Currency exchange licence in Spain (bureau de change): the Banco de España authorisation

The case, in five lines

What is brought

Application to the Banco de España (Spain's central bank) for authorisation to buy and sell foreign banknotes and traveller's cheques at premises open to the public (articles 2.2, 3 and 4 of Royal Decree 2660/1998), or only to buy them against payment in euros (article 2.1), followed by entry in the Registro de establecimientos de cambio de moneda (the register of currency exchange establishments). If refused, expressly or by silence, a recurso de alzada (administrative appeal) to the Minister for Economy, Trade and Business and, against the Minister's decision, a judicial review claim.

Before which court

The Banco de España grants authorisation after a report from SEPBLAC (Spain's financial intelligence unit) (article 3.1 of Royal Decree 2660/1998); its Secretary General decides under powers delegated by the Comisión Ejecutiva (Executive Committee) (Resolution of 23 March 2026). A refusal does not exhaust administrative remedies: a recurso de alzada lies to the Minister (article 3.1; article 2.2 of Law 13/1994) and, against the Minister's decision, a claim lies to the Sala de lo Contencioso-administrativo (Contentious-Administrative Chamber) of the Audiencia Nacional (National High Court), in sole instance (article 2.3), not to the Tribunal Superior de Justicia de Madrid (Madrid High Court of Justice). The prior attempt at negotiation under article 5 of Organic Law 1/2025 does not apply: it governs only civil and commercial proceedings.

Deadline

Three months from the date the application is received by the Banco de España; if no decision is notified, it is deemed refused (article 3.2 of Royal Decree 2660/1998), although requests for information and the SEPBLAC report may suspend the clock (article 22.1 of Law 39/2015, the Administrative Procedure Act, LPAC). Once authorised, six months from notification to execute the deed of incorporation of the sociedad anónima and register it (article 4.2.a). Recurso de alzada within one month of an express refusal, or at any time against a deemed refusal (article 122.1 LPAC); judicial review within two months of notification of the Minister's decision (article 46.1 of the LJCA, the Contentious-Administrative Jurisdiction Act).

Who can bring it

For buying and selling, the applicant is the sociedad anónima (public limited company) in formation, acting through its promoters: it is authorised before it exists and is incorporated only afterwards. For buying only, any natural or legal person may apply, including a sole trader or a sociedad limitada (private limited company), as its sole activity or alongside its main business. Any appeal is brought by the applicant.

Financial risk

If refused, months are lost, although you may reapply. Opening before registration means exchanging currency without authorisation: the Banco de España requests information, inspects and imposes penalties (article 13 of Royal Decree 2660/1998), and failing to cooperate is a very serious infringement (fourth additional provision of Law 10/2014). Once authorised, the 60,000 euros must be maintained as net assets at all times, and the authorisation may be revoked if business does not start within twelve months of registration or is interrupted for more than twelve. Money laundering fines start at 60,000 euros for serious infringements and at 150,000 for very serious ones.

Buying banknotes or selling them too: two different authorisations

Royal Decree 2660/1998 makes the professional activity of currency exchange at premises open to the public subject to authorisation by the Banco de España (Spain's central bank); that activity consists of buying or selling foreign banknotes and traveller's cheques (article 1.1), and only banks and other credit institutions fall outside it (article 1.2). What the rules regulate is the service to the public: buying and selling currency for your own account, without serving third parties, is not a regulated activity, as the Dirección General de Seguridad Jurídica y Fe Pública (the Directorate General for Legal Certainty and Public Faith) noted on 16 December 2021. Your premises by the port, open to tourists, are squarely within the rules.

The first decision is whether you will only buy. Buying foreign banknotes or traveller's cheques against payment in euros may be done by any natural or legal person, including a sole trader or a sociedad limitada (private limited company), as its sole activity or alongside another business, such as a hotel or a travel agency (article 2.1). It requires only good repute (article 4.1), which is presumed if the premises of the main business are already operating (article 4.3), and it is applied for on a dedicated form: FDU-156 for natural persons and FDU-159 for legal persons.

But the tourist who arrives with euros and wants dollars is buying banknotes from you: that is a sale, which the rules define as delivering foreign banknotes against euros or other banknotes (article 2.3), and it triggers all the requirements of article 4. Anyone who starts by buying only and later wants to sell needs a new authorisation and must meet the whole of article 4.2 (article 5.5). It is a small, closely watched market: at 31 December 2025 there were 17 currency exchange establishments on the register, not counting those that only buy, and that year the Banco de España opened 54 inquiries into signs of reserved activities being carried on without a licence, currency exchange among them. Buying a bureau that is already authorised is another route, which we cover in the case ‘Buy a licensed payment institution in Spain or a currency exchange house’.

Public limited company, exclusive purpose and 60,000 euros: the exact requirement

To sell banknotes, the holder must be a sociedad anónima (public limited company) incorporated by simultaneous foundation (article 4.2.a): neither a natural person nor a sociedad limitada can obtain this authorisation, so the private limited company you already have will not do for buying and selling. Its corporate purpose must be solely the purchase and sale of foreign banknotes and traveller's cheques, unless the company is a payment institution or an electronic money institution (article 4.2.b, as worded by Royal Decree 84/2015). The draft articles of association include those provisions and are accompanied by a certificate from the Registro Mercantil (the Companies Registry) that the proposed name is not already taken (article 5.3.a).

Minimum share capital is 60,000 euros, fully subscribed and paid up in cash, in registered shares (article 4.2.c): the premises, the furniture or the safe do not count as contributions. What almost nobody reads is that the figure is required at all times as net assets, calculated as for a capital reduction or a dissolution (article 2.2 of the Order of 16 November 2000; rule six.1 of Circular 6/2001). A first year of losses that takes net assets below the minimum is a breach of a condition of the authorisation, which is a ground for revocation (article 9.1.c). That is why the projections are built with headroom above the minimum.

Shareholders, directors and the general manager must be persons of recognised commercial and professional good repute, and that of the board and management is assessed under article 30 of Royal Decree 84/2015 (article 4.1). That article requires conduct that raises no doubts about sound and prudent management, requires a criminal record certificate for each person assessed and weighs convictions and penalties by their seriousness, finality, intent and type (with particular attention to offences against the public purse, money laundering and offences against property), limitation and subsequent conduct, together with the person's track record with supervisors. The tax penalty imposed on the company your partner ran does not rule him out by itself: it is explained with the decision and its context. Concealing it, by contrast, counts against the very good repute being examined.

The application and what the Banco de España and SEPBLAC really look at

The official list of documents for buying and selling requires the application, the draft articles and the name certificate, a programme of operations, projected balance sheets and income statements for the first three financial years with their assumptions, and the list of shareholders, directors and general manager. The programme is the document read most closely: the buying and selling process, whether cards are accepted and, if so, who performs the exchange, any complementary activities, the measures ensuring customers can identify the provider if the premises are shared with another business, the premises, the staff and their duties, and the tools for the daily record, reporting to the Banco de España and transparency.

Each shareholder with 10% or more, directly or indirectly, files the FDU-102 good repute form; directors and the general manager file the FDU-099 fit and proper questionnaire with the FDU-096 declaration. If the shareholder is a company, like the Gibraltar one, its financial data for the last two financial years and the composition of its board must be provided (article 5.3.b), and the obligation extends to those who control it (rule five.2 of Circular 6/2001): you have to reach the individual behind it and the source of the funds. As a legal person, the company can file only through the electronic register; we file it as representatives holding a power of attorney (article 5 LPAC), without using your digital certificate, and each declarant signs his or her own form. There is no pre-application stage: the file has to go in complete.

SEPBLAC (Spain's financial intelligence unit) reports before authorisation on whether the internal anti-money laundering controls are adequate (article 3.1), because article 4.2.d requires procedures and bodies in line with articles 31 to 40 of Royal Decree 304/2014. A small bureau, with fewer than ten people and up to 2 million euros, has an exemption in the regulation from part of those obligations (article 31.1), and how it fits with that authorisation requirement has not been settled: we file the full system. From 28 October 2026 the exemption no longer covers the representative to SEPBLAC, whom every bureau must appoint (small ones have until 28 July 2027 to notify the appointment): a person resident in Spain who is a director or manager (article 26 ter of Law 10/2010). Also from 28 October 2026, procedures must cover international financial sanctions and countermeasures (Royal Decree 813/2026). We go into this in ‘AML compliance for your currency exchange or money remittance business in Spain’.

The clock: three months, deemed refusal and the real sequence to opening

The Banco de España has three months from receipt of the application; if it does not decide, the application is deemed refused (article 3.2), a negative silence rule backed by statute in the twenty-ninth additional provision of Law 14/2000. Unlike the payment institution procedure, the period does not wait for a complete file, but that does not make it shorter: a request to remedy defects gives ten days, extendable by five, with a warning that the application will be treated as withdrawn (article 68 LPAC); the Banco de España may suspend the period while a request for information is answered (article 22.1.a), and the SEPBLAC report suspends it for up to three months (article 22.1.d). No rule limits the number of requests, and silence does not release the Banco de España from its duty to decide: it may grant authorisation late (articles 21.1 and 24.3.b).

The real sequence starts with authorisation, not with the deed. Once it is notified, you have six months to execute the deed of incorporation of the sociedad anónima and register it with the Registro Mercantil (the Companies Registry) (article 4.2.a), which will not register it without proof of the authorisation (article 84 of the Regulations of the Companies Registry). The Banco de España then enters the company in the register of currency exchange establishments and notifies it, and only from that moment may it operate (article 3.3); it also sends a certificate of the authorised operations and the registration number, which must be displayed at each premises (article 3 of the Order). With the lease already running, Easter is an ambitious target: opening before registration means exchanging currency without authorisation, with requests for information, inspection and penalties from the Banco de España (article 13), as we explain in ‘Unlicensed currency exchange or money transfer in Spain: the risk and the way out’.

Once the bureau is open, supervised day-to-day business begins: a daily record of every transaction identifying each customer (article 11), a signed declaration from resident customers in transactions over 6,010.12 euros (article 7.1 of the Order), the balance sheet and income statement by 28 February, the annual accounts within fifteen days of the general meeting approving them and a half-yearly return. Rates and fees may be set freely, but they must be published for amounts up to 3,000 euros, the customer must be informed before each transaction and give express consent, and a settlement document must be issued (article 10; article 6 of the Order; rule nine of the Circular). New premises, changes in data and cessation are notified within the following month (article 5.5), changes of shareholders are notified afterwards, with no prior approval, and failing to start within twelve months of registration or stopping for more than twelve is a ground for revocation (article 9.1).

Cards, transfers and agents: where a bureau de change ends

Taking card payments from your own customer is compatible with the authorisation; the programme simply has to state whether the exchange is performed by the bureau or by the card issuer. Transfers are another matter: since 2015 Royal Decree 2660/1998 no longer regulates the handling of transfers, which is a reserved payment service (Royal Decree-Law 19/2018), and the exclusion for currency exchange covers only cash-to-cash exchange without a payment account (article 4.f). Paying the counter-value into a third party's account, such as the customer's relatives abroad, fits in our view the literal definition of money remittance; paying it into the customer's own account is not classified by any published rule or official guidance. It is a grey area and the Banco de España sees it in the programme: it is resolved before filing, not afterwards.

If you want to do both, the same company needs two applications: the bureau de change authorisation and authorisation as a payment institution or registration as a small payment institution (entidad de pago exenta), which does have a pre-application stage and a preliminary meeting with the Banco de España. Being a payment institution only frees you from the exclusive purpose: you still need the sociedad anónima, the 60,000 euros and the rest of article 4.2. No rule sets the order of the two, and whether a small payment institution can at the same time be a buying and selling bureau without an exclusive purpose has not been settled, although the indications are that it can: it is one of the questions we take to that preliminary meeting. This is developed in the cases ‘FX payments licence in Spain (online currency exchange): do you need one for transfers?’ and ‘I want to start a remittance business: agent or money transfer licence in Spain?’.

Nor can you have the souvenir shop buy or sell banknotes for the bureau: buying and selling cannot be entrusted to agents (article 10.4 of the Order; rule twelve.3 of the Circular), although the bureau may handle requests that third parties pass on for their own customers. On the other hand, the 1,000-euro limit on cash payments where a business is involved does not apply to cash exchange by an authorised bureau supervised by the Banco de España and subject to anti-money laundering rules (article 7.One.5 of Law 7/2012); what does apply is identification from 1,000 euros in occasional transactions (article 4.1 of Royal Decree 304/2014) and enhanced due diligence above 6,000 euros per transaction or in aggregate over the calendar quarter (article 19.2.c). And the bank account: a bureau that is not a payment institution has no statutory right to have a bank open one for it, which we deal with in ‘Bank account closed for a payment institution or bureau de change in Spain’.

If the Banco de España refuses or stays silent: administrative appeal and the Audiencia Nacional

The Banco de España may only refuse, with reasons, if the requirements of articles 4 and 5 are not met (article 3.1), and until the hearing stage you may make submissions and provide documents (article 76 LPAC). A refusal cannot be challenged by a recurso de reposición (request for reconsideration) or taken straight to court: acts of the Banco de España outside its monetary functions are appealed by recurso de alzada (administrative appeal) to the Minister for Economy, Trade and Business (article 3.1 of the Royal Decree; article 2.2 of Law 13/1994), within one month of notification; once that deadline passes, the decision is final. Against a deemed refusal, the recurso de alzada may be filed at any time (article 122.1 LPAC).

The Minister has three months to decide; if not, the appeal may be treated as dismissed (article 122.2), unless it was brought against the Banco de España's silence: the Act then treats the appeal as upheld (article 24.1), although it is doubtful that this applies to these authorisations and we do not take it for granted. Against the Minister's decision, judicial review goes in sole instance to the Sala de lo Contencioso-administrativo (Contentious-Administrative Chamber) of the Audiencia Nacional (National High Court) (article 2.3 of Law 13/1994), not to the Tribunal Superior de Justicia de Madrid (Madrid High Court of Justice), within two months from the day after notification (article 46.1 LJCA), with a procurador (court agent) and the option of seeking interim measures (articles 129 and 130). Against a deemed dismissal, the Tribunal Constitucional (Constitutional Court) has held that the six-month time limit cannot be relied on against the claimant (STC 52/2014, of 10 April). No prior attempt at negotiation is required: article 5 of Organic Law 1/2025 applies only in civil and commercial proceedings.

The court defers to the supervisor's technical assessment and reviews the facts, the reasoning and any manifest error: the case is won in the administrative file, with every document and every reply dated. If the refusal rests on a real deficiency, such as a shareholder whose fitness has not been shown or capital of unclear origin, it is usually faster to correct it and reapply: withdrawing ends the procedure, there is no waiting period and the new application can ask for documents the Banco de España already holds to be incorporated. If it rests on a legal error, such as treating banknote exchange as a payment service, the appeal has real prospects. We go into detail in ‘Banco de España licence refused or request for information’.

How we run the case, step by step

1. 1

   We define what you will do with the banknotes and the money

   We separate buying, selling, card payments and payments by transfer, decide whether buying only is enough and, if the flow involves third-party accounts, seek payment services authorisation at the same time.

2. 2

   We design the public limited company in formation

   Articles with an exclusive purpose, 60,000 euros in cash with headroom above the minimum, registered shares, a fit and proper board and general manager, and the shareholder chain traced to the individual behind it.

3. 3

   We prepare a complete application

   Programme of operations, three-year projections, FDU-102, FDU-099 and FDU-096, an anti-money laundering manual with its representative to SEPBLAC, and a documented explanation of any previous penalty.

4. 4

   We file it and handle all dealings with the supervisor

   We file through the electronic register as representatives with a power of attorney, answer every request on time and log the date of every filing so we know when the period expires and a deemed refusal arises.

5. 5

   We finalise the authorisation and open the premises

   Deed and registration of the public limited company within the six months, entry in the Banco de España register, certificate and notice board on display, and the daily record and periodic reporting running from day one.

6. 6

   If authorisation is refused, we appeal within the deadlines

   A recurso de alzada to the Minister for Economy, Trade and Business within one month, judicial review before the Audiencia Nacional within two months from the day after notification of the Minister's decision or, if faster, a fresh application correcting the deficiency.

The law that applies

• Arts. 1 a 5, 9 y 11 RD 2660/1998. Authorisation by the Banco de España, after a SEPBLAC report, to buy or sell banknotes to the public; selling requires a public limited company with an exclusive purpose and 60,000 euros; three months with deemed refusal, administrative appeal, grounds for revocation and a transaction record. BOE-A-1998-28816
• Arts. 2, 3, 6, 7 y 10 Orden de 16 de noviembre de 2000. Minimum capital must be maintained as net assets at all times; certificate displayed at each premises; published rates and fees; declaration by resident customers above 6,010.12 euros; buying and selling cannot be entrusted to agents. BOE-A-2000-21340
• Normas quinta, sexta y novena Circular 6/2001 del Banco de España. Contents of the application, covering shareholders with 10% or more and those who control a corporate shareholder; minimum net assets at all times; transparency and customer protection at each premises. BOE-A-2001-21296
• Art. 30 RD 84/2015. Good repute: conduct raising no doubts about sound and prudent management; criminal record certificate and assessment of convictions, penalties, limitation, subsequent conduct and track record with supervisors. BOE-A-2015-1455
• Arts. 31 y 35 RD 304/2014. Anti-money laundering policies and procedures and a representative to SEPBLAC; partial exemption for firms with fewer than ten people and up to 2 million euros, which from 28 October 2026 no longer covers the representative. BOE-A-2014-4742
• Art. 7 Ley 7/2012. Prohibits cash payments of 1,000 euros or more where a business or professional is involved, except cash currency exchange by authorised establishments supervised by the Banco de España and subject to anti-money laundering rules. BOE-A-2012-13416
• Art. 2 Ley 13/1994, de Autonomía del Banco de España. Acts of the Banco de España outside its monetary functions are appealed to the Minister (now by recurso de alzada), and the Audiencia Nacional hears, in sole instance, challenges to the Minister's decision. BOE-A-1994-12553
• Arts. 22, 24, 68 y 122 Ley 39/2015 (LPAC). Suspension of the time limit for requests and reports; deemed refusal only opens the way to an appeal; ten days to remedy defects; recurso de alzada within one month or, against silence, at any time, with three months to decide it. BOE-A-2015-10565

Each article checked against the consolidated text published in the BOE (the Spanish official gazette).

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