Spain authorised nine crypto firms. Then a hundred and sixty-two walked in on a passport.
The CNMV publishes the list of everyone entitled to provide crypto-asset services in Spain. We transcribed all 178 entries and counted them. Fifteen are authorised in Spain — nine crypto firms and six banks. The rest are licensed somewhere else in the EEA and serve Spain under the passport. If you are deciding where to licence, that ratio is the most useful number on this page.
Since 1 July 2026 nobody may provide crypto-asset services in Spain without a MiCA authorisation, from the CNMV or from another competent authority in the EEA. The old Banco de España register closed to new entrants on 30 December 2024 and is now kept for information only. That much is widely reported. What is not reported is who actually holds the authorisations, and the answer reframes the whole question of where to licence.
Below is the full register, transcribed from the CNMV list and searchable. Everything after it is what the numbers say once you count them.
Filter by how the entity reaches the Spanish market, by the service you care about, or by home state. The counters above the table follow your filter.
All nine Spanish licences, against the deadline
The transitional period ended on 1 July 2026. Line the nine Spanish CASP authorisations up against that date and the picture is not of a market that prepared early. One firm was authorised with eight months in hand. Five arrived in the final three weeks. Three were authorised only after the deadline had already passed, which means they either stopped providing services in the interval or had not started.
The banks got there before the crypto firms. BBVA was authorised in March 2025, Cecabank and Openbank in July 2025 — all three before the first Spanish crypto firm, Bit2Me, in October 2025. A credit institution does not need a separate CASP authorisation to provide these services, only a notification, and the register shows the six Spanish banks using that route years ahead of the sector they compete with.
Where the licences actually come from
Twenty-one states appear in the register as a home jurisdiction, Spain among them. France leads, then the Netherlands, Malta and Cyprus. Spain, with the fourth-largest economy in the euro area, contributes nine firms.
Foreign entries are firms authorised in that state and passporting into Spain. The Spanish bar counts CASPs authorised by the CNMV and excludes the six credit institutions, which reach the market by notification rather than authorisation.
Why the timing tracks a decision each country made in 2024
MiCA let each member state grant existing crypto firms up to eighteen months to keep trading while they applied. Some took the full eighteen. The Netherlands, Latvia, Hungary, Poland, Slovenia and Finland took six. That choice decided when each country’s firms had to be ready, and the register still shows it.
| Grandfathering the state chose | States in the register | Firms | Median authorisation date |
|---|---|---|---|
| Six months | 4 | 31 | 18 December 2025 |
| Nine to twelve months | 6 | 44 | 16 December 2025 |
| Eighteen months, the maximum | 10 | 87 | 24 June 2026 |
Firms from the six-month states were authorised a full six months earlier, on the median, than firms from the states that took eighteen. Spain took eighteen. Its own firms had no reason to move early, and eight of the nine did not.
Time for incumbents
- Existing Spanish firms kept trading through to mid-2026 without a MiCA file.
- The CNMV could process a small queue slowly rather than a large one badly.
- Nobody was forced out of the market by a calendar.
First-mover advantage, given away
- Firms in six-month states were licensed and passporting across the EEA while Spanish firms were still deciding.
- By the time the second Spanish CASP was authorised in June 2026, 115 foreign firms were already entitled to serve this market.
- Three Spanish firms did not make the deadline at all.
What firms actually asked to be allowed to do
MiCA lists ten crypto-asset services, and an authorisation names the ones you may provide. Counting them across the register shows a market that is far less varied than the ten-item list suggests.
Custody appears in 80 per cent of entries and a trading platform in 8. That distribution has a direct consequence for capital, because the own-funds floor is set by the heaviest service in the set and not by how many you hold.
| Own-funds class | Triggered by | Floor | Entries in the register |
|---|---|---|---|
| Class 1 | Execution, placement, transfer, reception and transmission, advice, portfolio management | 50,000 EUR | 10 |
| Class 2 | Any class 1 service plus custody, exchange for funds or exchange for crypto | 125,000 EUR | 153 |
| Class 3 | Any class 2 service plus operating a trading platform | 150,000 EUR | 15 |
153 of the 178 entries sit in class 2, because custody or an exchange service is in almost every permission set. Only 10 firms stayed inside class 1 and the 50,000 euro floor. In practice the question is not which of three tiers applies to you but whether you touch client assets at all: the moment you do, the floor is 125,000.
Own funds are the higher of the class floor and one quarter of your previous year of fixed overheads. A firm with a compliance team, an office and audited systems passes 125,000 euro of quarterly overheads long before it reaches any scale. Treating the Annex IV figure as the capital requirement is the single most common mistake in the business plans we see, and the CNMV reads the business plan against the overheads test, not against the floor.
So what should you take from this
Do I need a Spanish licence to sell crypto to Spanish customers?
Is the old Banco de España registration still worth anything?
Why are there so few Spanish CASPs?
How much capital do I actually need?
Does a Spanish bank need a CASP licence?
How current is this list?
Nine firms chose Spain. The useful question is whether you should be the tenth.
Scope the application ↗Alexander Baranov
Seventeen years designing and delivering cross-border corporate structures — incorporation, tax, holding, banking and market entry — for founders and companies expanding into Spain and the EU. Author of professional books on entering the Spanish market.
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