I want to start a remittance business: agent or money transfer licence in Spain?

The case, in five lines

What is brought

Choosing the route and obtaining the right to send money: registration as an agent of a payment institution, which notifies the Banco de España (Spain's central bank) (article 23 of Royal Decree-Law 19/2018, RDL 19/2018, and article 13 of Royal Decree 736/2019); registration as an exempt payment institution (article 14 of RDL 19/2018 and article 4 of Royal Decree 736/2019); or authorisation as a payment institution for money remittance (articles 11 and 19.1.a of RDL 19/2018). If refused, a recurso de alzada (administrative appeal) to the Minister for the Economy and, against the Minister's decision, a recurso contencioso-administrativo (judicial review).

Before which court

The Banco de España (Spain's central bank) registers agents and exempt institutions (the latter through its secretario general, the Secretary General, by delegation from the Comisión Ejecutiva, its Executive Committee) and authorises payment institutions through its Comisión Ejecutiva, after a report from SEPBLAC (Spain's financial intelligence unit). Its decisions are appealed by recurso de alzada (administrative appeal) to the Minister for the Economy (today, the Ministerio de Economía, Comercio y Empresa, the Ministry of Economy, Trade and Business) and then before the Audiencia Nacional (National High Court). Disputes with your principal institution or your bank are civil matters: the Tribunal de Instancia (court of first instance), after a prior attempt at negotiation (article 5 of Organic Law 1/2025).

Deadline

Agent: the Banco de España has two months from receipt of the institution's notification, and the agent may not operate until registered (article 23.2 of RDL 19/2018). Exempt institution: registration is deemed to have taken place twenty days after the complete documentation is filed (article 4.1 of Royal Decree 736/2019), following the pre-application and preliminary meeting that the Banco de España requires in its procedure. Authorised institution: three months from complete documentation, with silence meaning refusal (article 11.2 of RDL 19/2018). Recurso de alzada within one month of an express refusal, or at any time against silence; judicial review within two months from the day after notification of the decision on the alzada (article 46.1 of the LJCA, the Contentious-Administrative Jurisdiction Act), with no time limit if it is not decided.

Who can bring it

Only the payment institution that appoints the agent can notify the agent's registration; an agent cannot register itself. Registration as an exempt institution is requested by the individual or company with its head office or residence in Spain (article 14.2.a of RDL 19/2018). Authorisation is requested by a Spanish commercial company of any form (in practice, a sociedad limitada (private limited company) or a sociedad anónima (public limited company)), which may still be in formation. The appeal is brought by the applicant whose request was refused; in the case of an agent, by the institution that notified it.

Financial risk

Sending money repeatedly and on a professional basis without being registered or authorised is a very serious infringement (article 92.aa of Law 10/2014), punishable with a fine on the company of three to five times the profit obtained, up to 10% of turnover or up to 10,000,000 euros, and, for each responsible director, a fine of up to 5,000,000 euros and disqualification for up to ten years (articles 97.1.a and 100.1). In anti-money laundering matters, the minimum fines are 150,000 euros (very serious) and 60,000 (serious). As an agent, the risk is different: termination leaves you with no right to keep sending money.

Sending other people's money is a reserved payment service

Money remittance is one of the eight payment services in Royal Decree-Law 19/2018 (article 1.2.f): receiving funds from a payer, without opening a payment account in anyone's name, for the sole purpose of transferring an equivalent amount to a payee or to the payee's provider, or receiving funds on behalf of the payee and making them available to the payee (article 3.36). That is exactly what a call shop does when it collects cash in Spain so that a family can pick it up in Quito.

Providing it on a professional basis is reserved to banks, electronic money institutions, authorised payment institutions and exempt institutions, plus Correos (the Spanish postal service) within the limits of its own rules; anyone else is prohibited from doing so (article 5.1 and 5.3). For a newcomer there are three doors: working as an agent of an institution, registering as an exempt institution or applying for authorisation as a payment institution. None of the three allows you to operate before entry in the Banco de España (Spain's central bank) register.

Doing it without authorisation, repeatedly and on a professional basis, is a very serious infringement (article 92.aa of Law 10/2014), investigated and sanctioned by the Banco de España itself. That is why the question of whether you can start 'in the meantime' has a short answer: no, except as a registered agent of another institution. What to do if you have already sent money without a licence is covered in our case on that risk and how to get out of it.

Agent of a payment institution: fast, but the business is not yours

An agent is a person or company that provides payment services on behalf of a payment institution (article 3.3 of RDL 19/2018 and article 12 of Royal Decree 736/2019). Agents do not register themselves: the institution notifies the Banco de España of the agent's name and address, the anti-money laundering controls it will apply, the identity and good repute of the people in charge and the services entrusted to it (article 23.1), together with its procedures for selecting and training agents (article 13 of Royal Decree 736/2019). The notification is filed electronically and must be made within fifteen calendar days of the appointment.

The Banco de España has two months from receipt of that information to decide whether to register you; if it doubts the information, it verifies it and, if the doubts remain, refuses (article 23.2). Until registration, the agent may not operate. It is the fastest way to start. You may work for several institutions, provided you inform customers of the dual appointment (article 14.2.c of Royal Decree 736/2019), and in every dealing you must identify the institution you represent. If the institution is based in another EU Member State, your registration reaches the Banco de España through a notification from the home supervisor.

What nobody tells you: the institution is fully liable for your acts (article 23.5 of RDL 19/2018), checks on you at least once a year (article 14.1 of Royal Decree 736/2019) and must terminate the contract of an agent who seriously or systematically breaches its anti-money laundering procedures (article 37 of Royal Decree 304/2014). That is why its warnings about split transfers are not a commercial nuisance. And if it terminates you, you are no longer authorised: the activity is reserved, and carrying on sending money would mean operating without a licence.

Exempt institution: your own licence for a neighbourhood-sized business

The exemption regime allows you to provide the services in letters a) to f), money remittance included, through registration rather than authorisation, provided the average value of transactions over the previous twelve months, including those of your agents, does not exceed 3,000,000 euros a month; at the outset it is measured against the business plan (article 14.1.a of RDL 19/2018). None of your managers may have been convicted of money laundering, terrorist financing or other financial crimes (article 14.1.b). It may be an individual or a company, with its head office or residence in Spain.

There is no minimum capital and, if you only send money, safeguarding of funds is not required unless the Banco de España considers it necessary (article 4.3 of Royal Decree 736/2019 and section 4.10 of its guide); the Banco de España charges no fee either. The procedure begins with a pre-application (form FDU-167) and a preliminary meeting in which the supervisor asks about your motivation, the maturity of the project and your resources, and requests a demonstration of the service; the application itself follows, with forms FDU-059 and FDU-163. Every year you report the total value of your transactions to it.

The 'licence in twenty days' comes with small print. The twenty days run from the complete documentation required by article 4.1 of Royal Decree 736/2019, which includes the criminal record certificates of the people in charge, and only then is registration deemed to have taken place; the Banco de España carries out a formal check and reviews the substance later, when supervising. An exempt institution has no passport: it cannot appoint agents or provide services in another EU Member State, although that does not prevent its customers in Spain from sending money to Colombia. If the average exceeds the limit, it has 30 calendar days to apply for authorisation (article 14.2.d).

Authorised payment institution: 20,000 euros, own funds and safeguarding

If you will exceed 3 million a month, want to grow in Europe or need more services, the route is authorisation. For money remittance only, initial capital is 20,000 euros, which may never fall below that figure (article 19.1.a of RDL 19/2018), and own funds must also be maintained under one of the three methods in the Royal Decree; the first equals 10% of the previous year's fixed overheads, and the Banco de España may require up to 20% more or allow up to 20% less (articles 17 and 18.1 and the annex of Royal Decree 736/2019 and article 19.2.b of RDL 19/2018).

Client money is protected: it is not commingled with the institution's own funds and, if it has not been paid out by the end of the following business day, it is deposited in a segregated account designated 'client balances of a payment institution' or in secure assets, or covered by insurance or a guarantee from an entity outside the group, which must also cover funds held by agents (article 21 of RDL 19/2018 and article 16 of Royal Decree 736/2019). Finding a bank willing to hold that account is usually the bottleneck.

Authorisation is granted by the Comisión Ejecutiva (Executive Committee) of the Banco de España, after a report from SEPBLAC (Spain's financial intelligence unit), within three months of the documentation being complete; if it does not decide, the application is deemed refused (article 11.2). There is a pre-application (FDU-168), the company may take any commercial form (in practice, a sociedad limitada or a sociedad anónima) and it can be authorised while still in formation; its directors are entered in the Registro de Altos Cargos (register of senior officers). In return, it has an EU passport and can build its own agent network. Buying an institution that is already authorised is another route, requiring prior notification to the Banco de España, which we cover in its own case, as we do the general requirements of the payment institution licence.

What the Banco de España and SEPBLAC look at: people, manual and cash

Payment institutions and exempt institutions are obliged entities under Law 10/2010 on the prevention of money laundering (article 2.1.h): they adopt in writing a customer acceptance policy and an anti-money laundering manual tailored to their business (article 26), appoint a representative to SEPBLAC (Spain's financial intelligence unit) who resides in Spain and is a director or senior manager, and undergo an annual review by an external expert (article 28), unless the owner is a sole trader. The size-based waiver in the implementing regulation does not apply to them: it is for bureaux de change and the other obliged entities in letters i) to u).

In money remittance the customer is always identified, whatever the amount (article 4.1 of Royal Decree 304/2014), and enhanced due diligence is mandatory where the transfer, on its own or added to others in the same calendar quarter, exceeds 3,000 euros (article 19.2.b). Every month, transfers involving cash of more than 1,500 euros and aggregated information by country and by agent are reported to SEPBLAC; if there is nothing to report, a nil return is filed every six months (article 27.1.b and e). Every transfer travels with the payer's and payee's details (Regulation 2023/1113), and everything is kept for ten years.

What the supervisor looks for is a manual that matches the business plan: a call shop moving cash to three countries needs its own rules on structuring, on multiple payers or payees with no apparent connection, which the regulation treats as an indicator, and on the oversight of its agents. From 28 October 2026, non-face-to-face identification no longer requires SEPBLAC's prior approval for each procedure if it meets SEPBLAC's published general approvals. We cover the full system in our case on anti-money laundering for bureaux de change and remittance businesses.

Bank account, termination and appeals: where the business breaks

A payment institution has a right of access to banks' account services on an objective, non-discriminatory and proportionate basis; if the bank refuses or closes the account, it must immediately send the Banco de España and the institution itself a decision reasoned on the institution's specific risks or on criteria published in advance (article 9 of RDL 19/2018). That an exempt institution has the same right is a reasonable interpretation, since it is treated as a payment institution; an agent has no such right, and against an agent the bank relies on the contract and on its duty not to maintain a relationship where it cannot apply due diligence (article 7.3 of Law 10/2010).

The Court of Justice of the European Union held in case C-235/14, Safe Interenvíos (judgment of 10 March 2016), that a bank may apply its own due diligence to a payment institution customer and its agents, with risk-based and proportionate measures, subject to review by the national court. Arriving with the manual, the figures and the source of the cash already explained prevents many closures; the rest is covered in our case on banks that refuse or close accounts.

If the Banco de España refuses registration, authorisation or an agent's entry in the register, its decisions do not exhaust administrative remedies: a recurso de alzada (administrative appeal) to the Minister for the Economy within one month of notification, or at any time against silence, and then a judicial review claim before the Audiencia Nacional (National High Court) within two months, where we act together with a procurador (court agent), with no prior attempt at negotiation. Termination as an agent or a dispute over commissions with the institution are civil matters: the Tribunal de Instancia (court of first instance), after that prior attempt at negotiation (article 5 of Organic Law 1/2025). How to respond to a request for information or a refusal is covered in its own case.

How we run the case, step by step

1. 1

   We classify your business and your volume

   We check which services you actually provide, how much you move each month including your agents, and whether you fit the exemption or need authorisation.

2. 2

   We review your agency contract and your exit

   Exclusivity, notice, non-compete and commissions: we design the transition so that there is not a single day of sending money without authorisation.

3. 3

   We design the structure

   Individual or company, managers with clean records, head office in Spain, a bank for operations and, if authorisation is needed, capital, own funds and safeguarding.

4. 4

   We prepare the file and the manual

   Programme of operations, business plan, security policy, an anti-money laundering manual tailored to your corridors and controls over your agents.

5. 5

   We file and handle all dealings with the supervisor

   We file as your representatives under your power of attorney, without using your digital certificate; we prepare the preliminary meeting and answer every request for information with evidence and on time.

6. 6

   If there is a refusal, termination or closure, we defend you

   A recurso de alzada to the Minister for the Economy and a judicial review claim before the Audiencia Nacional (National High Court), or negotiation and a lawsuit against your principal institution or the bank.

The law that applies

• Arts. 1.2, 3.36 y 5 RDL 19/2018. Money remittance is a payment service: receiving funds without opening a payment account in order to transfer them to a payee. Only authorised providers may provide it professionally; anyone else is prohibited from doing so. BOE-A-2018-16036
• Arts. 9, 14, 19, 21 y 23 RDL 19/2018. Payment institutions' access to bank accounts, with reasoned decisions; exemption up to 3,000,000 euros a month, with no passport; capital of 20,000 euros for money remittance; safeguarding; agents notified by the institution, registered within two months and under its full liability. BOE-A-2018-16036
• Arts. 4, 12, 13, 14 y 16 RD 736/2019. Registration of an exempt institution twenty days after complete documentation; definition of an agent and contents of its notification; annual checks and dual appointment; safeguarding requirements, including funds held by agents. BOE-A-2019-18425
• Arts. 2, 26 y 28 Ley 10/2010. Payment institutions and exempt institutions are obliged entities; they adopt in writing their policies, customer acceptance and manual; annual review by an external expert, not required of sole traders. BOE-A-2010-6737
• Arts. 4, 19, 27 y 37 RD 304/2014. Identification always required in money remittance; enhanced due diligence above 3,000 euros per transaction or quarter; monthly systematic reporting to SEPBLAC; the institution oversees its agents and terminates the contract of any agent in serious or systematic breach. BOE-A-2014-4742
• Arts. 92, 97 y 100 Ley 10/2014. Providing payment services repeatedly and professionally without authorisation is a very serious infringement, with a fine on the company of up to 10,000,000 euros or 10% of turnover, among other amounts, and sanctions on its directors. BOE-A-2014-6726
• 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 for the Economy, and the Audiencia Nacional hears, in sole instance, challenges to the Minister's decision. BOE-A-1994-12553
• Reglamento (UE) 2023/1113. A transfer travels with the payer's and payee's details; for transfers of 1,000 euros or less, the provider verifies the details if it receives cash or has suspicions. 32023R1113

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

Frequently asked questions