The Spanish cryptocurrency market is undergoing a transformative shift with the implementation of the Markets in Crypto-Assets Regulation (MiCA), positioning the country as a strategic hub for compliant crypto businesses in the European Union. As one of the leading Eurozone economies, Spain has established a clear regulatory framework for Crypto-Asset Service Providers (CASP) under the joint oversight of the National Securities Market Commission (CNMV) and the Bank of Spain.
This regulatory evolution ensures both innovation and investor protection, aligning Spanish crypto regulations with EU-wide standards. For international entrepreneurs and fintech firms, understanding the requirements, costs, and timeline for obtaining a CASP license in Spain is essential for successful market entry.
Understanding the CASP Licensing Framework in Spain
Under MiCA (Regulation (EU) 2023/1114), all entities offering crypto-asset services in Spain must obtain a CASP license. This includes activities such as crypto trading, custody, exchange, portfolio management, and advisory services. The licensing authority depends on the nature of the services:
- CNMV oversees investor-facing services like trading and custody.
- Bank of Spain supervises payment-related crypto operations and electronic money integration.
Existing Virtual Asset Service Providers (VASPs) registered in Spain must transition to the new MiCA-compliant CASP license by December 2025, marking a critical deadline for regulatory compliance.
👉 Discover how to fast-track your MiCA compliance process in Spain.
CASP License Categories and Capital Requirements
MiCA introduces three distinct classes of CASP licenses, each corresponding to the scope of services and capital obligations:
Class 1 – Limited CASP
- Services: Basic crypto functions such as custody, order execution, and crypto advice.
- Minimum Capital: €50,000
- Ideal for startups focusing on custodial or advisory solutions.
Class 2 – Standard CASP
- Services: Crypto exchange, trading, and asset management.
- Minimum Capital: €125,000
- Suitable for platforms offering multi-service operations.
Class 3 – Full CASP
- Services: Operating a crypto trading platform, lending services, and complex financial products.
- Minimum Capital: €150,000
- Subject to the highest level of regulatory scrutiny.
These classifications ensure proportionate regulation based on business complexity and risk exposure.
Key Requirements for Obtaining a CASP License
To qualify for a CASP license in Spain, companies must meet comprehensive legal, operational, and compliance criteria:
Corporate Structure
- Register a Spanish entity (typically a Sociedad Limitada or SL).
- Minimum share capital of €3,000 at incorporation (additional capital required before license application).
- A legal address in Spain is mandatory; a physical office is not required.
Governance & Personnel
- Appoint a director who is a Spanish or EU citizen.
- Designate a dedicated AML Compliance Officer (can be based in any EU country; local appointment recommended).
- Submit Fit and Proper assessments for key personnel to demonstrate integrity and competence.
Compliance Infrastructure
- Implement robust AML/KYC/CFT policies aligned with MiCA and EU standards.
- Develop internal procedures covering risk management, cybersecurity, client fund protection, and governance.
- Maintain records and report suspicious transactions to SEPBLAC (Spain’s Financial Intelligence Unit).
Documentation & Application
- Power of Attorney (notarized)
- Memorandum and Articles of Association
- Detailed business plan outlining operations, revenue model, and risk framework
- Structured application submitted to CNMV or Bank of Spain
👉 Access expert guidance on preparing your MiCA-compliant business plan.
Step-by-Step Roadmap to CASP Licensing
1. Company Formation & Documentation
- Choose and verify company name (1–3 days)
- Register entity via notarized Power of Attorney (up to 2 weeks)
- Provide shareholder/director IDs, proof of address, and criminal record clearance
2. Business Plan & Regulatory Engagement
- Draft or refine a MiCA-compliant business plan
- Schedule a preliminary meeting with CNMV or Bank of Spain to present your model
3. Compliance Development & Capital Adjustment
- Finalize AML/KYC, cybersecurity, and risk management policies
- Increase share capital to meet MiCA class requirements (2 weeks)
4. License Application Submission
- Submit structured application to CNMV or Bank of Spain
- Include all required documentation and internal policies
5. Approval & Post-Licensing Compliance
- Regulatory review period: 3–5 months
- Maintain ongoing compliance through audits, reporting, and policy updates
Advantages of a Spanish CASP License
Spain offers compelling benefits for crypto businesses seeking EU market access:
✅ Fully remote setup – No need to reside in Spain
✅ Fast processing – Ready-made licensed entities available within 1–2 months
✅ Cost-effective operations – Lower maintenance fees compared to other EU jurisdictions
✅ Flexible staffing – AML officers can be EU-based; no physical office required
✅ Broad service scope – License covers exchange, custody, lending, and advisory
✅ Unlimited licenses – No cap on approvals, ensuring open market access
✅ Supportive regulators – CNMV and SEPBLAC offer transparent, business-friendly oversight
Frequently Asked Questions (FAQ)
Q: Can a foreigner obtain a crypto license in Spain?
A: Yes. Foreign individuals can be shareholders. However, the company must appoint a director who is a Spanish or EU citizen.
Q: Is a physical office required for the CASP license?
A: No. A legal address in Spain suffices for registration and licensing. Some banks may request a virtual office lease, which can be arranged.
Q: How long does it take to get a CASP license?
A: From scratch, the process takes 2–3 months for setup plus 3–5 months for approval. With a ready-made entity, transfer can occur within 1–2 months.
Q: What is the minimum capital requirement?
A: While company incorporation requires only €3,000, MiCA mandates €50,000–€150,000 depending on license class before application.
Q: Is a business plan mandatory?
A: Yes. MiCA requires a detailed Programme of Operations outlining your business model, financial projections, governance, and risk controls.
Q: Do existing VASPs need to reapply?
A: Yes. All current VASPs must transition to a MiCA-compliant CASP license by December 2025.
👉 Learn how to seamlessly upgrade your VASP license under MiCA.
Final Thoughts
Securing a CASP license in Spain offers a strategic gateway to the EU’s rapidly evolving crypto market. With clear regulations, flexible requirements, and strong institutional support, Spain is emerging as a top destination for compliant digital asset ventures. Whether launching from scratch or acquiring a ready-made entity, aligning with MiCA now ensures long-term sustainability and regulatory credibility.
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