How to get a crypto license in Spain

How to get a crypto license in Spain (VASP / CASP via MiCA)

Want to legally work with cryptocurrency in Europe? Spain is one of the most promising, but also the most difficult markets to obtain a CASP (Crypto-Asset Service Provider) license. We know how to go all the way - and avoid mistakes that cost years.

Jurisprudential Consulting Group accompanies clients in obtaining crypto licenses from scratch: from the structure and AML documents to the DORA audit and approval by the National Bank of Spain. Do you want to work on the European market legally? We will help you do it right.

Consultation cost from 250 Euro

Since 2023, as part of the transition to MiCA, Spain has had a provisional registration regime for virtual asset providers (VASPs) in place , which will be replaced by CASP licenses in 2025.

What is a crypto license in Spain and who issues it?

The responsible regulator is Banco de España (the National Bank of Spain). It maintains the Register of Virtual Asset Service Providers (Registro de Proveedores de Servicios de Criptoactivos) and accepts applications for registration.

Who is required to obtain a VASP/CASP license?

1. Exchange platforms (crypto-fiat, fiat-crypto)
2. Custody providers (storage of assets)
3. P2P platforms, if they take a commission
4. OTC desks
5. Crypto ATMs
6. Companies that transfer/exchange crypto assets on behalf of the client
7. Fintechs and marketplaces with internal tokenization
8. NFT and DeFi providers if they manage assets

What are the requirements for obtaining a license in Spain?

Legal form : Spanish Sociedad Limitada (SL)

Director : Preferably a citizen of Spain (if a residence permit, only with a strong dossier and resume)

Office : A real office in Spain (coworking is possible, but not a virtual address)

Staff :

• Director General
• AML/CTF officer (cumplimiento normativo) with Spanish diploma or experience
• Financial Director (optional but desirable)

AML policies and DORA audit

To obtain a crypto license in Spain, you must:

• Develop AML/CTF policies (in Spanish), including:
  • KYC Policy
  • Suspicious Transaction Detection Policy
  • Internal procedures for employees
• Assign responsible officer for the prevention of money laundering
• Conduct DORA audit (Digital Operational Resilience Act), if a CASP license is planned under Mica:
  • IT infrastructure analysis
  • Incident Response Plan
  • Backups, data protection
  • Cyber risk audit

Registration procedure (stages)

1. Establishment of a company (SL) with authorized capital (read below about authorized capital)
2. Opening a bank account (or EMI) for crypto transactions
3. Preparing a dossier:
   • Charter
   • Contracts.
   • AML policies
   • Business plan
   • Information about shareholders and directors
4. Application to Banco de España:
   • Filling in the registration form
   • Attachment of all documents
   • Fit & proper test
5. The intermediate waiting period is 6-12 months
6. Registration in the Supplier Register
7. Transition to MiCA after 2025 (automatic or with modifications)

The minimum capital requirements for obtaining a CASP license under MiCA in Spain depend on the type of services provided:

— 150 euros — if the company is engaged in the storage and management of cryptocurrencies on behalf of clients (custodial wallet provider);

We offer a solution at the level of international standards

— 125 euros — if the activity includes the exchange of cryptocurrency for fiat and vice versa (crypto-fiat exchange);

— €50–€000 — if the company provides other services, such as transmitting client orders, providing investment advice, acting as a broker, or providing access to markets without storing assets.

These amounts refer to the minimum share capital (capital social mínimo) and must be deposited into the Spanish company's account before applying for a license.

Main CNAE (Spain):

1. CNAE 6612 – “Otras actividades auxiliares a los servicios financieros, excepto seguros y fondos de pensiones” — Used for companies operating in the field of financial technologies, currency exchange, mediation, including cryptocurrency platforms.
2. CNAE 6209 – “Otros servicios relacionados con las tecnologías de la información y la informática” — Suitable for companies providing digital services, including blockchain development and smart contracts.
3. CNAE 6499 – “Otros servicios financieros, excepto seguros y fondos de pensiones ncop” — The most commonly used code for cryptocurrency companies (including VASP, CASP, exchangers, custodial wallets). It is a kind of universal code.
4. CNAE 6611 – “Administration of mercados financieros” — Applicable when creating a crypto exchange or platform that executes clients’ orders.

How long does the process take?

In practice, it takes between 12 and 24 months , despite the official stated timeframe of 3–6 months. This is due to Banco de España's overload and the lack of transparent deadlines.

What is important to remember:

1. In Spain It is not officially stated anywherethat the director must be a citizen - but in reality Foreigners with a residence permit receive refusals or “eternal waiting”
2. Even after registration, the company may be limited in operations, unless it proves technical and operational readiness
3. The website, interface, terms of use, customer contracts - everything must be localized in Spanish
4. Internal cash discipline is needed: client funds reporting, accounting system, external data storage

Why is this possible with us?

Jurisprudential Consulting Group:

• ✅ supports licenses in Poland, Estonia, Spain, Czech Republic and Bulgaria
• ✅ knows real cases of refusals and blockings (and how to bypass them)
• ✅ has a team of lawyers, accountants, AML specialists
• ✅ develops complete dossiers: from charter to DORA audit

Want to assess your chances of getting a crypto license in Spain?

Sign up for a strategic consultation - we will analyze the structure, show the way, and give calculations.