Foreign Bank Branch in Spain

If your bank is authorized outside the European Union and wants to operate in Spain through an establishment, it needs Bank of Spain authorization to open a branch. We prepare the application (capital endowment, managers, program of activities and home supervisor documentation) and follow the process through to the decision.

Opening a branch in Spain? Free assessment

Tell us where your bank is from and what it wants to do in Spain, and we will tell you which route applies.

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Your branch in Spain, from analysis to authorization

We support third-country credit institutions throughout the procedure before the Bank of Spain: from choosing the right route to registering the branch and meeting its ongoing obligations.

RoutePhase 1

Branch, services without a branch or representative office?

We analyze what your institution wants to do in Spain and which route applies: each one has its own authorization and limits, such as the ban on taking deposits without a branch.

The decision that shapes everything else.
EndowmentPhase 2

Capital endowment and prior deposit

We plan the branch’s permanent capital endowment and the prior deposit of 20% of the minimum capital in favor of the Bank of Spain.

Funds available from the outset.
ManagersPhase 3

Managers and fit and proper requirements

We prepare the documentation for the persons, at least two, who will effectively direct the branch: good repute, knowledge and experience.

Among the first things reviewed.
ProgramPhase 4

Program of activities and business plan

We draft the program of activities, the organizational structure, the internal control framework and the business plan that accompany the application.

Consistency between plan and resources.
ApplicationPhase 5

Filing and requests for information

We file the application through the Bank of Spain’s electronic office and respond to requests for information until a decision is issued.

Six months, up to a maximum of twelve.
AfterwardPhase 6

Registration and ongoing obligations

After authorization, we handle the branch’s registration, the notification of changes and the periodic reporting it must submit to the Bank of Spain.

A supervised branch.

Which route you need

How you enter Spain depends on the bank’s home country and on what it wants to do here.

Non-EU bank

You want to operate through an establishment

A bank authorized in a third country that wants to operate in Spain through an establishment needs Bank of Spain authorization for its branch.

No branch

You want to provide services from abroad

Providing services in Spain without a branch also requires prior Bank of Spain authorization, and it does not allow taking deposits or other repayable funds from the public.

Representative office

You only want a commercial presence

A representative office of a non-EU bank needs authorization from the Bank of Spain, which decides within a maximum of three months.

EU bank

Your bank is already authorized in the EU

If the bank is authorized in another Member State, it does not need this authorization: it can operate in Spain under the EU passport, through notifications between supervisors.

A foreign bank branch, in figures

Figures from Law 10/2014 on the regulation, supervision and solvency of credit institutions, and from Royal Decree 84/2015, which implements it.

Law 10/2014, Art. 13 Prior authorization

The branch of a bank authorized outside the EU requires Bank of Spain authorization.

Endowment €18 million

For a branch, a bank’s minimum capital is understood to refer to its permanent capital endowment in Spain (Royal Decree 84/2015, Arts. 4 and 17).

Prior deposit 20%

Of the minimum capital, in cash at the Bank of Spain or in government debt blocked in its favor, to be evidenced with the application.

Time limit 6 months (max. 12)

From receipt or from when the documentation is complete, and in any case twelve months. If no decision is issued, the application is deemed rejected.

Management 2 persons

At least two persons must effectively direct the branch and meet the fit and proper requirements.

Changes and closure 1 month / 3 months

Changes to relevant information are notified one month in advance, and closure of the branch three months in advance.

Does your bank want to operate in Spain?

We tell you which route applies, what documentation the Bank of Spain will request and how to prepare a solid application from day one.

Foreign bank branch: common questions

Who authorizes the branch of a non-EU bank?

The Bank of Spain. This is set out in Article 13 of Law 10/2014 and implemented by Article 17 of Royal Decree 84/2015. According to the Bank of Spain’s electronic office, the body that decides is its Executive Commission.

What capital does the branch need?

The rules treat the branch’s capital endowment as its capital: permanent funds of indefinite duration, held in Spain and available to cover the branch’s losses. The minimum capital required of banks, €18 million, applies to it, and a deposit of 20% of that amount must be evidenced with the application.

How long does authorization take?

The application must be decided within six months of its receipt or of the documentation being complete and, in any case, within twelve months. If no decision is issued in time, the application is deemed rejected.

What documentation must be submitted?

Among other documents: the branch’s program of activities and structure, its address in Spain, information on its managers, the own funds and solvency of the institution and its group, information on the deposit guarantee scheme that protects the branch’s depositors, and the home-country authorizations or a certificate stating that none are required.

Can authorization be refused on grounds of reciprocity?

Yes. Authorization may be refused under the principle of reciprocity, that is, taking into account how Spanish institutions are treated in the bank’s home country.

Can I provide services in Spain without opening a branch?

A non-EU bank also needs prior authorization from the Bank of Spain to provide services without a branch, and in that case it is prohibited from taking deposits or other repayable funds from the public (Article 13(4) of Law 10/2014).

What changes with CRD VI?

Directive (EU) 2024/1619 harmonizes the regime for third-country branches across the EU, with minimum capital endowment and liquidity requirements and a classification into two classes. According to the European Banking Authority’s guidelines, the new regime applies from January 11, 2027. In August 2026, the European Commission indicated that Spain had not yet notified its transposition.

What if I only want a representative office?

A representative office of a non-EU bank also needs authorization from the Bank of Spain, which must decide within a maximum of three months; if it does not, the application may be deemed approved (Article 19(4) of Royal Decree 84/2015).

How to prepare the branch application

The Bank of Spain reviews the parent institution, its home supervisor and the branch itself at the same time. An application that is consistent across those three levels is the best way to avoid requests for information.

The starting point

Choose the right route

Branch, services without a branch or representative office: each route has its own authorization, its own limits and its own documentation.

The key people

Managers with the right profile

At least two persons who effectively direct the branch, with proven good repute, knowledge and experience.

The evidence

A home supervisor that backs you

The home-country authorizations, the group’s solvency and the deposit guarantee scheme carry as much weight as the branch’s plan.

The branch in 10 steps

  1. Define the branch’s activities: they cannot include activities the institution is not permitted to carry out in its home country.
  2. Obtain the authorizations from the home supervisor or a certificate stating that none are required.
  3. Plan the branch’s permanent capital endowment in Spain.
  4. Make the prior deposit of 20% of the minimum capital in favor of the Bank of Spain.
  5. Appoint at least two managers and prepare their fit and proper documentation.
  6. Draft the program of activities, the organizational structure and the business plan.
  7. Document internal control, complaints handling and anti-money laundering.
  8. Gather the information on own funds, solvency and the deposit guarantee scheme.
  9. File the application through the Bank of Spain’s electronic office and respond to requests for information.
  10. After authorization, register the branch and meet the periodic reporting obligations.

Sources: Law 10/2014 (Article 13), Royal Decree 84/2015 (Arts. 3–5, 17 and 19) and the Bank of Spain’s electronic office.

Working glossary

Key concepts for a foreign bank branch

These terms come up in the application and in your dealings with the Bank of Spain. Being clear about them helps you prepare an application with no gaps.

Third countryOrigin

Non-EU state

The institution’s home country, which is not part of the European Union.

Determines the route.
BranchEstablishment

Branch

An establishment without separate legal personality through which the institution operates in Spain.

Requires authorization.
EndowmentCapital

Capital endowment

Permanent funds of indefinite duration that the institution holds in Spain to cover the branch’s losses.

Serves as capital.
Prior depositGuarantee

20% deposit

A deposit in cash or government debt in favor of the Bank of Spain for 20% of the minimum capital.

Evidenced with the application.
Fit and properManagers

Good repute, knowledge and experience

Requirements that the persons who effectively direct the branch must meet.

At least two persons.
ReciprocityRefusal

Principle of reciprocity

Allows authorization to be refused based on how Spanish institutions are treated in the home country.

A ground for refusal.
Representative officePresence

Representative office

A presence in Spain of a foreign institution other than a branch; it also needs Bank of Spain authorization.

Three months for a decision.
CRD VIEU directive

Directive (EU) 2024/1619

Amendment to the Capital Requirements Directive that harmonizes the regime for third-country branches.

New regime from 2027.
Core banking servicesCRD VI

Core banking services

Taking deposits, granting loans and providing guarantees: CRD VI requires, with exceptions, that they be provided through a branch.

A closed list of exceptions.
Playbook

Current regime and CRD VI: what changes for branches

Aspect
Current regime
Under CRD VI

Legislation

Current regime: Law 10/2014 and Royal Decree 84/2015.

Under CRD VI: Directive (EU) 2024/1619, pending transposition in Spain.

Classification

Current regime: a single regime for all branches.

Under CRD VI: class 1 and class 2 branches, based on size and risk profile.

Capital

Current regime: endowment treated as equivalent to a bank’s minimum capital.

Under CRD VI: minimum capital endowment harmonized across the EU.

Services from abroad

Current regime: prior authorization, without a branch and without taking deposits.

Under CRD VI: core banking services must, with exceptions, be provided through a branch.

Application date

Current regime: in force.

Under CRD VI: new branch regime from January 11, 2027, according to the EBA.

Mistakes that delay authorization

Avoiding them makes the difference between an application that moves forward and one that piles up requests for information.

  • Choosing a route that does not allow what the institution wants to do in Spain.
  • Proposing activities that the institution is not permitted to carry out in its home country.
  • Filing without the prior deposit or without the home supervisor’s documentation.
  • Managers without proven good repute, knowledge or experience.
  • A business plan that is inconsistent with the branch’s resources and endowment.

Book a call

Tell us which country your bank is from and what it wants to do in Spain, and we will tell you which authorization it needs and how to prepare the application.

Opening a foreign bank branch in Spain

Credit institutions authorized in a state that is not a member of the European Union need Bank of Spain authorization to establish a branch in Spain. This is required by Article 13 of Law 10/2014 on the regulation, supervision and solvency of credit institutions, and implemented by Article 17 of Royal Decree 84/2015.

Branch requirements

The requirements for setting up a bank apply, with adaptations: the branch’s permanent capital endowment is treated as its minimum capital; the branch must have at least two persons who effectively direct it and meet the fit and proper requirements; and its scope may not include activities that the institution is not permitted to carry out in its home country. The application must be accompanied by a program of activities, information on managers, own funds and solvency, the deposit guarantee scheme and the home-country authorizations.

Procedure and time limits

The application is filed through the Bank of Spain’s electronic office, together with evidence of the deposit of 20% of the minimum capital. The time limit for a decision is six months from receipt or from when the documentation is complete and, in any case, twelve months; if no decision is issued, the application is deemed rejected. Authorization may be refused under the principle of reciprocity.

Other routes: services without a branch and representative offices

Providing services in Spain without a branch also requires prior Bank of Spain authorization and does not allow taking deposits or other repayable funds from the public. Representative offices of non-EU institutions likewise need authorization, with a maximum decision period of three months. For institutions from other Member States, the route is the EU passport. If you want to set up a new institution instead, see our page on the banking license or on how to operate in Spain as a foreign entity.

CRD VI and the new European regime

Directive (EU) 2024/1619 (CRD VI) harmonizes the regime for third-country branches, classifies them into two classes and sets minimum capital endowment and liquidity requirements. It also requires, as a general rule, that core banking services be provided through a branch, with exceptions such as services provided at the client’s own initiative. According to the European Banking Authority, the new regime applies from January 11, 2027; in August 2026, the European Commission indicated that Spain had not yet notified its transposition.

Branch Foreign bank Bank of Spain Law 10/2014 Royal Decree 84/2015 Capital endowment CRD VI Third country