Currency Exchange Business Registration in Spain and Money Transfers

We help you open a currency exchange establishment—buying and selling foreign banknotes and traveler's checks—with Bank of Spain authorization and registration (Royal Decree 2660/1998). And if what you want is to send money abroad, we explain why that is now a payment service that requires you to be a payment institution (PSD2), not a currency exchange establishment.

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Decision timeline
3 months
Registration deadline
6 months
Key legislation
Royal Decree 2660/1998
Authorizing authority
Bank of Spain

Who each regime is for

Physical currency exchange offices, businesses that buy foreign currency, remittance platforms or banks: each activity has its own regime. Identifying yours is the first step to avoid applying for the wrong authorization.

exchange office

Physical currency exchange office

"A currency exchange office at an airport or in a tourist area that buys and sells foreign banknotes and traveler's checks needs Bank of Spain authorization and entry in the Register of Currency Exchange Establishments."

banknote purchases

Business that buys foreign currency from customers

"Buying foreign banknotes against payment in euros, even as a sideline to another business, requires Bank of Spain authorization and making the service clearly distinguishable to customers."

remittances

Money transfer platform (remittances)

"Sending or receiving money to or from abroad is money remittance: it is now a payment service and requires authorization as a payment institution, or acting as an agent of one, under PSD2, not currency exchange registration."

credit institution

Bank that already exchanges currency

"Credit institutions fall outside the Royal Decree 2660/1998 regime: they can exchange currency for their customers without registering as a currency exchange establishment, as they are already authorized and supervised."

Why is the regime everything here?

Applying for currency exchange registration when your business is sending money (or the other way around), operating without authorization or neglecting anti-money laundering are the failures that most hold back, and most expose, this business.

Two different regimes: physical banknote exchange goes through the Bank of Spain register; sending money abroad goes through the payment institution regime (PSD2). They are not interchangeable.

Timeline 3 months

The Bank of Spain decides on the authorization within 3 months. If that period ends without an express decision, the application is deemed rejected (negative administrative silence).

Registration before operating: after authorization, you have 6 months to incorporate the company and register in the Register of Currency Exchange Establishments, via the Commercial Registry, before you start.

Buying and selling banknotes cannot be delegated: although agents can be used for certain operations, buying and selling foreign banknotes and traveler's checks cannot be entrusted to agents.

Form and capital: selling banknotes requires a public limited company (S.A.), minimum capital and an exclusive corporate purpose, with directors who meet the fit and proper standards of the financial sector.

AML/CFT and transparency: the establishment is an obliged entity under anti-money laundering rules and must publish exchange rates, fees and charges and keep the transaction record for 6 years.

Do you exchange currency or send money?

The whole project depends on the answer: currency exchange registration with the Bank of Spain or authorization as a payment institution. Clarify this before you take the first step so you do not apply under the wrong regime.

Currency exchange: common questions

What is a currency exchange establishment?

It is a natural or legal person, other than a credit institution, that buys and sells foreign banknotes and traveler's checks on premises open to the public. Its activity is authorized and supervised by the Bank of Spain.

It is governed by Royal Decree 2660/1998 and its implementing rules.

Who grants authorization and where do I register?

Authorization is granted by the Bank of Spain, and the entity must register in the Register of Currency Exchange Establishments kept by the Bank of Spain itself, after registration with the Commercial Registry.

Are money transfer services (remittances) covered here?

Not today. Sending and receiving money to and from abroad (money remittance) is a payment service governed by PSD2 rules: it requires authorization as a payment institution or acting as an agent of one. The register of currency exchange establishments focuses on physical banknote exchange.

What legal form and capital do I need?

It depends on the activity. Buying foreign banknotes against payment in euros has simpler requirements and can be done by a natural or legal person. Selling banknotes requires a public limited company (S.A.) formed by simultaneous incorporation, minimum capital and an exclusive corporate purpose.

How long does authorization take?

The Bank of Spain decides within 3 months; if that period ends without an express decision, the application is deemed rejected (negative administrative silence). After authorization, you have 6 months to incorporate the company and register in the Register of Currency Exchange Establishments.

Can I use agents?

For some operations, yes, with powers of attorney executed before a notary and entered in the register. But there is a clear limit: buying and selling foreign banknotes and traveler's checks cannot be entrusted to agents.

What obligations do I have once authorized?

You are an obliged entity under anti-money laundering rules, you must publish exchange rates, fees and charges at each location, record transactions and keep the documentation for 6 years, and you must also send periodic information to the Bank of Spain.

Does a bank need to register as a currency exchange establishment?

No. The Royal Decree 2660/1998 regime does not apply to credit institutions, which can exchange currency for their customers without registering as a currency exchange establishment, as they are already authorized and supervised.

Buying, selling, remittances and crypto

What is the difference between buying and selling foreign banknotes?

Buying (the establishment acquires foreign currency from the customer and pays in euros) has lighter requirements. Selling (handing foreign currency to the customer) requires a public limited company (S.A.), minimum capital and an exclusive purpose, because of its greater exposure.

How do I send money abroad legally?

Through an authorized payment institution or by acting as an agent of one. Sending money (money remittance) is a PSD2 payment service, separate from physical banknote exchange.

Are currency exchange offices AML obliged entities?

Yes. Currency exchange establishments are among the obliged entities under anti-money laundering and counter-terrorist financing rules.

What is a traveler's check?

A means of payment in foreign currency, issued in fixed amounts, that the customer can redeem for cash. Buying and selling them is part of the typical activity of a currency exchange establishment.

Can I exchange currency as a sideline to my business?

Yes, with Bank of Spain authorization. If currency is bought on the same premises as another activity, measures must be taken so that the customer can clearly identify who provides the exchange service.

Does cryptocurrency exchange fall under this regime?

No. Crypto-assets are not foreign currency for these purposes; exchanging them for money is governed by the MiCA regime and crypto-asset service providers (CASPs), not by the currency exchange regime.

Banknote exchange, remittances or bank

The same idea of "moving currency" hides different regimes depending on the transaction. This comparison shows which one is yours and which authority to apply to.

What determines your regime

Whether you exchange physical banknotes or move money between accounts makes the difference. These are the factors that decide your route.

Transaction
Exchanging physical banknotes (exchange) or sending money abroad (payment).
Authority
The Bank of Spain, under one framework or another depending on the transaction.
Form
Natural/legal person or public limited company (S.A.), depending on whether you buy or sell.
AML/CFT
Obliged entity in all cases, with customer identification.

How we handle the project

Before filing anything, we settle your regime: banknote exchange or money transfers. That way you avoid filing the wrong application and losing months.

  1. Analysis of the transaction and the regime (exchange or payment institution).
  2. Legal form, capital, fit and proper requirements and AML/CFT.
  3. Application to the Bank of Spain, authorization and registration.

Tell us about your project →

Comparison of regimes: buying banknotes, buying and selling, money transfers and credit institutions
Activity What it involves Where it is authorized / registered Legal form
Buying foreign banknotes Acquiring foreign currency in cash from the public (payment in euros) Bank of Spain — Register of Currency Exchange Establishments Natural or legal person
Buying and selling banknotes Buying and selling banknotes and traveler's checks Bank of Spain — Register of Currency Exchange Establishments Public limited company (S.A.), minimum capital, exclusive purpose
Money transfers (remittances) Transferring money to or from abroad (money remittance) Bank of Spain — as a payment institution (PSD2) Payment institution or agent of one
Exchange by credit institutions The bank exchanges currency for its customers Already authorized (not registered as a currency exchange) Credit institution

Indicative table for information purposes. Physical currency exchange is governed by Royal Decree 2660/1998 and its implementing rules; money transfers, by payment services legislation (PSD2 and Royal Decree-law 19/2018). Requirements, capital and timelines may vary and should be validated case by case with legal advice. This page is for information only and does not constitute advice.

How to set up a currency exchange business: a practical guide

Opening a currency exchange business is not just filing an application: it means identifying the regime, structuring the entity, evidencing fit and proper standards and anti-money laundering compliance, and obtaining authorization before registering. The order matters.

Regime

Regime first, paperwork second

Physical banknote exchange and sending money abroad are not the same. Identifying the transaction and the right legal vehicle is the first decision, and it keeps you from applying for the wrong thing.

Structure

Form, capital and fit and proper requirements

Selling banknotes requires a public limited company (S.A.), minimum capital and an exclusive purpose, with fit and proper directors. Buying has simpler requirements.

Registration

No registration, no activity

Entry in the Bank of Spain Register of Currency Exchange Establishments, after the Commercial Registry, is the condition for starting operations.

Checklist: setting up a currency exchange business in 10 steps

  1. Identify the activity (buying banknotes, buying and selling, or money transfers) and the applicable regime.
  2. If it is money transfers, route it through authorization as a payment institution (PSD2).
  3. For physical exchange, define the legal form (public limited company if you will sell) and the exclusive corporate purpose.
  4. Evidence the minimum capital required for the activity.
  5. Show that the directors are fit and proper and of good repute.
  6. Implement anti-money laundering measures (obliged entity) and transparency (rates, fees and charges).
  7. Prepare the documentation and the mandatory forms.
  8. File the authorization application with the Bank of Spain.
  9. Decision within 3 months (deemed rejected if there is no decision in time); incorporate and register in the Register of Currency Exchange Establishments within 6 months.
  10. Operate with a daily transaction record kept for 6 years, without entrusting the buying and selling of banknotes to agents.

Is your business sending money or issuing means of payment? See our pages on the payment institution license, PSD2 and the electronic money institution. For lending, see the financial credit establishment.

Currency exchange in operation

From regime to registration and activity

Setting up a currency exchange business is an ordered sequence (regime, structure, AML/CFT and transparency, application and authorization + registration) before the Bank of Spain. This is the path.

Identifying the regime: physical banknote exchange or money transfers1) Regime

Regime: the first decision

Physical banknote exchange (Bank of Spain register) or sending money abroad (payment institution). The transaction defines the legal vehicle and the procedure.

  • exchange vs. remittances
  • buying vs. selling
  • right vehicle
Legal form, capital and fit and proper directors2) Structure

Form, capital and fit and proper requirements

Public limited company (S.A.), minimum capital and exclusive purpose for selling banknotes, with directors who are fit and proper and of good repute.

  • S.A. and exclusive purpose
  • minimum capital
  • fit and proper
Anti-money laundering and exchange rate transparency3) AML/CFT + transparency

Anti-money laundering and transparency

AML/CFT manual (obliged entity), disclosure of exchange rates, fees and charges, and a transaction record.

  • obliged entity
  • rates and fees
  • transaction record
Decision map: physical exchange or money transfersQuick decision

Map: physical exchange or remittances?

banknotes

Buying and selling foreign banknotes: Bank of Spain Register of Currency Exchange Establishments.

sending money

Sending and receiving money to and from abroad: authorization as a payment institution (PSD2).

bank

Credit institutions: they exchange currency without registering as a currency exchange establishment.

Playbook

Obligations of a currency exchange establishment

Obligation
What it requires
Note

Authorization and registration

Bank of Spain authorization and entry in the Register of Currency Exchange Establishments.

Prerequisite for operating.

Form and capital

Public limited company (S.A.), minimum capital and exclusive purpose for selling banknotes.

Buying has simpler requirements.

Anti-money laundering

Obliged entity: manual, internal control body and customer identification.

Under Law 10/2010.

Transparency

Publish the applicable exchange rates, fees and charges at each location.

Information visible to customers.

Recording and retention

Record transactions daily and send information to the Bank of Spain.

Retention for 6 years.

Common mistakes that hold the project back

Anticipate them before filing the application to avoid requests for information and rejection.

  • Applying for currency exchange registration when the real activity is sending money (payment institution), or the other way around.
  • Buying and selling banknotes before authorization and registration.
  • Entrusting the buying and selling of foreign banknotes or traveler's checks to agents.
  • Neglecting anti-money laundering despite being an obliged entity.
  • Not publishing exchange rates, fees and charges on the premises.
Working glossary

Key concepts: currency exchange

If you are going to open a currency exchange office or send money abroad, these terms come up in the application, in dealings with customers and in Bank of Spain supervision.

exchangebasics

Currency exchange establishment

A natural or legal person, other than a credit institution, that buys and sells foreign banknotes and traveler's checks on premises open to the public, authorized by the Bank of Spain.

Royal Decree 2660/1998.
buyingtransaction

Buying foreign banknotes

Acquiring foreign currency in cash from the customer against payment in euros. It has the simplest requirements and can be done by an authorized natural or legal person.

Art. 2(1) of Royal Decree 2660/1998.
sellingtransaction

Sale of banknotes and traveler's checks

Handing foreign currency to the customer. It requires a public limited company (S.A.), minimum capital and an exclusive corporate purpose, because of its greater exposure.

Art. 2(2) of Royal Decree 2660/1998.
remittancespayment

Money transfer services

Sending and receiving money to and from abroad (money remittance). It is now a payment service and goes through the payment institution regime, not the currency exchange regime.

PSD2 and Royal Decree-law 19/2018.
payment institutionPSD2

Payment institution

An entity authorized to provide payment services, including money remittance. It is the vehicle for anyone who wants to run remittances professionally.

Supervised by the Bank of Spain.
registerBank of Spain

Registration of currency exchange establishments

The Bank of Spain register in which the establishment must be entered, after the Commercial Registry, before operating. Registration is a requirement for starting.

6 months from authorization.
exclusive purposerequirement

Exclusive corporate purpose

An establishment that sells banknotes must have the buying and selling of currency as its exclusive corporate purpose, without prejudice to ancillary activities authorized by the Bank of Spain.

Art. 4(2) of Royal Decree 2660/1998.
agentslimit

Agents

The establishment can operate through agents with registered powers of attorney for certain operations, but not for buying and selling foreign banknotes and traveler's checks.

An express limit set by the rules.
2660/1998legislation

Royal Decree 2660/1998

Royal Decree on foreign currency exchange at establishments open to the public other than credit institutions. It is the core legislation of the regime.

Together with its implementing rules.

Guide to opening a currency exchange business or sending money

A practical guide to launching your currency business: how to tell physical exchange apart from money transfers, what authorization each one needs, what legal form and capital are required, and what AML/CFT and transparency obligations you will have to meet.

  • Banknote exchange vs. money transfers (remittances)
  • Bank of Spain authorization and registration
  • Legal form, capital, AML/CFT and transparency
Request the guide
Currency exchangePractical guide · PDF
Bank of Spain authorization and registration

Author

Diego Molina

Director of Molina Law Boutique · Financial regulation and payments

Advises currency exchange offices, retailers and money transfer platforms on the authorization of currency exchange establishments by the Bank of Spain and on fitting remittances into the payment institution regime (PSD2): legal form, capital, fit and proper requirements, anti-money laundering and transparency.

Tell us about your currency exchange project

Tell us whether you will exchange physical banknotes or send money abroad, and we will tell you the applicable regime, the right legal vehicle and the requirements to apply to the Bank of Spain.

Regulatory framework for currency exchange

The buying and selling of foreign banknotes and traveler's checks on premises open to the public, by entities other than banks, is governed by Royal Decree 2660/1998, the Order of November 16, 2000 and Bank of Spain Circular 6/2001. Credit institutions are excluded from this regime. Sending money abroad, by contrast, is a payment service subject to PSD2 rules and Royal Decree-law 19/2018.

Two regimes

Two activities that are often confused should be kept apart: physical currency exchange (buying and selling banknotes) is authorized and entered in the Bank of Spain's Register of Currency Exchange Establishments; sending money (money remittance) requires being a payment institution or acting as an agent of one.

Authorization and registration

Authorization is granted by the Bank of Spain and decided within 3 months; if that period ends without a decision, the application is deemed rejected (negative administrative silence). After authorization, you have 6 months to incorporate the company, register it with the Commercial Registry and enter the establishment in the Register of Currency Exchange Establishments.

Form, capital and exclusive purpose

Buying foreign banknotes against payment in euros has simpler requirements and can be done by a natural or legal person. Selling banknotes requires a public limited company (S.A.) formed by simultaneous incorporation, minimum capital and an exclusive corporate purpose, with directors who meet the fit and proper and good repute standards of the financial sector.

Anti-money laundering, transparency and agents

The establishment is an obliged entity under anti-money laundering rules and must publish exchange rates, fees and charges, record transactions daily and keep those records for 6 years. It may operate through agents with registered powers of attorney for certain operations, but not for buying and selling foreign banknotes and traveler's checks.

Royal Decree 2660/1998 Order of November 16, 2000 Circular 6/2001 PSD2 Royal Decree-law 19/2018 Law 10/2010 Bank of Spain