8221-2026-INIT/en/pdf ; https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2023%2F0209%28COD%29

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Not legal advice. Entries marked placeholder or awaiting verification shouldn't be relied on. Verify with Spain's regulator and qualified local counsel before acting.