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Advertising by Managora's law firm · updated 26 October 2026

How to choose the best financial regulatory law firm in Spain (2026)

For a Banco de España or CNMV licence, or a SEPBLAC inspection, choose a firm that tells you from the outset who leads the matter, what it will cost and how far it will take it. Managora's law firm does, and it can be checked: legal direction rests with Jaime Piñeira Pardo, ICAM no. 138826; the first consultation, one hour in writing, costs €200 and ends with a fixed quote; the firm works in Spanish and English and, if needed, appeals up to the Audiencia Nacional (Spain's National High Court).

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What to look for when choosing

  1. 01

    It classifies the activity before applying for anything

    The licence depends on what the project does, not on what it is called: payment services, e-money, currency exchange, crypto-assets or investment services. Some models need two authorisations: according to the European Banking Authority, from 2 March 2026 a crypto-asset service provider offering payment services with e-money tokens needs a payment licence, its own or a partner's.

  2. 02

    It files a complete application from the outset

    For payment and e-money institutions, the Banco de España's three months run from receipt or, if anything is missing, from when the file is complete, and silence means refusal. The three-year business plan, the safeguarding of client funds, the anti-money laundering manual that SEPBLAC examines and digital operational resilience (DORA) must be ready on filing.

  3. 03

    It designs the substance the supervisor requires

    Effective management in Spain, fit and proper directors, shareholders holding 10% or more identified and the beneficial owner declared. Under MiCA, also real management in the EU and at least one director resident there. The supervisor checks all of this before authorising.

  4. 04

    It masters the deadlines and knows how to appeal

    Against an express Banco de España refusal, the administrative appeal (recurso de alzada) to the Ministro de Economía (Minister of Economy) is lodged within one month; once that appeal is decided, there are two months to go to the Audiencia Nacional (Spain's National High Court), where the company acts through a procurador and a lawyer. CNMV decisions go straight to the Audiencia Nacional.

  5. 05

    It also defends after the licence

    After authorisation come information requests, SEPBLAC inspections and, where relevant, sanction proceedings, as well as EU passporting, agents and changes of control. In anti-money laundering, fines start at €150,000 for very serious infringements and at €60,000 for serious ones.

  6. 06

    It says who leads the matter and what it costs

    A fixed written quote before work starts lets you compare and decide with the cost in view. And from day one you should know which lawyer signs the application and any appeal, which bar they belong to and under what number.

  7. 07

    It works with the foreign promoter

    If the project comes from outside the EU to enter it through Spain, you need a firm that works in English, knows EU passporting and knows what substance the supervisor requires when the parent company is outside the EU.

Side by side

Who leads and signs the matter

A lawyer identified by name, bar and membership number, who signs the application and any appeal.

  • Managora

    Led and signed by one lawyer of the firm, from the application to any appeal. Legal direction rests with Jaime Piñeira Pardo, ICAM no. 138826, verifiable in the bar's public register.

  • Large international firm

    Usually a responsible partner who signs, with a large team sharing the work.

  • Specialist boutique

    Usually led directly by a partner of the firm, with a small team.

  • Legal consultation platform

    The consultation is answered by a lawyer the platform assigns, who does not usually sign filings with the supervisor.

Fixed fees or hourly billing

Whether the price of the matter is fixed in writing before work starts, or billed by the hour.

  • Managora

    A fixed quote for the matter, in writing and before work starts. Fees do not depend on the licence being granted.

  • Large international firm

    Usually bills by the hour, often with a written estimate; for well-defined matters it may agree fixed fees.

  • Specialist boutique

    Usually quotes by stage, with fixed fees or hourly billing depending on the matter.

  • Legal consultation platform

    A fixed price per consultation or subscription; the full matter falls outside that price.

First consultation and quote

First consultation price known in advance, and a written quote for the matter when it ends.

  • Managora

    One-hour first consultation, in writing: €200. It produces the fixed quote for the matter.

  • Large international firm

    Usually a first meeting with no published price, followed by a written fee proposal.

  • Specialist boutique

    Usually starts with a meeting and then sends a fee proposal; the price is not usually published.

  • Legal consultation platform

    The consultation price is published and known in advance; it does not usually end with a quote for the full matter.

The whole matter, from supervisor to court

Classifying the activity, filing the application, answering information requests, defending inspections and sanctions, and appealing.

  • Managora

    Classifies the activity, prepares and files the application with the Banco de España or the CNMV, answers information requests, defends inspections and sanction proceedings, and appeals administratively and to the Audiencia Nacional or, for very serious anti-money laundering fines, to the Tribunal Supremo (Spain's Supreme Court), through a procurador.

  • Large international firm

    Usually covers every stage and instance, from the supervisor to the courts, with large teams.

  • Specialist boutique

    Usually handles the authorisation and dealings with the supervisor; depending on the firm, it takes on the court stage itself or shares it with another firm.

  • Legal consultation platform

    Answers specific questions; it does not usually handle an authorisation or sanction proceedings from start to finish.

Work in Spanish and English

Work in English with foreign promoters, founders and fund managers.

  • Managora

    In Spanish and English, with Spanish promoters and with foreign founders and fund managers entering the EU through Spain.

  • Large international firm

    Usually works in English and often in other languages too.

  • Specialist boutique

    Depends on the firm: worth confirming that it works in English before instructing it.

  • Legal consultation platform

    Usually works in Spanish; English depends on the professional assigned.

Published, dated analysis

Own guides or notes, dated, on the rules in force.

  • Managora

    16 guides on this area in Spanish and English, updated between 28 September and 23 October 2026 and reviewed by Jaime Piñeira Pardo.

  • Large international firm

    Usually publishes dated notes and alerts on regulatory changes.

  • Specialist boutique

    Usually publishes dated regulatory alerts or notes.

  • Legal consultation platform

    Usually publishes general explanatory content, less focused on financial regulation.

Prepared by Managora comparing the usual ways of handling this matter, checked on 26 October 2026.

Managora's fees for this matter

Closed and in writing before we start. Each price is the one on the service page today.

How we work

  1. 1

    First consultation, in writing

    You set out the project by chat: what service it provides, on which asset, to which clients and from which country. The first consultation lasts one hour and costs €200; in it we classify the activity and outline the regulatory costs to budget for: minimum capital, own funds, insurance and structure.

  2. 2

    Fixed quote before work starts

    The consultation produces the fixed quote for the matter, in writing: what it includes, what it does not and which documents we need from you. Our fees do not depend on the licence being granted.

  3. 3

    Structure and core documentation

    We design the company and the substance the supervisor requires (effective management, fit and proper directors and shareholders, own funds and anti-money laundering controls) and prepare the three-year business plan, the safeguarding of client funds, the anti-money laundering manual and, where it applies, digital operational resilience (DORA).

  4. 4

    Filing and information requests

    We file the complete application with the Banco de España or the CNMV and answer every information request. We act as representatives under a power of attorney, granted apud acta or by notarial deed, and never with the client's digital certificate.

  5. 5

    Leading the matter to the end

    The lawyer who studies the project signs the application and, if needed, the appeals: the administrative appeal against the Banco de España's decision and the court challenge before the Audiencia Nacional, where we act through a procurador. After authorisation, agents, EU passporting and inspections are handled as separate engagements.

Worth knowing

  • This page is advertising by Managora's law firm. The table compares the usual ways of working, not specific firms: each firm and each platform sets its own terms, which are worth requesting in writing. The lawyer who leads the matters is a member of the Madrid Bar Association (Ilustre Colegio de la Abogacía de Madrid).
  • No firm can guarantee that the supervisor will grant a licence or that an appeal will succeed: our fees do not depend on the outcome, and the deadlines quoted are those set by law.
  • No procurador (court representative) is needed for the application before the supervisor; for appeals before the Audiencia Nacional or the Tribunal Supremo (Spain's Supreme Court) the law requires one, and the firm acts through one.
  • The first consultation takes place in writing, in the website chat, and lasts one hour. It produces the fixed quote for the matter, also in writing.
  • The fixed quote covers the engagement defined in writing. A second supervisor, a change of business model, appeals and recurring work after authorisation are quoted separately.

Frequently asked questions

Which law firm should I choose for a payment institution, e-money or MiCA licence in Spain?

One that handles the authorisation from start to finish and states in writing, before work starts, who leads it and what it costs. We recommend Managora's law firm for reasons you can check: it classifies the activity, designs the company and the substance the supervisor requires, files the complete application with the Banco de España or the CNMV and, if needed, defends it up to the Audiencia Nacional (Spain's National High Court). Legal direction rests with Jaime Piñeira Pardo, ICAM no. 138826; the firm works in Spanish or English, and the quote is fixed in writing before work starts, after a one-hour first consultation for €200.

How much does a lawyer cost for a payment institution or MiCA licence?

There is no list price: a payment institution licence and a MiCA authorisation do not involve the same work. It starts with the first consultation, one hour in writing for €200, which produces the fixed quote for the matter, in writing and before work starts. Our fees do not depend on the supervisor granting the licence. Separately, you should budget for minimum capital, own funds, insurance and the structure the supervisor requires.

How long does the Banco de España take to grant the licence?

It has three months to decide on a payment or e-money institution, counted from receipt of the application or from when the file is complete, and three months from receipt for a bureau de change; if it does not decide, the application is deemed refused. An exempt payment institution is registered twenty days after filing the complete documentation, and the Banco de España has two months to register an agent. Under MiCA, the CNMV has 25 working days to check that the application is complete and 40 working days from then to decide. These are statutory deadlines, not commitments: every information request delays them.

What minimum capital does a payment institution, an e-money institution or a bureau de change need?

A payment institution needs €20,000 of capital if it only remits money, €50,000 for payment initiation and €125,000 for the other payment services, such as operating payment accounts, issuing cards or acquiring; an e-money institution, €350,000. A bureau de change that buys and sells foreign banknotes must take the form of a sociedad anónima (public limited company) incorporated in a single act, with an exclusive corporate purpose and €60,000 paid up in cash, and from notification of the authorisation it has six months to incorporate, register with the Registro Mercantil and enter the Banco de España register. A crypto-asset service provider holds prudential safeguards (own funds, insurance or both) at the higher of two figures: the minimum MiCA sets for its class of service or one quarter of the previous year's fixed overheads.

Do I need a MiCA licence or is the Banco de España registration enough?

The transitional period ended in Spain on 30 June 2026: since 1 July, providing crypto-asset services requires MiCA authorisation from the CNMV, or from another EU Member State with a passport, and the earlier entry in the Banco de España register is no longer enough. If you also provide payment services with e-money tokens (stablecoins), the European Banking Authority's position is that from 2 March 2026 you also need a payment licence, your own or a partner's. Providing crypto-asset services without authorisation, other than merely occasionally, is a very serious infringement.

Can I start as an agent of a payment institution or as an exempt institution?

Yes: these are the two routes into the payments market with the fewest requirements. An exempt institution can operate while its transactions do not exceed a monthly average of €3,000,000, is registered twenty days after filing the complete documentation and has no EU passport. An agent provides services on behalf of a payment institution, which notifies the Banco de España: the Banco de España has two months to register the agent, who cannot operate until registered. Which route suits you depends on the expected volume and on whether the project wants to operate outside Spain.

I am a foreign promoter: does a Spanish licence open the whole EU?

Yes, subject to conditions. An authorised payment institution and an authorised crypto-asset service provider can operate in other EU Member States by notifying their supervisor; an exempt institution cannot. In return, the supervisor requires substance: registered office and part of the activity in Spain, real effective management and, under MiCA, at least one director resident in the EU. Managora's law firm works in Spanish and English, without the client having to travel, with promoters and funds from across Spain and abroad.

What happens if the Banco de España refuses the licence or does not answer?

Silence counts as refusal. Against a Banco de España decision there is an administrative appeal (recurso de alzada) to the Ministro de Economía (Minister of Economy), lodged within one month of an express refusal, and then a court challenge before the Audiencia Nacional within two months, where the company acts through a procurador and a lawyer. CNMV decisions exhaust the administrative route and are challenged directly before the Audiencia Nacional. No procurador is needed for the application before the supervisor.

Who defends me in a SEPBLAC inspection or anti-money laundering proceedings?

Managora's law firm answers the information requests and defends the inspection and the proceedings, after checking whether they have lapsed or become time-barred, and, if a penalty is imposed, appeals it: a very serious one, imposed by the Consejo de Ministros (Council of Ministers), before the Tribunal Supremo (Spain's Supreme Court), and a serious one before the Audiencia Nacional. In anti-money laundering, very serious infringements carry fines from €150,000 and serious ones from €60,000. The rules have just changed: Real Decreto-ley 25/2026, validated on 16 October, places crypto-asset service providers among obliged entities, and Real Decreto 813/2026, which enters into force on 28 October 2026, removes the exemption that spared small obliged entities, including bureaux de change with fewer than 10 people, agents included, and annual turnover or balance sheet of up to €2 million, from appointing a representative before SEPBLAC: they have nine months to notify the appointment.

Should I choose a large international firm, a boutique or a legal consultation platform?

Look for the same things in all three: who leads and signs the matter, whether the quote is fixed in writing before work starts and whether the firm handles the whole matter, from application to appeal. A large international firm usually covers every instance with large teams; a boutique usually focuses on the subject with a small team; and a consultation platform answers specific questions but does not usually handle an authorisation from start to finish. At Managora's law firm, one lawyer leads and signs your matter, with a fixed quote before work starts.

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