The decision is not about capital, it is about services: if you only issue personalized recommendations, an EAF is enough; if you also handle orders, place products or want to grow through agents, your license type is the securities broker (agencia de valores). We help you decide with your business plan in front of us.
Torn between an EAF and a securities broker? Free assessment
Tell us what you will do with each client and we will tell you which license type fits, how much capital it requires and what structure you will have to maintain.
Each license defines what you will be able to do for years. These are the pieces involved in the decision and how we support you with each one.
For models that, in addition to advising, receive and transmit orders, execute transactions on behalf of others or place instruments. We design the program of activities, the control structure and the complete application to the CNMV.
If your value proposition is personalized recommendations and the client executes on their own, an EAF focuses the license on what you actually do: less capital, less structure and a narrower application.
A securities broker with a limited program of activities: fewer services, fewer resources to demonstrate. We analyze whether your model can take advantage of it.
The process common to both license types: application, fit and proper assessment, policies and a CNMV decision within a general timeframe of up to 6 months.
The sales channel that only some license types can use. Agreements, registration and supervision of the agent network.
If the balance tips toward pure advice, here is the full route: requirements, capital, application and timelines.
The same question comes from very different profiles. Look at the verb that defines each business: recommend, process orders, place or distribute.
“My client decides and executes at their bank; I provide the recommendation and the follow-up. I don’t need to touch the order, so paying for the structure of a securities broker would be throwing capital away.”
“I work with several fund managers and get paid for placing their funds with qualified investors. That is placing, not advice: my license has to be a securities broker license.”
“We want users to receive the proposal and confirm the transaction inside the app. As soon as we transmit that order to the broker, we are outside the EAF perimeter.”
“My client acquisition plan relies on a network of agents across the country. Since an EAF generally cannot appoint them, the license type that allows it is the securities broker.”
Applying for the wrong license type costs you twice: in capital and structure if your license is more than you need, and in sanction risk if it falls short. These are the mistakes we see most often.
Deciding on price: staying with an EAF because it requires less capital when your actual operations include handling orders puts you outside your license, and providing reserved investment services without authorization is a very serious infringement.
Oversizing “just in case”: applying for a securities broker license when you don’t need it doubles the initial capital, tightens the prudential regime and multiplies the resources you will have to demonstrate and maintain year after year.
Forgetting the sales channel: if your growth depends on a network of tied agents, the EAF is not your license type: as a general rule it cannot appoint them, and discovering this once the license is granted forces you to rebuild your strategy.
| License type | Initial capital | Services allowed |
|---|---|---|
| EAF | €75,000 | Investment advice. Does not handle orders or place products and, as a general rule, does not appoint tied agents. |
| Securities broker (agencia de valores) | €150,000 | In addition to advice: reception and transmission of orders, execution and placing, always on behalf of clients. Can appoint tied agents. |
| Broker-dealer (sociedad de valores) | €750,000 | The full range of investment services, including dealing on own account. The most structurally demanding license type. |
We review each client’s actual flow with you—who recommends, who places the order, who gets paid what—and translate it into the right license: EAF, securities broker or its simplified version. Then we prepare the application so the CNMV can approve it without surprises.
The scope of services. An EAF is licensed for a single investment service: investment advice, that is, recommending specific instruments to specific clients. A securities broker can, in addition to advising, receive and transmit orders (RTO), execute them on behalf of clients and take part in placing instruments.
Everything else hangs on that scope: initial capital (€75,000 vs €150,000), structure, technical resources and the ability to appoint tied agents.
As a general rule, no. Reception and transmission of orders is an investment service separate from advice and falls outside the EAF license: the client receives the recommendation and executes it themselves with their own institution.
If someone on your team channels the order to the intermediary, you are providing RTO without authorization to do so, and carrying out reserved investment services without authorization is a very serious infringement. In that scenario, the license type to consider is the securities broker.
Reception and transmission of orders consists of taking the client’s instruction and passing it on to whoever executes it (a broker, a fund manager, a market). Execution goes one step further: completing the transaction on the client’s behalf. And placing means distributing an issuer’s or a fund manager’s instruments among investors, usually in exchange for a commission.
All three are services reserved to entities authorized to provide them. If your model includes any of them, an EAF is not enough: you need a securities broker or, depending on the scope, another investment firm (ESI).
Broker-dealers and securities brokers can rely on tied agents to attract clients and promote their services; EAFs, as a general rule, cannot appoint them.
It is a decisive difference if your sales plan relies on an external network: the agent acts on behalf of the firm, is entered in the relevant register and remains under the firm’s responsibility and supervision. You will find the details in tied agents and agent registers.
Under the prudential regime for investment firms (IFR/IFD), the indicative initial capital is:
Initial capital is only the entry ticket: the firm must then maintain permanent own funds linked, broadly speaking, to its fixed overheads, as well as the liquidity and governance requirements that apply to it. We cover this in regulatory capital and the IFR/IFD regime.
It is not a separate legal category, but a securities broker with a limited program of activities: for example, RTO and advice without holding client money or instruments. With fewer services, the resources, controls and structure you must demonstrate are generally lighter.
It is an attractive route for light intermediation models that do not want to take on the infrastructure of a full-service broker. We explain it in simplified securities broker.
Yes. Expanding into additional services is processed with the CNMV through the corresponding amendment or new authorization, as the case may be, with an application that demonstrates the capital, resources and controls for the new operations.
However, each change of license type takes time and fees: if your three-to-five-year plan already includes handling orders or placing products, it usually pays to size the license correctly from the start. It is the same logic we apply to the move from EAFN to EAF.
The framework is the same—Law 6/2023, Royal Decree 813/2023 and the investment firm (ESI) authorization procedure before the CNMV, with a general decision period of up to 6 months from the complete application—but the content is not: more services mean more resources, more controls and more questions from the supervisor.
A securities broker will have to demonstrate order-handling systems, best execution and, if it holds client assets, asset safeguarding; an EAF focuses its effort on the advisory process. That is why the first step is always to pin down the scope of services.
Our method reduces the decision to three moves: map what you will actually do, put a price on each license and apply for the chosen one with a tailored application.
Draw a client’s full journey: who recommends, who enters the order, who pays whom. Each verb in that flow points to a specific investment service, and the sum of services points to a license type.
Compare initial capital, permanent own funds, minimum structure and annual compliance cost for an EAF and a securities broker. The license that is cheap to obtain may be expensive to maintain, and vice versa.
Once you have chosen the license type, the program of activities must reflect exactly those operations: no extra services that force you to demonstrate unnecessary resources, and no missing services that leave you outside your license with your first client.
Is it clear now? Start with EAF authorization or with the securities broker license; if your model is light intermediation, look at the simplified securities broker.
The 10 steps to set up your Financial Advisory Firm (EAF) with the CNMV, with the evidence you must be able to show at each one. Keep it at hand throughout the project.
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These are the terms that separate one license from another. Once you know which service each one is, choosing the license type almost takes care of itself.
Taking the client’s instruction and passing it on to whoever executes it. It is the service that most often takes a project outside the EAF perimeter.
Completing the transaction in the market on the client’s behalf. It requires systems, controls and a best execution policy that is genuinely applied.
Distributing third-party issues or products among investors, usually for a commission paid by the issuer or fund manager. A reserved activity.
A natural or legal person that attracts clients and promotes services on behalf of an investment firm (ESI), under the firm’s responsibility and entered in a register.
An investment firm (ESI) limited to investment advice: personalized recommendations without touching the order or the product.
An investment firm (ESI) that advises and also handles and executes orders and places instruments on behalf of clients, without dealing on own account. It can appoint agents.
An investment firm (ESI) with the full range of services, including dealing on own account. Much greater structure and requirements.
An ancillary service of safekeeping client money and instruments. Adding it to the program of activities significantly raises the controls required.
The application document that lists services, instruments and resources. What is not in it, you cannot provide; what is in it, you must be able to demonstrate.
If the client executes on their own after receiving your recommendation, you fit within an EAF; if your firm is involved in the order or in distribution, you need a securities broker.
Program of activities, client agreements and a description of the operational flow.
Advisory fees point to an EAF; placing or brokerage commissions presuppose services that only a securities broker can provide.
Fee schedule, cost disclosures and agreements with fund managers or issuers.
A network of tied agents requires a license type that can appoint them; with direct or digital client acquisition, an EAF remains an option.
Sales plan, agency agreements and entries in the agent registers.
Ability to pay in and maintain €75,000 or €150,000, plus the permanent own funds, liquidity and reporting of the applicable IFR/IFD class.
Three-year financial plan, calculation of prudential requirements and evidence that the capital has been paid in.
Each service adds infrastructure: order handling, best execution and, where applicable, asset safeguarding require systems that the supervisor will want to see described.
Organizational chart, operating procedures and description of systems in the application.
If you tick any of these boxes, review the license type before filing the application: you probably need a securities broker.
Choosing between an EAF and a securities broker is only one of the forks on the license map. Before committing capital, check your project against the other license types and growth paths in the Spanish securities market.
The full route if your license type is advice: requirements, capital, CNMV application and launch.
If you advise on family wealth, the prior question is different: do you even need a license? The boundary of the reserved activity.
The upgrade within advice: when to move from the national license to an investment firm (ESI) with an EU passport.
When the model requires dealing on own account or offering every investment service, the conversation moves into a different league.
Would you rather we look at it with you? Our team handles investment firm (ESI) authorization before the CNMV in all its forms: EAF, securities broker, simplified broker and portfolio management company.
Tell us which services you want to provide and we will tell you whether your project fits within an EAF or requires a securities broker.
Law 6/2023 of March 17 and Royal Decree 813/2023 of November 8 organize Spanish investment firms (ESIs) into four types: broker-dealer (sociedad de valores), securities broker (agencia de valores), portfolio management company and financial advisory firm (EAF). When an advisory or intermediation project seeks a license, the question almost always comes down to two of them: the EAF, specialized in personalized recommendations, and the securities broker, which adds operations on behalf of clients. Getting the choice right determines the capital you tie up, the structure you maintain and the regulatory risk you take on.
An EAF provides a single investment service: investment advice, understood as personalized recommendations on specific financial instruments. The client decides and executes on their own. A securities broker, by contrast, can also receive and transmit orders, execute them on behalf of clients and place instruments, always without dealing on own account (that territory belongs to the broker-dealer). The practical consequence: if your firm is involved in the transaction—even just by passing on the order—an EAF does not cover your activity.
Under the IFR/IFD prudential regime (Regulation (EU) 2019/2033 and Directive (EU) 2019/2034), the indicative initial capital is €75,000 for an EAF and €150,000 for a securities broker. From there, both must maintain permanent own funds linked, broadly speaking, to their fixed overheads, together with liquidity, governance and reporting requirements proportionate to their prudential class; EAFs usually fall into Class 3, for small and non-interconnected firms. The more services a firm provides, the heavier its prudential and organizational burden tends to be. We go into more detail in IFR/IFD and regulatory capital.
In some projects, the choice is driven not by the service but by the channel. Broker-dealers and securities brokers can rely on tied agents—professionals who attract clients and promote services on behalf of the firm and are entered in the relevant registers—while EAFs, as a general rule, cannot appoint them. If your business plan rests on an external sales network, that fact alone rules out the EAF, however advice-driven your model may be.
Both license types follow the investment firm (ESI) authorization procedure before the CNMV, with a general decision period of up to 6 months from the date the application is complete; the difference lies in the content, because each additional service requires you to demonstrate more resources and controls. Choosing too narrow a license means operating outside your authorization—a very serious infringement under the reserved activity rules—and choosing too broad a one drives up capital and compliance costs with no return. If you start with advice, you will find the full route in how to set up an EAF; and if the business later needs more services, the change of license type is processed with the CNMV through an extension application, as we explain in relation to converting an EAFN into an EAF.
Key legislation, linked to the official text:
Legislation and links reviewed in .