Cross-border client
The client who moves to Lisbon
“One of my best clients is moving to Portugal and wants to stay with me. Without an EU passport I cannot serve them there: my national license has become my ceiling.”
Convert an EAFN into an EAF: When and How to Make the Move
The EAFN was the entry door; the EAF is the license for growth: EU passport, investment firm (ESI) status and institutional credibility. We explain what changes in capital, prudential rules and reporting, and how the change is processed with the CNMV without slowing down your business.
Outgrowing your EAFN? We assess the move for free
Tell us where your clients are and where the business is heading: we will tell you whether the upgrade pays off and what your application would require.
- 50+ entities advised
- Reply within 24 h
- No commitment
- EAF initial capital
- €75,000
- EAFN capital
- €50,000
- Maximum CNMV time limit
- Up to 6 months
- IFR prudential class
- Class 3
Roadmap
What goes into moving from EAFN to EAF
The upgrade pulls four levers at once: license type, capital, prudential regime and application. This is how we work on each one.
Target license
EAF authorization
Becoming an EAF means joining the investment firm (ESI) category: we prepare the application, adapt your articles of association and program of activities, and defend the application before the CNMV until registration.
See more →
ESICNMV€75,000MiFID II
What you gain
The investment firm EU passport
The number one reason for the change: providing advice in other EU Member States through the free provision of services or a branch, with the relevant notifications made through the CNMV.
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EUFree provisionBranchNotification
Starting license
EAFN: your starting point
Review the rules for the national license to measure the real distance between what you are and what you will be.
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€50,000Spain only
Prudential
IFR/IFD regime
As an investment firm (ESI), you will take on the full prudential framework: own funds, liquidity and reporting according to your class.
See more →
Class 3Own funds
Application
Program of activities
The document you will need to rewrite: same business, new license, new resources to prove.
See more →
UpdateCNMV
Afterwards
EAF obligations
The day after the change: more reporting, the same MiFID II requirements and a busier compliance calendar.
See more →
ReportingCompliance
Turning points
When an EAFN starts calling for a change
Changing license type is rarely a whim: the business forces it. These four situations are the ones that have most often brought an EAFN to our table.
Institutional partner
The investor that requires investment firm status
“A financial group wants to take a stake, but its due diligence requires an entity with European investment firm status. The EAFN does not fit for them; the EAF does.”
Scale
The business that can now carry the structure
“With our current recurring revenue, the difference in capital and compliance between an EAFN and an EAF no longer scares me. What costs me money is not being able to sign clients outside Spain.”
Partnerships
The European platform that demands a full license
“To integrate with a European distribution platform, we are being asked for a license with a passport. That deal alone justifies the conversion application.”
Before the move
The three typical mistakes when planning the conversion
The upgrade goes wrong when it is treated as a form rather than a regulatory project. These are the mistakes that make it most expensive.
Crossing the border too early: serving a client established in another EU Member State from an EAFN means operating outside the scope of your license, which covers Spain only. The right order is first the EAF with a passport, then the European client.
Looking only at capital: going from €50,000 to €75,000 is the easy part. The real cost lies in the full IFR/IFD prudential regime: permanent own funds, liquidity, governance and reporting that your structure must be able to produce every financial year.
Recycling the old application: filing the EAFN program of activities with a couple of tweaks invites requests for information. The CNMV will assess a new investment firm: organization, resources and policies must be described at the level of the target license.
| Area | EAFN | EAF |
|---|---|---|
| Scope of activity | Spain only: a national license without an EU passport and without investment firm (ESI) status. | The whole EU through the EU passport (free provision of services or a branch), as a full investment firm (ESI). |
| Initial capital | €50,000, with professional liability insurance or a combination of both accepted as an alternative. | €75,000 paid up, with no insurance alternative, plus the applicable permanent own funds. |
| Prudential regime and reporting | Requirements adapted to its status as a national license, with a lighter reporting burden. | Full IFR/IFD framework (usually Class 3): own funds, liquidity, governance and periodic prudential reporting. |
Turn the upgrade into a project with a timeline
We measure the gap between your EAFN and the EAF you need (capital, governing bodies, policies and resources), put together the conversion application and defend it before the CNMV while you keep advising your existing clients.
Frequently asked questions
Moving from EAFN to EAF, question by question
Why convert my EAFN into an EAF if the business is working?
For two reasons an EAFN cannot give you. The first is the EU passport: as a national license, an EAFN operates only in Spain, whereas an EAF can provide advice throughout the EU after making the relevant notifications. The second is status: an EAF is an investment firm (ESI), and that label carries weight with institutional partners, banks, fund managers and sophisticated clients.
If your clients, your partnerships or your client acquisition point outside Spain, conversion stops being optional: it is the condition for growing lawfully. We explain this in detail in the investment firm EU passport.
How much additional capital do I need?
Initial capital goes from €50,000 to €75,000. There is an important nuance: in an EAFN, those €50,000 could be replaced by professional liability insurance or a combination of capital and insurance; in an EAF, capital means capital.
In addition, as an investment firm (ESI) you will be subject to the permanent own funds requirement of the IFR/IFD regime, generally linked to your fixed overheads. It is worth projecting it against your forecasts before filing anything: the supervisor will want to see that the figure holds up over time, not just on the day of the application. More detail in IFR/IFD and regulatory capital.
How is the change processed with the CNMV?
Depending on the case, the conversion is structured before the CNMV as a new authorization as an investment firm (ESI) or as an amendment to the existing regime, with an application that proves every requirement of the target license: capital, fit and proper post-holders, an updated program of activities, MiFID II policies and an adequate organization.
In practice, it works as a full-fledged authorization project, with the advantage that you already have a supervisory track record and a structure up and running: well presented, that history works in your favor. The general framework of the procedure is explained in investment firm (ESI) authorization.
How long does the process take?
For investment firm authorizations, the CNMV has a general decision period of up to 6 months from the time it has the complete application. The real length of your project will depend above all on prior preparation: how long it takes you to finalize capital, post-holders and policies, and how many requests for information to remedy deficiencies the application triggers.
Our practical recommendation: do not file until the dossier withstands a first reading without gaps. Each round of requests for information extends the timeline far more than the weeks spent preparing better.
Can I keep advising my clients while the application is processed?
Yes, within the scope of your current license: while you are an EAFN, you can keep providing investment advice in Spain, exactly as you have until now.
What you cannot do is bring forward the activity of the future license: no clients established in other EU Member States and no activity that requires the passport before you have it. A well-planned conversion does not interrupt the business; it simply does not expand it until the effective date.
What happens to my current contracts and clients?
Continuity is one of the goals when designing the transaction. Depending on how the change is structured, you will need to review the contractual documentation (name, references to the license type, pre-contractual information) and clearly inform clients of whatever is required.
It is also a good time to update the financial advisory agreement and the cost information: clients should recognize the same firm with a better license, not a different entity.
Does anything change with FOGAIN when you become an EAF?
Membership of FOGAIN is not new with the change: since Law 6/2023, both EAFs and EAFNs must be members of the fund, which covers investors up to €100,000 in the cases provided by law.
When you convert, you will keep that membership under your new status, with the contributions that correspond to your activity. What matters is coordinating the notification of the change and checking that client information on coverage remains accurate.
What if staying an EAFN makes more sense for me?
That is a perfectly valid conclusion. If your client base is and will remain Spanish, an EAFN offers the same service with less capital tied up and a lighter compliance burden. The upgrade only pays off when the passport or investment firm status generates revenue or deals that cover the extra cost.
Our advice: decide based on a three-to-five-year business plan, review the decision every financial year and do not make the move for prestige. If you have doubts about the license type from the outset, the full analysis is in how to set up an EAF.
Process
Converting an EAFN into an EAF, from decision to registration
We treat the change of license for what it is: an investment firm authorization with a prior history. Three stages and a ten-step checklist.
Gap analysis
We compare your current situation (capital, governing bodies, policies, resources, reporting) with what an EAF requires. That comparison produces the real work list for the project and its timeline, with no surprises halfway through.
New-license application
We rewrite the program of activities to investment firm standard, strengthen MiFID II and AML/CFT policies, document the fitness and propriety of post-holders and finalize the financial plan with the own funds required under the IFR/IFD regime.
Filing and go-live
We file with the CNMV, handle requests for information and, once authorized, carry out the go-live: registers, contracts, client communications and, where applicable, the first EU passport notifications.
The EAFN-to-EAF upgrade in 10 steps
- Business case: put numbers on the reason for the move: which clients, deals or markets justify the extra cost of being an investment firm.
- Gap analysis: compare your current capital, governing bodies, policies and resources with the EAF requirements and list the differences.
- Capital plan: organize the move from €50,000 (or professional liability insurance) to €75,000 paid up and project the permanent own funds.
- Governance and suitability: check whether directors and general managers meet the standard of the new license and document that they are fit and proper.
- Program of activities: rewrite it at investment firm level, with services, clients, organization, resources and controls consistent with one another.
- Policies and manuals: update the MiFID II and AML/CFT package to the standard of the target license, with evidence of real application.
- Prudential reporting: prepare processes and systems to produce the periodic IFR/IFD information from day one.
- CNMV application: file the complete application and handle requests for information with fast, consistent answers.
- Go-live as an EAF: after authorization, adjust registers, contracts, website and client information to your new status.
- EU passport: notify, through the CNMV, the Member States where you will provide services and launch the expansion that started it all.
Want us to run the whole project? Start with EAF authorization; if you are still weighing license types from scratch, the overview is in how to set up an EAF and in EAFN authorization.
Free resource · PDF
Download the 10-step EAF Checklist
The 10 steps to set up your Financial Advisory Firm (EAF) before the CNMV, with the evidence you must be able to show at each one. Keep it at hand throughout the project.
- The 10 steps, from idea to authorization
- The evidence the CNMV expects at each step
- License comparison table: EAFN, EAF and securities broker (agencia de valores)
- Professional PDF · 5 pages · 11 KB
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Working glossary
Terms you will master during the conversion
The license-change application has its own language. These nine concepts will come up in every conversation with the supervisor and with your partners.
EAFNOrigin
The national license
National financial advisory firm created by Law 6/2023: it advises only in Spain, without investment firm (ESI) status or an EU passport.
Capital: €50,000 or professional liability insurance.
EAFDestination
The advisory investment firm
Investment firm (ESI) specializing in investment advice, with access to the European market.
Initial capital: €75,000.
ESIStatus
What you become
The European category of investment firm. It involves full supervision, the IFR/IFD prudential regime and passporting rights.
The EAFN falls outside this category.
EU passportBenefit
Operating across the EU
The right of an authorized investment firm to provide its services in other Member States, after a notification channeled through the CNMV.
The main reason for most upgrades.
Free provision of servicesMethod
Services without an establishment
Passport method for serving clients in another Member State without opening an office there. The usual route for EAFs that expand.
The alternative with an establishment is a branch.
IFR/IFDPrudential
The framework you take on
Regulation (EU) 2019/2033 and Directive (EU) 2019/2034: capital, own funds, liquidity, remuneration and reporting of investment firms.
EAFs usually fall into Class 3.
Class 3Prudential
Small and non-interconnected
Investment firm category with a simplified prudential regime. Even so, it requires permanent own funds and reporting the EAFN never had.
Simplified does not mean light.
Permanent own fundsCapital
The ongoing requirement
Minimum level of own funds that an investment firm must maintain at all times, generally linked to its fixed overheads.
It is projected in the financial plan of the application.
Conversion applicationProcedure
Your application to the CNMV
The set of documents proving that you meet every EAF requirement: capital, fit and proper post-holders, program of activities and policies.
It is processed as a new authorization or as an amendment, depending on the case.
Upgrade playbook
What the CNMV will review in your license change
Capital and solvency
That the €75,000 is paid up and that your forecasts sustain the IFR/IFD permanent own funds over the coming financial years.
Proof of payment, a projected financial plan and a calculation of the prudential requirements for your class.
Program of activities
That the description of services, clients, organization and resources corresponds to an investment firm, including cross-border activity if you plan it.
A program rewritten to EAF standard, consistent with contracts, website and actual processes.
Governance and suitability
That directors and general managers maintain good repute, knowledge and experience at the level of the new license, and that the governance structure is proportionate.
Updated fit and proper files, an organizational chart and rules of operation for the governing bodies.
MiFID II and AML/CFT policies
That suitability, conflicts of interest, inducements, costs and anti-money laundering are not just on paper: they work and leave a trail in day-to-day operations.
Versioned manuals, records of tests and conflicts, and evidence of application with real clients.
Reporting capacity
That you will be able to produce the prudential and activity information your new status requires, with defined processes and assigned owners.
Procedures for preparing reporting statements, an internal filing calendar and support tools.
Signs that the time for the upgrade has come
If two or more of these statements describe your situation, the gap analysis is no longer premature: it is urgent.
- You have clients (or firm prospects) residing or with interests in other EU Member States.
- A partner, bank or platform makes the deal conditional on you being an investment firm.
- Your recurring revenue would comfortably cover the capital and compliance of an EAF.
- You are turning down cross-border opportunities because you do not have an EU passport.
- Your client acquisition plan for the coming years places part of your growth outside Spain.
Context
Pages that complete your growth decision
Moving from EAFN to EAF is one of several growth routes within the securities market license map. Before committing to a timeline, compare your case with the alternatives and with the life that awaits you as an investment firm.
From scratch
How to set up an EAF
The complete guide to the target license: requirements, application and launch. Useful for gauging how demanding the investment firm standard is.
See the guide →
RequirementsApplication
Alternative
EAF vs securities broker
If, as you grow, you also want to handle orders or place products, your move may not be to an EAF but to a securities broker (agencia de valores).
Compare license types →
RTO€150,000
Life afterwards
EAF obligations
Reporting, audit, FOGAIN, training and policy updates: the compliance calendar you will take on.
See the details →
ComplianceCNMV
Expansion
The investment firm EU passport
How notification works, which methods exist and what operating in other Member States involves after authorization.
See the mechanism →
EUNotifications
We are the firm that handles the entire project: from the initial EAFN authorization to the EAF authorization and its EU passport, including the program of activities and day-to-day MiFID II compliance.
Contact
Book a call
Explain your situation as an EAFN and we will map out the path to operating as an EAF with an EU passport.
From EAFN to EAF: legal framework and strategy for changing license type
Law 6/2023 of March 17 created a two-speed system for financial advice in Spain: the EAFN, a national license designed to operate only in Spain with moderate entry requirements, and the EAF, a full investment firm (ESI) with access to the European market. Many projects start as an EAFN precisely because the legislature designed that entry door; the question arises a few years later, when clients, partners or alliances ask for what the national license cannot provide. Converting is not starting from scratch, but it is not a mere name change either: it means proving to the CNMV that your organization meets the investment firm standard set by Royal Decree 813/2023.
What you gain: passport and status
The decisive functional difference is the EU passport: an EAF, as an investment firm, can provide advice in other Member States under the free provision of services or through a branch, with notifications channeled through the CNMV; an EAFN, a strictly national license, cannot. Add to that an intangible that carries weight in every negotiation: investment firm status, which makes it easier to reach agreements with banks, fund managers, platforms and institutional partners used to requiring counterparties with a European license. We explain the expansion mechanism in the investment firm EU passport.
What changes: capital, prudential rules and reporting
In figures, initial capital rises from €50,000 (which an EAFN can replace with professional liability insurance or a combination of both) to €75,000. In terms of regime, the leap is bigger: an EAF becomes subject to the IFR/IFD prudential framework (Regulation (EU) 2019/2033 and Directive (EU) 2019/2034), with permanent own funds generally linked to fixed overheads, liquidity requirements, proportionate governance and remuneration rules, and periodic prudential reporting; EAFs usually fall into Class 3, small and non-interconnected firms. The reporting burden toward the CNMV grows accordingly, and the structure must be able to produce it on a recurring basis. The details of the framework are in IFR/IFD and the ongoing obligations in EAF obligations.
How the CNMV process works
Depending on the case, the change is structured as a new investment firm authorization or as an amendment to the entity’s regime, always on the basis of an application that demonstrates full compliance with the requirements of the target license: paid-up capital, fit and proper directors and general managers, a program of activities rewritten to EAF standard, operational MiFID II policies and an anti-money laundering system. The general decision period for investment firm authorizations is up to 6 months from the complete application, and the EAFN’s prior supervisory experience (reporting filed, no incidents, policies applied) is an asset worth documenting and leveraging in the application.
When it pays off (and when it does not)
Conversion pays off when there is real cross-border demand, a partner that requires investment firm status or an expansion plan that the passport unlocks; it is premature when it is driven only by image. Our professional view: quantify the business the EAFN prevents you from signing, compare it with the extra cost of capital and compliance, and decide based on a three-to-five-year plan. If the conclusion is to stay, the EAFN is still an efficient license; if it is to make the move, plan the application well in advance and without slowing down your business. And if you are choosing a license type from the start, the full overview is in how to set up an EAF.
Authorizations
Your conversion application
Official sources
Key legislation, linked to the official text:
- Law 6/2023 of March 17 on Securities Markets and Investment ServicesBOE · consolidated text
- Royal Decree 813/2023 of November 8 on the legal regime of investment firms and other entities providing investment servicesBOE · consolidated text
- Regulation (EU) 2019/2033 of November 27, 2019 on the prudential requirements of investment firmsEUR-Lex · Official Journal of the EU
Legislation and links reviewed in .