CNMV MiCA authorization checklist for CASPs in Spain
Spain's MiCA transitional period ended on July 1, 2026. Crypto-asset service providers now need CNMV authorization or a valid MiCA passport from another EU member state to operate in Spain.
This 85-item checklist covers the authorization process from start to finish. Each requirement includes its legal basis, the documents applicants must prepare and the issues most likely to delay approval.
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About the report
Applying for authorization as a crypto-asset service provider (CASP) in Spain involves extensive documentation across governance, financial resources, compliance and operational controls.
Range's CNMV authorization checklist organizes the process into 85 actionable requirements across 15 sections. It explains what applicants need to demonstrate, which documents to submit and where the CNMV and ESMA expect greater scrutiny.
Designed for legal, compliance, risk and operations teams, the checklist helps assign responsibilities, track progress and identify gaps before filing. It covers Spanish applicants and international firms seeking authorization to operate in Spain.
Each requirement maps to its legal basis, including MiCA, EU technical standards, DORA, Spain’s AML framework, and CNMV guidance. The report also addresses the changes introduced by Royal Decree 813/2026, effective October 28, 2026, and identifies outstanding questions to confirm directly with the CNMV.
Based on primary regulatory sources from EUR-Lex, the BOE, the CNMV and ESMA.
This checklist is a working guide and does not constitute legal advice.
Inside the report
- 01Governance and business planning: Corporate structure, staffing and three-year business plan.
- 02Capital requirements: Minimum thresholds by CASP class and supporting evidence.
- 03Management suitability: Fitness assessments for directors and shareholders.
- 04AML/CFT: SEPBLAC, customer due diligence and the Travel Rule.
- 05ICT and DORA: Cybersecurity, operational resilience and business continuity.
- 06Client asset protection: Custody, segregation, conflicts and outsourcing.
- 07Service-specific requirements: Required policies and wind-down planning.
- 08Application process: CNMV forms, filing procedures and approval timelines.
- 09Open questions: Outstanding points to confirm with the CNMV.
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