Mica Regulation Spain: Comply-Or-Quit Push For Licenses

Spain is entering a decisive phase for its digital asset industry, with Mica regulation setting strict conditions for crypto platforms that want to keep serving local customers.

CNMV sets detailed roadmap for crypto platforms

The Spanish National Securities Market Commission (CNMV) has issued extensive guidance explaining how crypto must adapt to the European Union’s new Markets in Crypto-Assets rules. The document, structured as a question-and-answer guide, sets out the authorization pathway and makes the choice clear: secure a MiCA license or exit the Spanish market.

According to the CNMV, only firms that comply with the new standards will be allowed to continue operating. Moreover, the regulator stresses that companies should treat the transition calendar as a hard deadline rather than a flexible target. The guidance interacts with existing Spanish rules, aiming to align the domestic framework with the broader EU regime.

Spain’s transitional period runs to July 1, 2026

The EU regulation permits member states to give crypto-asset service providers a transition window running until July 1, 2026. Spain has opted for the maximum period, giving companies just under 18 months from MiCA’s full application date of December 30, 2024 to secure authorization.

This means all crypto-asset service providers (CASPs) operating in Spain must obtain full MiCA regulation by July 1, 2026. However, any company that fails to do so will be barred from continuing activity in the country after that date. The approach is intended to offer time for adaptation while maintaining regulatory certainty.

Spain’s stance mirrors that of several other EU jurisdictions that have also made use of MiCA’s regulation transitional provisions.

That said, timelines differ significantly across the bloc: France offers an 18-month window, while the Netherlands allows only six months. Some member states may decide not to implement a transition regime at all.

Who can use Spain’s transition period

The CNMV guidance makes clear that not every crypto company automatically benefits from the transitional regime. Only certain entities can continue operating while they seek MiCA authorization, subject to conditions linked to their existing status and activities.

Firms that were registered in the Bank of Spain registry for currency exchange and wallet custody services before December 30, 2024 can keep serving customers during the transition. This registry, created in May 2021 under Spain’s anti-money laundering framework, now primarily has an informational role, but it remains a key reference for eligibility.

The CNMV also clarified that companies offering other crypto-related services, such as portfolio management or investment advice, may use the transition period if they were operating before December 30, 2024. However, these entities were never required to appear in the Bank of Spain registry, so they must demonstrate through documentation that they were already active in the market.

Shift of responsibility from Bank of Spain to CNMV

One structural change highlighted in the guidance is the end of new registrations at the Bank of Spain. As of December 30, 2024, the central bank stopped accepting fresh CASP applications, and its registry now serves purely as a historical and informational database.

From this point forward, the CNMV assumes full responsibility for authorization and supervision of crypto-asset service providers. Moreover, this transfer of competence reinforces the idea that MiCA authorization will be the single decisive license for those wishing to operate in Spain’s crypto market.

What MiCA regulation in Spain requires from firms

The CNMV has published a detailed handbook for crypto service providers that want to obtain a license under MiCA regulation in Spain. It explains which business models fall within the regulation’s scope, how MiCA interacts with Spanish law, and what documentation must be filed to complete the authorization process.

The application is extensive and demands in-depth disclosure. Companies must submit more than 100 pages of information on their operations, shareholder structures, governance, and risk management systems. However, the regulator argues that this level of detail is necessary to protect investors and ensure financial stability in a volatile asset class.

For certain financial institutions already supervised under EU legislation, such as banks, investment firms, and e-money institutions, the path is somewhat easier. Instead of full authorization, these entities can follow a streamlined notification procedure, provided they inform the CNMV at least 40 days before starting crypto services.

The CNMV began accepting CASP applications in September 2024. So far, only BBVA has successfully obtained a MiCA license in Spain, highlighting how few players are currently fully compliant. That said, the regulator expects a significant increase in applications as deadlines approach.

Limits on cross-border activity during the transition

The new guidance also addresses a crucial issue for international platforms: whether companies relying on transitional arrangements in other EU states can serve Spanish clients without separate approval. The answer provided by the CNMV is unambiguous.

Firms using transitional periods in their home jurisdictions cannot automatically passport services to Spain unless they also qualify under Spain’s specific regime. In practice, this means each company must check whether it meets Spanish transitional conditions or obtain authorization directly. Moreover, they cannot assume that temporary permissions elsewhere will be recognized.

This situation creates a fragmented landscape during the implementation phase. Different countries have chosen different timelines, with France giving 18 months and the Netherlands limiting transitional relief to six months. Once full MiCA authorization is granted in any EU member state, however, companies will be able to passport services across all 27 countries under uniform rules.

Additional regulatory guidance on investment and marketing

Beyond licensing, the CNMV’s documentation provides broader crypto regulatory guidance Spain for investment vehicles and intermediaries. It explains how MiCA applies to collective investment schemes, venture capital funds, and entities regulated under the Markets in Financial Instruments Directive (MiFID II).

The regulator also examines when online promotion of crypto products becomes a regulated activity. If influencers are paid according to the number of clients they attract, or if they interact with followers to establish ongoing client relationships, their work may be treated as client acquisition. In that case, it could fall under marketing rules subject to supervisory oversight.

Moreover, the CNMV sets out conditions for over-the-counter derivatives issued to clients for hedging purposes. These instruments must meet specific criteria to remain compliant, with requirements designed to protect investors and prevent the misuse of complex products in the retail market.

A clear comply-or-quit message for the industry

In its communication, the CNMV characterizes the framework as a clear comply-or-quit regime. Firms are expected to adjust their structures, governance, and disclosures to align with MiCA by July 1, 2026, or they will have to stop offering crypto services in Spain.

This stance reflects a wider European trend toward standardized crypto oversight. MiCA became fully applicable across the European Union on December 30, 2024, creating a single regulatory framework for service providers, issuers, and trading platforms. The aim is to safeguard investors while offering legal certainty to legitimate businesses.

By adopting the full transitional period and clarifying each step, Spanish authorities are signalling that they want orderly integration of crypto into the mainstream financial system. However, they are equally clear that firms unable or unwilling to comply will not be allowed to remain active.

What comes next for crypto companies in Spain

In the coming months, Spanish crypto firms face an intensive compliance effort. They must prepare the required documentation, upgrade internal controls, and file robust applications with the CNMV well ahead of the July 1, 2026 deadline to reduce the risk of delays or rejections.

The regulator encourages entities seeking authorization to apply early so both sides can refine reporting systems and supervisory processes before full enforcement. That said, companies missing the deadline, or failing to meet MiCA standards, will lose the ability to provide crypto services in Spain.

For a sector that has historically operated under lighter oversight, the shift is significant. Nevertheless, authorities argue that a clearer framework will help attract more stable, long-term participants while providing users with greater assurance that platforms meet consistent regulatory expectations.

Spain’s role in shaping the EU crypto market

Spain’s implementation strategy shows how national regulators are using MiCA to tighten oversight while offering a defined path to compliance. By publishing detailed cnmv guidance for casps and adopting the maximum transition period, the country is attempting to balance market continuity with stronger investor protection.

For local users and businesses, the outcome will likely be a more transparent and supervised market, albeit one with fewer providers. Once the transition ends and full passporting rights are in place, companies that have secured authorization will be able to operate more easily across the EU, while those that fall short will be forced to exit.

Overall, Spain approach suggests that MiCA regulation will not only raise standards at home but also influence the structure of the broader European crypto ecosystem, concentrating activity among firms capable of meeting rigorous regulatory expectations.