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 125k-EUR 350k capital, 3-month statutory clock, no application fee, Spanish-resident director 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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Request demoCapital and scope
- PI. EUR 20k (remittance), EUR 50k (PISP), EUR 125k (acquiring, issuing, transfers).
- EMI. EUR 350k.
- Small PI / Small EMI. Spain runs both small regimes, domestic-only. Small EMI typically capped at EUR 5M outstanding e-money; review in 20 days vs 3 months for a full file.
Application fee. None. Spain is one of the few EU jurisdictions with a zero authorisation fee, alongside Ireland.
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 small PI/EMI if documentation 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. At least two directors; at least one must be a Spanish resident. Physical office in Spain, 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 provides the core-banking platform aligned with Banco de España expectations: ledger, IBANs, cards, SEPA rails, KYC and AML (Ley 10/2010), safeguarding, DORA ICT and Banco de España-ready reporting.
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 small PI/EMI. Real-world 6 to 9 months for a full PI and 9 to 12 for a full EMI.
No. Spain is one of the few EU jurisdictions with a zero authorisation fee.
Yes, primarily. The file is filed in Spanish. English annexes may be accepted for specific technical content.
Crassula provides the core-banking platform aligned with Banco de España expectations: ledger, IBANs, cards, SEPA rails, KYC/AML, safeguarding, DORA ICT and regulator-ready reporting.
