EMI License in Spain: Requirements and Obtaining Procedures in 2026
Spain remains one of the most attractive jurisdictions in the European Union for obtaining an EMI (Electronic Money Institution) license. In 2026, the Spanish regulator continues to support fintech projects focused on innovative payment solutions, while imposing strict requirements for business transparency, capital, and risk management.
Key Requirements for Obtaining an EMI License in Spain
- Legal Entity in Spain. The company must be registered in the licensing country and comply with the permitted type of activity under SIC code 64999. Legal entities such as LLCs, partnerships, and trusts are permitted, subject to full compliance with regulatory requirements.
- Initial Share Capital. The minimum share capital is €350,000. To cover operating expenses and enhance project sustainability, the regulator recommends a capital of €500,000 or more. Funds must be permanently held in the company's account for the entire license term.
- Management Team At least four resident key managers with relevant experience in the financial or payments sector, a proven business reputation, and the necessary professional competencies are required.
- Verified Source of Funds (SoW). Beneficial owners (UBOs) must confirm a legitimate and verifiable source of funding for amounts of EUR 350,000 or more.
- Client Fund Protection. The company must implement a client fund segregation mechanism, including a separate safeguarding account or alternative protection tools that meet regulatory requirements.
- Software and IT Infrastructure. The software used must be certified, accompanied by full technical documentation, and comply with applicable regulations, including DORA requirements.
- Full EMI License Application. The application package must include a detailed application with an innovative business model relevant to the 2026 fintech market, financial projections, and a description of operational activities.
Stages and Timeframes for Obtaining a License
The EMI license process consists of three stages. The first stage involves an interview and the creation of an application development plan, while banks and directors are selected. The second stage involves preparing a complete set of documents and submitting an application to the regulator. The third stage involves corresponding with the supervisory authority until a final decision is received.
The process timeframe varies: company registration takes approximately three weeks, opening a bank account takes up to eight weeks, application preparation takes six to eight weeks, and regulatory review can take anywhere from three to 12 months.
IT-OFFSHORE will help prepare and submit all the necessary documents, providing professional support at every stage of obtaining an EMI license in Spain.
