The rise of digital assets has transformed the financial landscape across Europe, and Spain has taken a proactive approach in regulating cryptocurrency service providers. For companies looking to operate a crypto exchange in Spain, understanding the legal framework and compliance requirements is essential. This guide breaks down everything you need to know about obtaining a crypto exchange license in Spain, including regulatory foundations, eligibility criteria, required documentation, and practical steps for registration.
What Is a Crypto Exchange Service in Spain?
A crypto exchange (or trading platform) is a digital marketplace that enables users to buy, sell, or trade cryptocurrencies—either for fiat currency (like EUR) or other digital assets. These platforms may also support trading of tokenized financial instruments such as digital securities or stablecoins.
The primary purpose of these services is to facilitate liquidity and market participation in the growing digital asset economy. By enabling seamless conversion between traditional money and crypto, exchanges play a vital role in driving adoption and financial innovation.
In Spain, entities offering such services must comply with strict anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. This is where the VASP license comes into play.
Understanding the VASP License in Spain
VASP stands for Virtual Asset Service Provider, a term defined under EU and Spanish financial regulations. In Spain, the VASP framework specifically applies to businesses that:
- Exchange virtual currencies (e.g., Bitcoin, Ethereum) for fiat currencies (e.g., EUR), or vice versa.
- Operate as custodians of crypto assets.
- Facilitate transfers of digital assets on behalf of clients.
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Obtaining a VASP license in Spain does not grant full banking or investment firm status. It is a registration-based regime focused on transparency and AML compliance rather than prudential supervision. The goal is to protect consumers, prevent illicit financial flows, and integrate crypto businesses into the formal economy.
Legal Framework: Where Is the VASP Registration Regulated?
The regulatory foundation for crypto exchange licensing in Spain is established through several key laws:
- Law 10/2010, of April 28, on the Prevention of Money Laundering and Terrorist Financing (LBCFT).
- Royal Decree-Law 7/2021, of April 27, which amended Law 10/2010 to include virtual asset service providers.
- Royal Decree 304/2014, of May 5, which details the implementation of AML measures.
Under Additional Provision Two of Law 10/2010, any individual or company offering virtual-to-fiat exchange services in Spain must register with the Bank of Spain as a VASP. This obligation applies regardless of the provider’s nationality or where its users are located—as long as the business activity is directed at the Spanish market.
Who Must Register?
Registration is mandatory for:
- Individuals or legal entities (regardless of nationality) providing crypto-fiat exchange services in Spain.
- Companies headquartered or managed from Spain, even if their customers are abroad.
- Legal entities established in Spain offering crypto-related services.
Importantly, this registration requirement applies even if the entity is already authorized under another financial regulation.
How to Apply for a Crypto Exchange License in Spain
To begin the licensing process, applicants must submit their request to the Bank of Spain through one of the following methods:
- Electronically – Mandatory for legal entities.
- By postal mail
- In person – Only available for individuals at the Bank of Spain’s central registry or regional branches.
Once submitted, the Bank of Spain has three months to review and issue a decision on the application.
While the process is administrative rather than judicial, it is rigorous. Approval depends on compliance with AML protocols and proof of professional integrity.
Key Requirements for VASP Registration
To qualify for registration, applicants must meet two core conditions:
- Establish adequate internal AML/CFT prevention systems
- Demonstrate commercial and professional honorability
1. Internal AML Prevention Mechanisms
All registered VASPs must implement robust internal controls to detect and prevent financial crime. This includes:
- Appointing a dedicated Internal Control Body (OCI) responsible for monitoring compliance.
- Designating a legal representative who will liaise with SEPBLAC, Spain’s Financial Intelligence Unit (part of the Bank of Spain).
- Developing a comprehensive Anti-Money Laundering and Counter-Terrorist Financing Manual, detailing policies, risk assessments, reporting procedures, and employee training protocols.
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2. Honorability Requirements
Under Article 30 of Royal Decree 84/2015, individuals in effective control of the company must demonstrate professional integrity. Factors considered include:
- Past conduct with financial regulators
- Criminal convictions or administrative sanctions
- Nature (intentional vs. negligent) and severity of any offenses
- Whether penalties are final or under appeal
- Relevance of misconduct to financial services (e.g., fraud, tax evasion, consumer protection violations)
- Ongoing investigations into economic crimes or breaches of financial regulations
- Evidence of rehabilitation or mitigating circumstances
Failure to meet these standards can result in rejection or removal from the registry.
Required Documentation for Application
To complete the registration process, applicants must submit the following documents:
- AML/CTF Prevention Manual: A detailed document outlining internal procedures, risk mitigation strategies, employee roles, and reporting lines.
- Risk Assessment Report: A comprehensive analysis identifying potential money laundering and terrorist financing risks associated with the business model, customer base, and geographic reach.
- VASP Registration Form: Official form for enrollment in the Bank of Spain’s provider registry.
- Suitability Evaluation Form: Completed and signed by both the legal entity and all individuals exercising effective management.
- Criminal Record Certificate: A clean police certificate (penal clearance) issued no more than three months prior to submission—for both the company and each managing individual.
All documents must be submitted in Spanish and may require notarization or apostille if issued abroad.
Frequently Asked Questions (FAQ)
Q: Is a VASP license the same as a full crypto banking license in Spain?
A: No. The VASP registration is an AML-focused compliance requirement, not a financial license allowing deposit-taking or investment services.
Q: Can non-EU companies apply for a crypto exchange license in Spain?
A: Yes, foreign companies can register as long as they conduct business in Spain or target Spanish residents.
Q: How long does it take to get approved?
A: The Bank of Spain has up to three months to respond after receiving a complete application.
Q: Do I need physical office space in Spain?
A: While not explicitly required, having a local presence strengthens your application and supports ongoing compliance obligations.
Q: Are there ongoing reporting requirements after registration?
A: Yes. Registered VASPs must report suspicious transactions to SEPBLAC and update their risk assessments regularly.
Q: Can I offer derivatives or lending services with a VASP license?
A: No. These activities fall under separate financial regulations and require additional authorization from CNMV (Spain’s securities regulator).
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Final Thoughts
Obtaining a crypto exchange license in Spain is a critical step for any business aiming to operate legally in one of Europe’s most dynamic fintech markets. While the registration process is less complex than obtaining full financial institution status, it demands serious attention to compliance, governance, and transparency.
By meeting AML standards and demonstrating professional integrity, companies can gain legitimacy, build trust with users, and position themselves for long-term growth in the European digital asset ecosystem.
Whether you're launching a new exchange or expanding an existing platform into Spain, starting with proper regulatory alignment ensures sustainable success in this rapidly evolving industry.
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