TargetStep 1
We choose the entity
We check the license, the authorized services, the agents and the EU passport of each candidate in the official registers.
Registers of the Bank of Spain and the CNMV.
Buy a Payment Institution, EMI, EAF or CASP in Spain
If you would rather buy an already authorized entity than apply for a license from scratch, we support you through the whole transaction: regulatory due diligence, notification of the acquisition to the Bank of Spain or the CNMV, fit and proper assessment of the new shareholders and directors, the purchase agreement, and closing.
Want to buy an authorized entity?
Tell us which license you are looking for, what stage the deal is at and which country you are buying from, and we will reply with the steps and a tailored quote.
- Reply within 24 h
- No commitment
- Confidential
- Qualifying holding
- 10%
- New thresholds to be notified
- 20, 30 and 50%
- Supervisor assessment period
- 60 business days
- If the supervisor does not reply
- Non-objection
What we do
The whole purchase of a regulated entity, from due diligence to closing
The license is not for sale: it belongs to the entity. What you buy is its shares, and the supervisor must not object to you becoming the new shareholder.
Due diligenceStep 2
Regulatory due diligence
We review files, requests for information and inspections, AML/CFT, safeguarding of funds, outsourcing, DORA and sanctions.
Before you sign.
StructureStep 3
Structure of the purchase
We design the transaction and the contract terms: the supervisor's non-objection as a condition, warranties and price.
Purchase agreement.
SupervisorStep 4
Notification of the acquisition
We prepare the notification to the Bank of Spain or the CNMV with the acquirer's information, its financial soundness and the business plan.
Law 10/2014, Law 6/2023 and MiCA.
Fit and properStep 5
New directors
If the board or management changes, we prepare the evidence of their good repute, knowledge and experience.
Fit and proper assessment of senior officers.
ClosingStep 6
Closing and integration
We sign after non-objection, update registers and policies, and adapt the entity to the new group.
After the purchase.
Scenarios
When it makes sense to buy instead of applying for a license
Buying is not always faster or cheaper. These are the cases in which it usually pays off.
Time
You need to operate soon
Applying for a license requires preparing a complete application and waiting for the decision. Buying an already authorized entity replaces that process with the assessment of the acquisition.
Abroad
You come from outside the EU
Groups from Latin America, the United Kingdom or Asia buy a Spanish entity to operate in Spain and, with the EU passport, in the rest of the Union.
Growth
You want to add services to your group
A fintech or a bank buys a payment institution, an EMI or an EAF to add a license it does not have.
Seller
You are the seller
If you are going to sell your entity, preparing the information the buyer and the supervisor will ask for shortens the transaction considerably.
What the law says
Buying a regulated entity, in figures
Data from Law 10/2014, Royal Decree 84/2015, Royal Decree-law 19/2018, Law 21/2011, Law 6/2023 and the MiCA Regulation.
Art. 16 Law 10/2014
10%
Qualifying holding: 10% of the capital or voting rights, or less if it allows significant influence.
Art. 17 Law 10/2014
20, 30 and 50%
You must also give prior notice each time these percentages are reached or exceeded, or control is acquired.
Art. 25.3 RD 84/2015
60 business days
Maximum period for the Bank of Spain to object, counted from the acknowledgment of receipt of the complete notification.
Art. 25.5 RD 84/2015
Silence
If there is no decision within that period, the acquisition is deemed not to be objected to.
Art. 17.5 RDL 19/2018 and Art. 21 Law 21/2011
Same regime
Payment institutions and electronic money institutions follow the qualifying holding regime before the Bank of Spain.
Art. 83 MiCA
60 business days
Assessment period for the acquisition of a CASP; if the authority does not object, the acquisition is deemed approved.
Considering buying an authorized entity?
We help you review the entity before you sign and prepare the notification to the supervisor so that the deal closes on time.
Frequently asked questions
Buying a regulated entity: frequently asked questions
Can you buy a payment institution or EMI license?
The license cannot be transferred separately: it belongs to the authorized entity. What you buy is its shares. That is why the transaction requires the Bank of Spain not to object to the buyer acquiring a qualifying holding (Art. 17 of Royal Decree-law 19/2018 for payment institutions and Art. 21 of Law 21/2011 for electronic money institutions).
When must the purchase be notified to the supervisor?
Before closing, when you are going to acquire a qualifying holding (10% of the capital or voting rights, or less if it gives significant influence) or to exceed 20, 30 or 50%, or control of the entity (Arts. 16 and 17 of Law 10/2014). We explain it in qualifying holding.
How long does the supervisor take?
For credit institutions, payment institutions and electronic money institutions, the Bank of Spain has a maximum of 60 business days from the acknowledgment of receipt of the complete notification, which it must send within 2 business days; if it does not rule, it is deemed not to object (Art. 25 of RD 84/2015). For a CASP, MiCA also sets 60 business days (Art. 83).
What does the supervisor look at in the buyer?
The good repute and experience of the acquirer and of those who will run the entity, its financial soundness, whether the entity can keep meeting its prudential requirements, and whether there are any indications of money laundering or terrorist financing. The notification must prove all of this with documents.
What does regulatory due diligence cover?
That the license and authorized services are those advertised, open requests for information and inspections, AML/CFT, safeguarding of client funds, outsourcing, cybersecurity and DORA, complaints and sanctions. It is what most affects the price and the warranties in the contract.
What if I want to buy an EAF or an ESI?
The authority is the CNMV: it assesses the acquirer's suitability and the financial soundness of the transaction using the criteria of Delegated Regulation (EU) 2017/1943 (Arts. 152 to 157 of Law 6/2023). We also cover it in ESI authorization.
How much does the whole transaction cost and how long does it take?
It depends on the type of entity, its size and what the due diligence turns up. We give you a fixed quote by phases: due diligence, contract, notification to the supervisor and closing.
Practical guide
How we buy a regulated entity with you
A regulated purchase involves two negotiations at once: with the seller and with the supervisor.
Negotiation
Price, warranties and conditions, with non-objection as a condition to close.
Assessment
Complete notification, requests for information and assessment period.
Continuity
That it keeps complying during the transaction and after the change of shareholders.
Your purchase in 10 steps
- We define which license you need and which services and countries you want to cover.
- We check the candidate entities in the official registers.
- We sign a confidentiality agreement and request the information for due diligence.
- We carry out the regulatory, AML/CFT and corporate due diligence.
- We negotiate the contract with the supervisor's non-objection as a condition.
- We prepare the notification of the acquisition with all of the buyer's documentation.
- We handle the requests for information from the Bank of Spain or the CNMV.
- We prepare the fit and proper assessment of the new directors and managers.
- We close the purchase after non-objection or expiry of the period.
- We update the entity's registers, policies and contracts.
Source: Law 10/2014 (Arts. 16 and 17), Royal Decree 84/2015 (Art. 25), Royal Decree-law 19/2018 (Art. 17), Law 21/2011 (Art. 21), Law 6/2023 (Arts. 152 to 157) and Regulation (EU) 2023/1114 (Art. 83).
Working glossary
Key concepts in buying a regulated entity
Terms from Law 10/2014, Law 6/2023 and the MiCA Regulation.
HoldingThreshold
Qualifying holding
10% of the capital or voting rights, or less if it allows significant influence.
Art. 16 Law 10/2014.
Non-objectionDecision
Declaration of non-objection
The supervisor's response that allows the purchase to close; it also arises through silence.
Art. 25 RD 84/2015.
AcquirerPerson
Proposed acquirer
Whoever decides to buy a qualifying holding, alone or acting in concert with others.
Art. 17 Law 10/2014.
Fit and properRequirement
Fit and proper assessment of senior officers
Good repute, knowledge and experience of directors and managers.
Sector regulations.
Due diligenceReview
Regulatory due diligence
Review of the entity's regulatory compliance before buying it.
Market practice.
PassportEU
EU passport
The right of an entity authorized in Spain to operate in other EU Member States.
Sector directives.
Playbook
Who assesses the purchase, by type of entity
Payment institution
Supervisor: Bank of Spain.
Rule: Art. 17 RDL 19/2018, which refers to Law 10/2014 and RD 84/2015.
Electronic money institution (EMI)
Supervisor: Bank of Spain.
Rule: Arts. 4 and 21 of Law 21/2011.
Bank or credit institution
Supervisor: Bank of Spain, with the decision taken by the European Central Bank.
Rule: Law 10/2014 and RD 84/2015.
National ESI or EAF
Supervisor: CNMV.
Rule: Arts. 152 to 157 of Law 6/2023.
Crypto-asset service provider (CASP)
Supervisor: CNMV.
Rule: Arts. 83 and 84 of the MiCA Regulation.
Common mistakes when buying a regulated entity
These are the ones that most often delay or raise the cost of a transaction.
- Signing the purchase without making it conditional on the supervisor's non-objection.
- Not reviewing open requests for information and inspections.
- Filing an incomplete notification, which does not start the clock.
- Forgetting the fit and proper assessment of the new directors.
- Assuming the EU passport remains active in every country.
Contact
Book a call
Tell us which entity you want to buy or sell and what stage the transaction is at, and we will prepare a diagnosis and a tailored quote.
What the law says about buying a regulated financial entity
Updated November 4, 2026
Financial licenses are not bought: you buy the company that holds them. The law protects that license by requiring the supervisor to assess whoever is going to control the entity before they do so.
Payment institutions, EMIs and banks
Anyone who is going to acquire a qualifying holding (10% of the capital or voting rights, or less with significant influence) or to exceed 20, 30 or 50% must notify the Bank of Spain beforehand (Arts. 16 and 17 of Law 10/2014). The Bank of Spain acknowledges receipt within 2 business days and has 60 business days to object; if it does not rule, there is no objection (Art. 25 of RD 84/2015). Payment institutions follow this regime (Art. 17 of RDL 19/2018) and electronic money institutions follow the one in their own law (Art. 21 of Law 21/2011). Before buying, review what each license involves in payment institution license and EMI license.
EAFs, ESIs and CASPs
For investment firms and national EAFs, the CNMV assesses the acquirer's suitability and the financial soundness of the transaction (Arts. 152 to 157 of Law 6/2023). For a crypto-asset service provider, MiCA sets a 60-business-day assessment period and approval if the authority does not object (Art. 83).
Due diligence
Reviewing the entity is the other half of the transaction: license, requests for information, AML/CFT, safeguarding of funds and sanctions. We do it with the same approach as in legal due diligence, focused on regulatory matters. If you are looking at another route, compare it with setting up a fintech and applying for the license from scratch.