Every crypto company operating in Spain faces the same hard deadline: July 1, 2026. From that date, the EU's MiCA regulation enters full enforcement. Operating without a CASP (Crypto-Asset Service Provider) license issued by the CNMV is a criminal offense in all 27 EU member states, with fines of up to €5 million per violation.

The Banco de España VASP registry — which governed Spanish crypto operators since 2021 — was formally abolished on December 30, 2024. The old registration is no longer sufficient. Every exchange, custodian, wallet provider, and crypto advisory firm in Spain needs a MiCA CASP authorization before the deadline.

This checklist covers every requirement. Use it to assess your current compliance status and prioritize what to tackle first.

Deadline Milestone
Jul 1, 2026 MiCA Full Enforcement
Mar 31, 2027 Modelo 173 Annual Filing
Sep 30, 2027 DAC8 Implementation

What Is a CASP License?

A CASP license is a full financial services authorization under MiCA (EU Regulation 2023/1114). It replaces the former VASP registration and grants an EU passport — meaning one CNMV authorization lets you operate in all 30 EEA countries without separate national applications.

The key difference from the old Banco de España registration: a CASP license requires minimum capital, segregated client assets, whitepaper disclosures, market abuse surveillance, and ongoing regulatory reporting. It is not an AML registration — it is a license equivalent to a brokerage or payment institution authorization.

First Mover

Bit2Me (BITCOINFORME S.L.) became the first Spanish-speaking fintech to receive CNMV CASP authorization in July 2025. Criptan followed in March 2026. The CNMV application queue is growing — earlier applications receive earlier reviews.

Step 1: Determine Which CASP Services You Provide

MiCA authorizes specific crypto-asset services. Your license covers only the services you apply for. Identify every service your firm currently offers or plans to offer:

Step 2: Meet Minimum Capital Requirements

Capital under MiCA is a permanent floor — not a one-time deposit. Your firm must maintain it continuously and report to CNMV if it falls below threshold.

ServicesMinimum Capital
Advice + order reception/transmission only€50,000
Execution, exchange, portfolio management€125,000
Custody and safekeeping€150,000
Operating a trading platform€150,000

Step 3: Build Your Governance Framework

MiCA requires a "robust organizational structure" before the CNMV will approve an application. This is typically the longest step for startups and fintechs that have grown informally.

Common Rejection Reason

CNMV applications are most frequently rejected or delayed due to insufficient governance documentation — specifically, the absence of a dedicated compliance officer and undocumented conflict-of-interest policies. Address these before submitting.

Step 4: Client Asset Segregation

MiCA prohibits CASPs from using client assets for their own account. Segregation must be operational, documented, and auditable before the CNMV review.

Step 5: AML/KYC Framework (SEPBLAC)

Under MiCA, licensing supervision moved to CNMV — but AML/KYC supervision remains with SEPBLAC under Law 10/2010. Both must be satisfied simultaneously. SEPBLAC has been actively fining crypto firms for KYC deficiencies since 2024.

Step 6: Whitepaper Requirements

If your platform issues tokens, runs an ICO, or is the first to admit a crypto-asset to trading, MiCA requires a whitepaper. This is separate from the CASP license application but enforced simultaneously.

Step 7: Ongoing Reporting Obligations

A CASP license is not a one-time event. It creates permanent reporting obligations to three Spanish authorities. Failure to file on time attracts automatic penalties.

AEAT Tax Reporting (Modelo 172/173/721)

CNMV Prudential Reporting

DAC8 (EU Cross-Border Reporting) — effective Sep 2027

Step 8: Submit to CNMV

The formal CNMV application requires a specific set of documents. Incomplete applications are returned — the 3-month review clock does not start until the CNMV confirms completeness.

Timeline Reality Check

The formal CNMV review is 3 months. Preparation of a complete application typically takes 6–12 months. If you have not started, the July 1, 2026 deadline is functionally out of reach for a first-time applicant. Focus immediately on what you can control: capital adequacy, governance appointments, AML framework, and engaging a MiCA-specialized legal advisor.

Post-License: Ongoing Compliance

Receiving a CASP license is not the finish line. MiCA compliance is a continuous operation:

Most firms underestimate post-license compliance costs. A dedicated compliance FTE costs €60,000–€90,000/year in Spain. Automated monitoring infrastructure (like SENTINEL) runs a fraction of that while covering more regulators and jurisdictions.

Frequently Asked Questions

What is the deadline to obtain a CASP license in Spain?

July 1, 2026. After that date, unauthorized operation is a criminal offense in all 27 EU member states. Fines reach €5 million per violation. Firms that had VASP registrations with the Banco de España before December 30, 2024 may operate under the transitional regime until they are granted or denied a CNMV CASP license.

What is the minimum capital requirement for a CASP license in Spain?

Capital requirements vary by service: €50,000 for advice and order reception/transmission; €125,000 for execution, exchange, and portfolio management; €150,000 for custody and trading platforms. These are permanent capital floors maintained continuously.

Which authority issues CASP licenses in Spain?

The CNMV (Comisión Nacional del Mercado de Valores) is the competent authority for CASP licensing under MiCA. AML/KYC supervision remains separately with SEPBLAC under Law 10/2010.

Can a company registered with Banco de España continue operating after July 2026?

No. The Banco de España VASP registry was abolished on December 30, 2024. Companies registered before that date operate under transitional rules only — they must obtain a CNMV CASP license before July 1, 2026, or cease operations.

How long does the CNMV CASP license application take?

The formal CNMV review period is 3 months from a complete application. In practice, preparation takes 6–12 months. Firms targeting the July 1, 2026 deadline should have submitted complete applications by Q1 2026 at the latest.

What tax reporting obligations come with a CASP license in Spain?

CASPs in Spain must file Modelo 172 (quarterly transaction reporting), Modelo 173 (annual transaction summary), and Modelo 721 (foreign crypto-asset holdings disclosure) with the AEAT. All require machine-readable XML format. DAC8 cross-border reporting applies from September 2027.

Does a CASP license from CNMV let me operate across the EU?

Yes. A CNMV CASP authorization is an EU passport under MiCA, valid in all 30 EEA countries. You notify the relevant national competent authority in each country you plan to operate — no additional full license applications required.