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.
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.
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.
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.
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.
We prepare the documentation for the persons, at least two, who will effectively direct the branch: good repute, knowledge and experience.
We draft the program of activities, the organizational structure, the internal control framework and the business plan that accompany the application.
We file the application through the Bank of Spain’s electronic office and respond to requests for information until a decision is issued.
After authorization, we handle the branch’s registration, the notification of changes and the periodic reporting it must submit to the Bank of Spain.
How you enter Spain depends on the bank’s home country and on what it wants to do here.
A bank authorized in a third country that wants to operate in Spain through an establishment needs Bank of Spain authorization for its branch.
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.
A representative office of a non-EU bank needs authorization from the Bank of Spain, which decides within a maximum of three months.
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.
Figures from Law 10/2014 on the regulation, supervision and solvency of credit institutions, and from Royal Decree 84/2015, which implements it.
The branch of a bank authorized outside the EU requires Bank of Spain authorization.
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).
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.
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.
At least two persons must effectively direct the branch and meet the fit and proper requirements.
Changes to relevant information are notified one month in advance, and closure of the branch three months in advance.
We tell you which route applies, what documentation the Bank of Spain will request and how to prepare a solid application from day one.
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.
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.
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.
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.
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.
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).
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.
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).
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.
Branch, services without a branch or representative office: each route has its own authorization, its own limits and its own documentation.
At least two persons who effectively direct the branch, with proven good repute, knowledge and experience.
The home-country authorizations, the group’s solvency and the deposit guarantee scheme carry as much weight as the branch’s plan.
Sources: Law 10/2014 (Article 13), Royal Decree 84/2015 (Arts. 3–5, 17 and 19) and the Bank of Spain’s electronic office.
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.
The institution’s home country, which is not part of the European Union.
An establishment without separate legal personality through which the institution operates in Spain.
Permanent funds of indefinite duration that the institution holds in Spain to cover the branch’s losses.
A deposit in cash or government debt in favor of the Bank of Spain for 20% of the minimum capital.
Requirements that the persons who effectively direct the branch must meet.
Allows authorization to be refused based on how Spanish institutions are treated in the home country.
A presence in Spain of a foreign institution other than a branch; it also needs Bank of Spain authorization.
Amendment to the Capital Requirements Directive that harmonizes the regime for third-country branches.
Taking deposits, granting loans and providing guarantees: CRD VI requires, with exceptions, that they be provided through a branch.
Current regime: Law 10/2014 and Royal Decree 84/2015.
Under CRD VI: Directive (EU) 2024/1619, pending transposition in Spain.
Current regime: a single regime for all branches.
Under CRD VI: class 1 and class 2 branches, based on size and risk profile.
Current regime: endowment treated as equivalent to a bank’s minimum capital.
Under CRD VI: minimum capital endowment harmonized across the EU.
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.
Current regime: in force.
Under CRD VI: new branch regime from January 11, 2027, according to the EBA.
Avoiding them makes the difference between an application that moves forward and one that piles up requests for information.
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.
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.
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.
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.
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.
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.
Key legislation, linked to the official text:
Legislation and links reviewed in .