The programme of operations is the document the CNMV uses to decide whether to authorize your fund manager: activities, organizational structure, technical and human resources, delegation arrangements and business plan. We draft it for your SGIIC, SGEIC or self-managed SCR using the CNMV models.
Applying for CNMV authorization? Free assessment
Tell us which fund manager you want to set up and which vehicles you will manage, and we will tell you what the CNMV will ask for.
The CNMV does not authorize an idea; it authorizes an organization: who will do what, with what resources and how it will be controlled. We set this out in the programme and in the rest of the application.
We define the right type of entity for your project, which activities you will apply for and whether your SGEIC will fall below the thresholds in Art. 72 of Law 22/2014.
We describe the activities you will carry out, including ancillary ones, and the strategies, risk profiles and leverage policy of the vehicles you will manage.
We detail the organizational chart, the staff in each area, the technical resources and the risk management, compliance and internal audit units, whether in-house or delegated.
We identify which areas will be outsourced, to whom, and who will supervise the delegated functions, so that the delegation does not hollow out the authorization.
We prepare the estimate of revenue, expenses and own funds compliance for the first financial year, consistent with the minimum capital and the fixed overheads.
We prepare the pre-notification meeting, the rest of the documents (articles of association, directors, shareholders, remuneration) and the responses to the CNMV’s requests for information.
The programme is not only for new fund managers: any significant change in what the manager does goes through the CNMV.
The programme of operations accompanies the authorization application, together with the draft articles of association.
Self-managed SCRs also need CNMV authorization and submit a programme of operations, just like SGEICs.
If an SGIIC wants to manage venture capital entities, it must apply to amend its articles of association and submit a report on the vehicles it will manage.
An SGEIC that is no longer below the thresholds must inform the CNMV and move to the full regime under the law.
Figures from Law 35/2003 on Collective Investment Schemes, its implementing regulation (Royal Decree 1082/2012) and Law 22/2014.
Deadline for the CNMV to decide, counted from the application or from when the documentation is complete; it can be extended by another three months.
Minimum fully paid-up share capital of an SGIIC and of an SGEIC.
Of assets under management exceeding €250 million, up to a total maximum of €10 million.
Minimum number of board members, who must be of good repute and, in the majority, have knowledge and experience.
Minimum subscribed share capital of an SCR, including a self-managed one (€900,000 for an ECR-Pyme).
An SGIIC’s authorization lapses if registration in the CNMV register is not requested within one year.
We turn your plan into a complete programme of operations and application, ready for the pre-notification with the CNMV.
It is the document that accompanies the authorization application and sets out the activities, the organizational structure, how the manager will meet its legal obligations and its technical and human resources (Article 45(1)(c) of Law 22/2014 for SGEICs; for SGIICs, the report (memoria) under Article 41(2) of Law 35/2003). The CNMV publishes model programmes of operations for SGIICs and for SGEICs.
According to its Technical Guide 3/2019 on authorization procedures, which the CNMV currently has under review: the activities, including ancillary ones; an organizational chart with the areas and the staff in each; the expected time commitment of the directors; the areas to be outsourced and who will supervise the delegated functions; and, for management companies, an estimate of revenue, expenses and own funds for the first financial year.
The decision must be notified within three months of the application or of the date the documentation is completed, extendable by another three. If no decision is made in time, the application may be deemed approved by administrative silence (Article 41(4) of Law 35/2003 and Article 46 of Law 22/2014). Requests for documentation can suspend that period while they are being answered.
Minimum fully paid-up share capital of €125,000, increased by 0.02% of assets under management exceeding €250 million, up to a total cap of €10 million. There are also requirements linked to fixed overheads and professional liability (Article 100 of Royal Decree 1082/2012 and Article 48 of Law 22/2014).
SGEICs whose assets under management do not exceed €100 million (or €500 million if the vehicles are unleveraged and have no redemption rights for five years) do not apply Chapter II of Law 22/2014 and must inform the CNMV of their vehicles and strategies (Art. 72). The CNMV has a specific authorization manual for these managers.
Yes. Self-managed SCRs must obtain CNMV authorization just like SGEICs, and their application includes the draft articles of association and a programme of operations (Article 45(1) of Law 22/2014). Their minimum capital is that of an SCR: €1,200,000 subscribed.
Yes. The application must report the arrangements made for the delegation and sub-delegation of functions to third parties, and the manager must provide sufficient documentation on what is outsourced so that the CNMV can verify that it does not hollow out the authorization (Arts. 41(2) and 43(1)(k) of Law 35/2003; Article 45(1)(d) of Law 22/2014).
The management company is incorporated by public deed and registered in the Commercial Registry and in the CNMV register. For SGIICs, the authorization lapses if registration with the CNMV is not requested within one year of its notification (Article 41(6) of Law 35/2003).
A good programme answers before the CNMV asks: who, with what resources, how it is controlled and with what numbers.
SGIIC, SGEIC, self-managed SCR or sub-threshold manager: each has its own model and its own requirements.
People, resources, control functions and delegation arrangements that fit your size and your business plan.
The programme, the articles of association, the business plan and the CVs must tell the same story.
Source: Law 35/2003 (Arts. 41 and 43), Royal Decree 1082/2012 (Art. 100), Law 22/2014 (Arts. 45, 46, 48 and 72) and CNMV Technical Guide 3/2019.
These terms appear in Law 35/2003, Law 22/2014 and the CNMV models.
Document that sets out the activities, the organizational structure and the technical and human resources of the fund manager.
Document in an SGIIC’s application that describes its structure, activities and resources.
Preliminary meeting with the CNMV to present the project before the formal application.
Estimate of revenue, expenses and own funds for the first financial year of activity.
Minimum capital plus additional amounts depending on assets under management and professional liability.
SGEIC with less than €100 million under management, or €500 million with no leverage and no redemptions for five years.
Venture capital company (SCR) that manages itself and is subject to the SGEIC regime.
Requirements for directors, senior managers and significant shareholders that the CNMV assesses.
If the CNMV does not decide in time, the application may be deemed approved.
SGIIC: investment funds and investment companies (IICs).
SGEIC: venture capital entities and other closed-ended vehicles.
SGIIC: Law 35/2003 and Royal Decree 1082/2012.
SGEIC: Law 22/2014.
SGIIC: report (memoria) covering structure, activities and resources.
SGEIC: programme of operations covering structure, compliance and resources.
SGIIC: €125,000 plus 0.02% above €250 million.
SGEIC: €125,000 plus 0.02% above €250 million.
SGIIC: can manage ECRs if it amends its articles of association and submits a report.
SGEIC: its corporate purpose is managing closed-ended vehicles.
These are the most common reasons for CNMV requests for information.
Tell us which fund manager you want to set up, which vehicles you will manage and what team you have, and we will tell you how to build the programme.
Updated October 15, 2026
To manage investment funds or venture capital vehicles in Spain, you need a management company authorized by the CNMV. The programme of operations (or the report, in the case of SGIICs) is the part of the application where the CNMV checks that the organization is real, sufficient and controllable.
Law 35/2003 requires the application to include the draft articles of association and a report covering the organizational structure, the activities, the technical and human resources, the directors and senior managers and the significant shareholders, as well as the remuneration policies and delegation arrangements. The management company must be a public limited company (S.A.) or a limited liability company (S.L.), with its registered office and management in Spain, a board of at least three members and minimum capital of €125,000.
Law 22/2014 requires information on directors, significant shareholders, draft articles of association, programme of operations, delegation and remuneration, and on the vehicles to be managed: strategies, leverage, fund rules and depositary. Self-managed SCRs follow the SGEIC regime, with the exceptions provided for in the law.
The CNMV must notify its decision within three months of the application or of the date the documentation is complete, a period that can be extended by another three. If it does not, the application may be deemed approved by silence. In practice, the actual timeline depends on the quality of the application and on the requests for information.
The CNMV publishes model programmes of operations for SGIICs and SGEICs, authorization manuals and pre-notification forms. Its Technical Guide 3/2019 explains what it expects in each section and recommends holding the pre-notification meeting at least one month before the formal application; the CNMV itself has marked the guide as under review.
The programme of operations is at the heart of the authorization of an SGIIC or of a private equity / venture capital fund manager. If you plan to delegate control functions, see how to outsource compliance; for investment firms, see the programme of operations of an investment firm (ESI).