MiCA CASP authorisation in Spain (CNMV)

Why teams look at Spain

Spain is one of the EU’s largest consumer markets and an active crypto market. Under MiCA’s crypto-asset service provider regime, applying from 30 December 2024, the Comision Nacional del Mercado de Valores (CNMV) is the authorising authority, with Banco de Espana involved on prudential matters. The CNMV began accepting CASP applications early and has been active on crypto advertising and influencer-promotion rules, so plan for a marketing-aware supervisor.

This page is informational and does not replace legal, regulatory, or tax advice. Confirm current requirements, forms, fees, and timelines directly with the CNMV before acting.

The authorisation route

A firm that is not already an EU-authorised financial entity applies to the CNMV for authorisation as a CASP under Article 62. A firm already authorised under EU financial law can use the lighter Article 60 notification.

Under Article 63 the CNMV has 25 working days to confirm completeness and then 40 working days to decide once the file is complete. Spain applied a transitional period for existing providers running toward 1 July 2026; confirm your exact position with the CNMV.

What the CNMV expects

Local substance

A registered office in Spain and management effectively based there under Article 59(2).

Marketing and conduct

The CNMV has been active on crypto advertising and influencer promotions. Expect attention to marketing, risk disclosure, and the conduct obligations in Article 66.

Custody and client assets

Segregation, reconciliation, a custody policy, and strict liability for loss under Article 75 where you hold client crypto-assets or the means of access.

Prudential safeguards

Own funds, an insurance policy, a comparable guarantee, or a mix under Article 67, at the higher of the class minimum or one quarter of fixed overheads.

Capital and the Article 67 question

The minimum is 50,000 euro, 125,000 euro, or 150,000 euro depending on the services you are authorised for, or one quarter of the previous year’s fixed overheads if higher. If you are weighing insurance against capital, build the evidence first: see the CASP insurance evidence pack and own funds vs insurance.

Transitional path

Firms operating under Spain’s pre-MiCA regime transition onto MiCA through a process the CNMV manages. Spain applied a transitional window running toward mid-2026; confirm the current cut-off date and the exact transition steps with the CNMV.

Transitional dates have moved at the member-state level. Confirm any date against current CNMV guidance before planning around it.

FAQ

Is a Spain CASP licence valid across the EU?

Yes. A CASP authorisation passports to all 27 member states under Article 65. You authorise in Spain and notify the host states before providing services there.

Does Spain have strict crypto marketing rules?

The CNMV has been active on crypto advertising, including influencer promotions. Plan marketing and risk disclosures carefully and confirm the current rules with the CNMV.