Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the Banco de España decision, including banking and payment rails.
Get an EMI license in Spain.
48 million consumers, an instant-payments culture built on Bizum, and the EU licence that doubles as a bridge into Latin America. The Banco de España authorises e-money institutions under Law 21/2011; we build the Spanish file end to end.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Spain in brief
The EU passport with a Latin American accent.
Spain authorises e-money institutions through the Banco de España under Law 21/2011 (as amended by Royal Decree-Law 19/2018, transposing PSD2) and Royal Decree 778/2012. The mechanics are precise: the application is filed through the Banco de España's electronic Virtual Office, SEPBLAC - the anti-money-laundering authority - reports on the file as part of the process, initial capital is the harmonised €350,000, and the statutory window is three months from the moment the documentation is complete. One Spanish particularity deserves respect: if the regulator does not answer within the window, the application is deemed refused - administrative silence works against you, which makes file quality the whole game.
The prize is a double market. At home: 48 million consumers in one of Europe's most advanced retail-payment cultures - Bizum's account-to-account instant payments are a national habit, and a fintech sandbox under Law 7/2020 signals a system that wants new entrants. Abroad: no EU jurisdiction matches Spain's corridor into Latin America - language, banking groups, remittance flows and a 90+ treaty network that runs deepest exactly where LatAm-facing models need it. Realistic end-to-end timelines run 12-18 months; we manage the file in Spanish from our Madrid office.
Banco de España authorisation under Law 21/2011: €350,000 capital, Virtual Office filing, SEPBLAC report inside the process, 3-month window, and silence means refusal.
The prize: 48M consumers, Bizum-grade payment culture, and the EU's only real Latin American corridor. We file in Spanish from our Madrid office.
The two routes
Full EMI - or the payment-institution tier.
One supervisor, two entries: the entidad de dinero electrónico at €350,000 with the full services list, or entidad de pago licences from €20,000. We fix the scope first, then build once.
Full EMI at €350,000 - or PI tiers from €20,000, with the LatAm remittance corridor attached.
01 - ENTIDAD DE DINERO ELECTRÓNICO
E-money institution
The flagship Banco de España authorisation: e-money issuance plus the payment-services list, €350,000 initial capital, safeguarding and EU/EEA passporting. With the SEPBLAC report managed inside the process.
The flagship Banco de España authorisation: e-money issuance plus the payment-services list, €350,000 initial capital, safeguarding and EU/EEA passporting. With the SEPBLAC report managed inside the process.
- ✓E-money issuance and distribution
- ✓Full PSD2 payment-services list
- ✓€350,000 initial capital · own funds ongoing
- ✓Safeguarding of client funds
- ✓EU/EEA passport on notification
- ✓3-month statutory window from complete
02 - ENTIDAD DE PAGO ROUTES
The LatAm corridorPayment institution routes
Payment-institution licences run €20,000-€125,000 by service. Remittance to acquiring. With account information services alongside. For LatAm-facing remittance models, Spain is the natural EU home.
PI licences €20k-€125k; remittance, acquiring, AIS; upgrade path to the EMI.
- ✓PI licences - €20k / €50k / €125k by service
- ✓Money remittance - the LatAm corridor
- ✓Acquiring and transfers
- ✓Account information services
- ✓Upgrade path to the EMI
- ✓Same Banco de España supervision
Costs and timelines are confirmed for your case before any work begins. Banco de España process runs through its Virtual Office; capital, safeguarding and substance costs are itemised in your quote.
Why Spain
Two markets for one licence.
The framework is EMD2/PSD2 under the Banco de España. Attached to Europe's fourth-largest economy and the EU's only true Latin American gateway.
✓
48 million consumers
Europe's fourth-largest economy with one of its most digital retail-payment cultures. Bizum made account-to-account instant payments a national habit merchants and users expect.Bizum made instant payments a habit.
✓
The Latin American bridge
Language, banking groups, remittance corridors and treaties - no EU licence sits closer to LatAm flows. For models serving both markets, Spain is the obvious EU seat.Language, banks, corridors, treaties.
✓
A precise, published process
Virtual Office filing, a SEPBLAC report inside the procedure and a three-month window from completeness. The steps are codified, which rewards a file built right the first time.Virtual Office; SEPBLAC inside.
✓
The sandbox signal
Spain's fintech sandbox under Law 7/2020 gives novel models a supervised testing track, and signals a system that wants payments innovation onshore.Law 7/2020 - innovation onshore.
✓
EU passport
One Banco de España authorisation notifies into every EU/EEA state. The single market from Madrid, with LatAm corridors attached.Single market on notification.
✓
PSD3-ready files
With PSD3/PSR close to adoption, e-money folds into the unified payment-institution regime. We structure Spanish files to convert rather than be rebuilt.Built to convert, not rebuild.
How it compares
How Spain differs from other routes.
Spain trades queue speed for market depth and the LatAm corridor. The side-by-side comparison is below.
Spain vs other jurisdictions
| Feature |  Spain | Other jurisdictions |
|---|---|---|
| Regulatory regime | Law 21/2011 - Banco de España | Same directives, other desks |
| Home market | 48M consumers + LatAm corridor | Mostly passport-dependent |
| Silence rule | Deemed refusal - file quality decides | Varies |
| Timeline | 12-18 months realistic | 6-12 at specialised desks |
Regulatory regime
SpainLaw 21/2011 - Banco de España
Other jurisdictionsSame directives, other desks
Home market
Spain48M consumers + LatAm corridor
Other jurisdictionsMostly passport-dependent
Silence rule
SpainDeemed refusal - file quality decides
Other jurisdictionsVaries
Timeline
Spain12-18 months realistic
Other jurisdictions6-12 at specialised desks
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Spain | EMI (Banco de España) | 25% CIT · new 15% | Spanish file, SEPBLAC report |
 Lithuania | EMI (Bank of Lithuania) | 17% CIT (2026) | CENTROlink, specialised desk |
 Ireland | EMI (CBI) | 12.5% CIT trading | Engagement-led, 12+ months |
 Germany | EMI (BaFin) | ~30-33% effective | German file, dual supervision |
SpainLicense typeEMI (Banco de España)
Taxation25% CIT · new 15%
RequirementsSpanish file, SEPBLAC report
LithuaniaLicense typeEMI (Bank of Lithuania)
Taxation17% CIT (2026)
RequirementsCENTROlink, specialised desk
IrelandLicense typeEMI (CBI)
Taxation12.5% CIT trading
RequirementsEngagement-led, 12+ months
GermanyLicense typeEMI (BaFin)
Taxation~30-33% effective
RequirementsGerman file, dual supervision
Before you apply
Requirements for the Banco de España authorisation.Requirements for the authorisation.
The law and its implementing decree publish the file's contents, and the silence rule makes completeness existential. The checklist below is what a passing application contains.
01
Spanish entity. An S.L. or S.A. with its registered office and effective management in Spain.
02
Initial capital - €350,000 for the EMI, evidenced and paid in; €20,000-€125,000 for PI tiers.
03
Fit and proper management and holders. Competence, clean records and ownership transparent to UBOs.
04
Programme of operations. Services, volumes, three-year financials and unit economics the supervisor can interrogate.
05
Safeguarding. Segregated client-fund accounts or insurance, with documented reconciliation.
06
AML/CFT framework. KYC, monitoring and SEPBLAC reporting with a resident compliance officer; the SEPBLAC report is part of the authorisation itself.
07
IT and security documentation. Architecture, DORA-grade resilience and incident procedures.
08
Internal governance. Control functions, outsourcing register and conflicts procedures.
09
Own-funds methodology. The ongoing capital calculation, modelled forward.
10
Spanish-language file. The application and annexes drafted and defended in Spanish, through the Virtual Office.
01
Spanish S.L./S.A., managed locally.
02
€350,000 capital (EMI).
03
Fit & proper holders to UBOs.
04
Interrogable programme of operations.
05
Safeguarding with reconciliation.
06
SEPBLAC-proof AML with resident officer.
07
DORA-grade IT documentation.
08
Governance and outsourcing register.
09
Own-funds method modelled forward.
10
Full file in Spanish, via Virtual Office.
Reflects Law 21/2011, RD-Law 19/2018, RD 778/2012 and Banco de España procedure as of 2026.Law 21/2011 + RD 778/2012 + BdE procedure, as of 2026.
How it works
From first call to the Banco de España register.
01
Route and strategy
EMI or PI tier, home-market or LatAm-corridor weighting. We fix the scope, capital and timeline in writing.EMI or PI; home vs LatAm weighting.
02
Spanish company and people
S.L. formation, capital evidence and the resident officers the supervisor vets.S.L., capital, resident officers.
03
The application file
Programme, safeguarding, AML and IT documentation in Spanish. Complete before filing, because silence works against you.Complete first time - silence rule.
04
Banco de España review
Virtual Office filing, the SEPBLAC report, question rounds. Three months statutory from complete, 12-18 months realistic.3 months statutory; 12-18 realistic.
05
Authorisation and launch
The register entry, passport notifications and the reporting calendar. Live in Spain, pointed at two continents.Register, passports, two continents.
Quick facts
RegulatorBanco de España
EMI capital€350,000
PI tiers€20k / €50k / €125k
FilingVirtual Office · in Spanish
AML reportSEPBLAC - inside the process
Statutory window3 months · silence = refusal
Realistic timeline12-18 months
PassportEU/EEA on notification
Administrative silence means refusal in Spain. The file must be complete and convincing the first time. That is our job.
On the ground in Spain
Run from our Madrid office.
Prifinance - Spain
Madrid · Spain
Madrid, Spain
01
Spanish company formation
S.L. incorporation, capital placement and the corporate layer the Banco de España expects. Structured for the licence from day one.S.L. + capital, structured for the file.
02
The BdE file - in Spanish
Programme of operations, safeguarding design, AML pack and IT documentation drafted natively in Spanish and filed through the Virtual Office. Built to survive the silence rule.Drafted natively; silence-proof.
03
SEPBLAC-proof AML
The anti-money-laundering authority reports on your file inside the process. Our AML packs are drafted for that reader from the first page.Written for the second reader.
04
Substance and staffing
Resident directors, compliance officer and MLRO from Madrid's and Barcelona's deep talent pools. Real substance the supervisor recognises.Madrid/Barcelona talent, real ops.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Spain.
Standard southern-European numbers with a genuine startup gift: 15% for new companies' first two profitable years, and a treaty network that runs deepest into Latin America.
Corporate tax 25%
The standard rate on an EMI's fee and float income. With consolidated-group and R&D regimes that model well for platform businesses.Standard rate; groups model well.
New companies 15%
Newly created companies pay 15% in the first tax period with profit and the next. A real two-year runway subsidy for licensed startups.First two profitable years.
VAT-exempt payment services
Payment and e-money services are VAT-exempt financial services; the 21% standard rate touches only ordinary supplies.21% only on ordinary supplies.
The LatAm treaty network
90+ treaties overall, and the EU's deepest coverage of Latin America, which is exactly where Spain-seated remittance and payout models need relief.Deepest EU coverage - 90+.
Founder relocation - Beckham
Qualifying inbound executives can elect a 24% flat rate for six years under the impatriate regime. Founder-level economics we model alongside the corporate plan.Six years, inbound founders.
Dividends 19%
19% withholding on outbound dividends, reduced by treaties and eliminated intra-EU under the Parent-Subsidiary Directive for qualifying holdings.Treaty and EU-directive relief.
Tax summary
Corporate tax25%
New companies15% · first 2 profit years
VAT on payment servicesExempt
Standard VAT21%
Dividend withholding19% · treaty/EU relief
Impatriate regime24% flat · 6 years
Tax treaties90+ · deepest into LatAm
*Figures as of 2026 per the Agencia Tributaria. Group, R&D and impatriate outcomes are modelled per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Spanish S.L., AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised institution.
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Spain · Banco de España
Launch your payment project in Spain with expert support.
Full-service assistance - from S.L. registration to the Banco de España authorisation, passporting and ongoing compliance.
Get a consultation →Free legal opinion
Is Spain the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Spanish EMI licence: quick answers.
What licence does an e-money business need in Spain?+
An entidad de dinero electrónico authorisation from the Banco de España under Law 21/2011 - €350,000 initial capital, safeguarding and EU/EEA passporting. Payment-institution licences at €20,000-€125,000 sit alongside.
How long does licensing take?+
Three months statutory from complete documentation, and if the window passes without an answer, the application is deemed refused. Realistic end-to-end: 12-18 months. The silence rule makes first-time completeness the whole strategy.
What is SEPBLAC's role?+
Spain's AML authority reports on your application as part of the authorisation procedure itself - the AML framework is not a formality but a reviewed component. We draft the pack for that reader from the start.
What does it cost?+
The process runs through the Banco de España's Virtual Office; the real investment is capital (€350,000 EMI), substance and the file - all itemised in your quote before we start.
Why is Spain strong for Latin America-facing models?+
Language, banking relationships, remittance corridors and the EU's deepest LatAm treaty coverage. A Spanish EMI serves the single market with passporting and LatAm flows with infrastructure no other EU seat matches.
What substance is expected?+
A Spanish S.L. effectively managed in Spain, resident directors and compliance officer, real safeguarding arrangements and DORA-grade systems documentation - reviewed by both the central bank and SEPBLAC.
How are payment companies taxed?+
25% corporate tax - 15% for new companies' first two profitable years - with VAT-exempt payment services, 19% dividend withholding subject to treaty and EU relief, and the impatriate regime at founder level.
Does the licence passport across the EU?+
Yes - the authorisation notifies into every EU/EEA state. Spain-seated institutions typically run the single market plus the LatAm corridor from one licence.
What changes under PSD3?+
PSD3 and the PSR - provisionally agreed in November 2025 and close to formal adoption - fold e-money institutions into a unified payment-institution regime. Files we build now are structured to convert.
Why Spain rather than Lithuania?+
Lithuania wins on speed and CENTROlink; Spain wins where the model needs its markets - 48 million consumers at home and the LatAm corridor abroad. Remittance and payout businesses pointed south-west usually belong in Madrid.
What licence is needed?+
BdE EMI - €350k; PI €20k-€125k.
How long?+
3 months statutory; 12-18 realistic.
Silence rule?+
No answer = refusal. Completeness decides.
SEPBLAC?+
Reports on your file inside the process.
Cost?+
Virtual Office process; capital is the investment.
Substance?+
Resident officers, real Spanish ops.
Taxes?+
25% CIT; 15% new cos; VAT-exempt.
LatAm?+
The EU's only real corridor. Yes.
PSD3?+
Agreed Nov 2025 - files convert.
Vs Lithuania?+
Their desk speed; your two markets.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
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Google
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.Free legal opinion: which Spanish route fits your project and what it will cost.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Banco de España or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.