Spain EMI and PI License in 2026: Banco de España Complete Guide
A 2026 deep dive into the Spanish EMI and PI licence: Banco de España authorisation, EUR 20k-EUR 350k capital, 3-month statutory clock, central administration in Spain and PSD3 transition.
Spain as an EMI and PI jurisdiction
Banco de España (Bank of Spain) is the Spanish supervisor for credit institutions, PIs and EMIs. The CNMV supervises securities markets and investment firms; the DGSFP covers insurance. For payment and e-money projects Banco de España is the single point of contact.
Spain is Europe's fourth-largest economy and has the largest concentration of retail-focused fintech customers in the EU. Typical use cases for a Spanish EMI or PI: SME card programmes, consumer wallet apps, Spanish-market acquirers, and retail-brokerage cash management.
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Capital and scope
- PI. EUR 20k (remittance), EUR 50k (PISP), EUR 125k (acquiring, issuing, transfers).
- EMI. EUR 350k.
- Small PI. Spain offers an exempt (small) payment institution regime under Article 14 of RDL 19/2018: average payment volume up to EUR 3M a month, Spain only, no passporting. Registration is deemed made 20 days after a complete filing. Spain has no equivalent small EMI regime, so e-money issuers need full authorisation.
Process, timeline and substance
- Incorporation. Spanish SA or SL with registered office in Spain and capital paid up in a Spanish credit institution.
- File preparation. Business plan, programme of operations, governance, AML/CFT aligned with Spanish Ley 10/2010, safeguarding plan, outsourcing register, fit-and-proper files.
- Submission. Via the Banco de España Electronic Registry, in person or by mail. Primarily Spanish-language.
- Statutory clocks. 3 months from complete file for full PI/EMI. 20 days for a small PI registration once the documentation is complete.
- Real timeline. 6 to 9 months end-to-end for a full PI, 9 to 12 for a full EMI. Small PI often lands in 3 to 5 months.
- Substance. Registered office, central administration and effective management in Spain. Directors and senior managers must pass Banco de España fit-and-proper checks and be entered in its Registro de Altos Cargos. Plan for a real office and local compliance and risk functions.
PSD3 and MiCA connections
Spanish PIs and EMIs migrate to the unified PSD3 regime in 2027. For crypto, CNMV is the designated MiCA CASP authority in Spain. Spain initially opted for a 12-month grandfathering window for pre-MiCA registrants but extended it in December 2025 to 18 months, ending 30 June 2026, aligning with the EU-wide backstop.
Ship a Spanish PI or EMI product with Crassula
Crassula Core keeps the ledger, client accounts with virtual IBANs, SEPA rails and the audit trail. Cards come through pre-integrated issuers you contract with directly, and identity checks run through connected verification providers. Transaction monitoring, sanctions screening and reporting to Banco de España stay with you and your chosen providers; Crassula supplies the ledger balances and transaction exports for safeguarding reconciliation and, as your ICT provider, the incident and outsourcing information you need for DORA.
FAQ
Banco de España (Bank of Spain). CNMV handles securities markets and investment firms; the MiCA CASP authority is CNMV.
Statutory 3 months from complete file for full PI/EMI; 20 days for a small PI registration. Real-world 6 to 9 months for a full PI and 9 to 12 for a full EMI.
Confirm the current position with Banco de España at the pre-application stage. In practice the bigger budget lines are legal advice, initial capital and the local substance build-out.
Yes, primarily. The file is filed in Spanish. English annexes may be accepted for specific technical content.
Crassula Core runs the ledger, client accounts and IBANs, SEPA rails and the audit trail. Cards, identity checks, transaction monitoring and sanctions screening plug in through connected providers, and Crassula gives you the data and ICT-provider information for safeguarding checks, DORA and reporting to Banco de España.
