We handle your registration as a mortgage credit intermediary (ICI) or real estate lender (PI) under Law 5/2019 (LCCI): registration with the Bank of Spain (or your Autonomous Community), good repute, knowledge requirements (Art. 16), professional liability insurance or a guarantee and transparency obligations. Registration is a requirement to operate; without it, you cannot act as an intermediary or grant mortgage loans on a professional basis.
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Six building blocks that structure your registration as a mortgage credit intermediary or real estate lender, from identifying your role to registration with the Bank of Spain or your Autonomous Community and keeping the requirements up to date.
We determine whether you are a mortgage credit intermediary (ICI), a real estate lender (PI) or both. Your role defines the register, the requirements and the obligations you will have to meet.
We prepare and file the online application. You register with the Bank of Spain if you operate in more than one Autonomous Community, or with the Autonomous Community if you operate in only one.
We evidence your good repute and recognized standing, and the knowledge and competence required by Article 16, with training certified by an entity recognized by the Bank of Spain.
Intermediaries must have professional liability insurance or a bank guarantee, with the minimum amounts set by EU rules. We help you take it out and renew it.
We implement the pre-contractual information obligations (FEIN and FiAE), the 10-day reflection period and the conduct rules that the LCCI requires toward the borrower.
We integrate anti-money laundering compliance and the ongoing staff training plan, a permanent requirement to keep your registration and LCCI certification.
Mortgage brokers, private lenders, real estate agencies that help with financing, or networks with designated representatives: the LCCI requires you to register before acting as an intermediary or granting mortgage loans on a professional basis.
"A mortgage credit intermediary presents or offers loans from several lenders, assists the client and may conclude agreements on the lender’s behalf. It needs registration and liability insurance."
"Anyone who grants or manages mortgage loans to consumers on a professional basis, without being a bank or an EFC, is a real estate lender and must register in the relevant register."
"If a real estate agency presents or offers loan agreements, or assists with the preliminary steps in exchange for remuneration, it is acting as a mortgage credit intermediary and falls within the scope of the LCCI."
"An intermediary that operates through designated representatives must notify them to the register so that they can be registered; they are subject to the same supervisory regime as the intermediary."
Acting as an intermediary or lender without being registered, choosing the wrong register, or neglecting insurance and training are the mistakes that most often hold back (and expose) a real estate credit professional.
Registration is a requirement to operate: to be an ICI or PI and carry out the activity lawfully, you must be registered. Operating beforehand is an irregularity.
Bank of Spain or Autonomous Community: the register depends on your geographic scope. Several Autonomous Communities or nationwide: the Bank of Spain. A single Autonomous Community: that Community.
The Bank of Spain decides within 3 months. If that period ends without an express decision, the application is deemed rejected (negative administrative silence).
Liability insurance or guarantee (ICI): intermediaries must have professional liability insurance or a bank guarantee, with minimum cover set by EU rules, and renew it every year.
Knowledge and training (Art. 16): without the required training and knowledge certification, and without ongoing training, registration cannot be maintained.
Transparency with the client: the FEIN, the FiAE, the 10-day reflection period and keeping documentation for 6 years are obligations whose breach is penalized.
Whether you present third-party loans or grant them yourself, the LCCI requires you to register before operating. Before you start, identify your role, the competent register and the requirements correctly.
It is a natural or legal person that, in exchange for remuneration, presents or offers credit agreements to consumers, assists with the preliminary steps or concludes agreements on behalf of the lender. It is the role of the mortgage broker.
It is regulated by Law 5/2019 (LCCI), which transposes Directive 2014/17/EU.
It is a natural or legal person that grants or manages mortgage loans to consumers on a professional basis, without being a credit institution or an EFC. It must also register in the relevant register before operating.
It depends on your geographic scope. If your borrowers will be domiciled in more than one Autonomous Community (or nationwide), you register with the Bank of Spain. If you operate exclusively in a single Autonomous Community, you must apply to the competent body of that Community.
The main ones are good repute and recognized standing, knowledge and competence (Art. 16 of the LCCI, evidenced by certified training) and, for intermediaries, professional liability insurance or a bank guarantee. You also need a staff training plan.
The Bank of Spain decides within 3 months of the application. If that period ends without an express decision, the application is deemed rejected (negative administrative silence). There is no administrative fee for registration with the Bank of Spain.
Intermediaries (ICI) do: they must have professional liability insurance or a bank guarantee, with the minimum amounts set by Delegated Regulation (EU) 1125/2014 (around €460,000 per claim and €750,000 per year). It must be renewed annually.
No. Credit institutions and EFCs are already authorized and supervised, so they do not register as real estate lenders. The PI register is for those who grant mortgages professionally without being a credit institution or an EFC.
Provide the FEIN (European Standardized Information Sheet) and the FiAE (Standardized Warnings Sheet), observe the 10-day reflection period before signing and keep the documentation given to the client for at least 6 years.
A tied intermediary acts on behalf of one or more lenders and is usually paid by them. An independent intermediary works without an exclusive link to any lender, and its remuneration comes from the client. This status must be disclosed.
It is a person who acts on behalf and under the responsibility of a mortgage credit intermediary. The intermediary must notify it to the register so that it is registered, and it is subject to the same supervisory regime.
Not necessarily. If the activity is limited to collecting data and giving partial information, without presenting or offering finalized agreements, it may not be intermediation. If it goes as far as offering a complete agreement tailored to the client, it does fall within the ICI role.
Knowledge and competence evidenced through training and certification by an entity recognized by the Bank of Spain, plus annual ongoing training for staff (around 10 to 15 hours depending on the position).
Directive 2014/17/EU on credit agreements for consumers relating to residential immovable property (the “Mortgage Credit Directive”), which Law 5/2019 transposes into Spanish law.
Yes. Registration with the Bank of Spain allows you to operate with borrowers in more than one Autonomous Community or nationwide. If you will only operate in one Community, regional registration is the right one.
They all operate in real estate credit, but their activity, their register and their distinctive requirement differ. Use this comparison to see where you fit.
Whether you present third-party loans or grant them yourself, and your geographic scope, define your role and your register. These are the key factors.
Before filing anything, we pin down your role and the competent register. That way, you avoid filing with the wrong authority or falling short on requirements.
| Role | What it does | Where it registers | Distinctive requirement |
|---|---|---|---|
| Intermediary (ICI) | Presents or offers third-party loans, assists, or concludes agreements on the lender’s behalf | Bank of Spain (several Autonomous Communities) or the Autonomous Community | Professional liability insurance or guarantee |
| Lender (PI) | Grants or manages mortgage loans without being a bank or an EFC | Bank of Spain (several Autonomous Communities) or the Autonomous Community | Good repute and knowledge |
| Designated representative | Acts on behalf and under the responsibility of an intermediary | Registered through the intermediary | Same regime as the intermediary |
| Bank / EFC | Grants credit as an authorized institution | Already authorized (not registered as a PI) | The institution’s own authorization |
Indicative table for information purposes. The regime derives from Law 5/2019 (LCCI), Royal Decree 309/2019 and Order ECE/482/2019; requirements, insurance amounts and timelines may vary and should be checked case by case with legal advice. This page is for information only and does not constitute advice.
Registering is not just filling in a form: it means identifying your role, evidencing fitness and training, taking out insurance and filing the application with the competent authority. The order matters.
Intermediary, lender or both, and whether you operate in one or several Autonomous Communities. That determines the competent register and the requirements, and it is the first decision in the project.
Good repute, certified knowledge (Art. 16) and, for intermediaries, liability insurance or a guarantee. Without these requirements, there is no registration.
Registration is a requirement to operate, with a 3-month timeline after which the application is deemed rejected. Plan for it before you start operating.
Granting credit on a larger scale, or credit other than mortgages? See the financial credit establishment (EFC) and the banking license. For contracts and general terms and conditions, see commercial contracts.
Registering under the LCCI is an ordered sequence (role, fitness and training, insurance, application and registration) with the Bank of Spain or your Autonomous Community. This is the path.
1) RoleIntermediary (ICI), lender (PI) or both, and whether you operate in one or several Autonomous Communities. That determines the competent register.
2) Fit and properGood repute, recognized standing and Article 16 knowledge, evidenced by certified training and a staff training plan.
3) InsuranceThe intermediary takes out professional liability insurance or a bank guarantee, with the minimum cover set by EU rules, before registering.
4) Application + registrationThe online application is filed, with the mandatory forms, with the Bank of Spain or the Autonomous Community. The decision comes within 3 months (deemed rejected if none is issued), and the registration is published in the register.
Quick decisionBorrowers in more than one Autonomous Community or nationwide: registration with the Bank of Spain.
Activity limited to one Autonomous Community: registration with the competent body of that Community.
Credit institutions and EFCs: already authorized, they do not register as real estate lenders.
Recognized commercial and professional standing of the applicant.
Declarations and records submitted with the application.
Training and level of knowledge under Article 16 of the LCCI.
Certification by an entity recognized by the Bank of Spain.
Minimum cover set by EU rules for intermediaries.
Insurance policy or bank guarantee, renewable every year.
Initial and ongoing training for sales staff.
Documented plan, reviewed periodically.
FEIN, FiAE and a 10-day reflection period for the borrower.
Procedures and 6-year record keeping.
Anticipate them before filing the application to avoid requests for information and rejection.
If you are going to broker or grant mortgage loans, these terms appear in the registration application, in your dealings with clients and in Bank of Spain supervision.
A natural or legal person that, in exchange for remuneration, presents or offers third-party loans, assists the consumer or concludes agreements on behalf of the lender.
A natural or legal person that grants or manages mortgage loans to consumers on a professional basis, without being a credit institution or an EFC.
A person acting on behalf and under the responsibility of an intermediary. It is registered through the intermediary and is subject to the same supervisory regime.
The law governing real estate credit agreements. It transposes Directive 2014/17/EU and regulates transparency, the roles involved and the registration and supervision regime.
The register you must join before operating: the Bank of Spain’s if you operate in several Autonomous Communities, or the Autonomous Community’s if you operate in only one.
Pre-contractual document setting out the terms of the mortgage loan, which must be given to the borrower as part of the LCCI transparency obligations.
Document warning the borrower about the relevant and risky clauses or features of the loan, also mandatory at the pre-contractual stage.
Professional liability insurance or bank guarantee that intermediaries must hold, with the minimum cover set by EU rules, renewable annually.
Directive 2014/17/EU on credit agreements for consumers relating to residential immovable property. It is the EU framework that the LCCI transposes.
A practical guide to registering under the LCCI: how to identify your role, where to register, what fitness, training and insurance you need, and what transparency obligations you will have toward the client.
Tell us whether you will broker or grant mortgage loans, and in which territory, and we will tell you your role, the competent register and the requirements for registration.
The brokering and professional granting of mortgage loans to consumers is governed by Law 5/2019 of March 15 on Real Estate Credit Agreements (LCCI), implemented by Royal Decree 309/2019 and Order ECE/482/2019. It transposes Directive 2014/17/EU. The law distinguishes two roles, the mortgage credit intermediary (ICI) and the real estate lender (PI), and provides for designated representatives.
You must register before operating: in the Bank of Spain register if your borrowers are in more than one Autonomous Community or nationwide, or in the register of the Autonomous Community if the activity is limited to a single one. Registration is a requirement to operate, and supervision falls to the Bank of Spain.
Access requires good repute and recognized standing, knowledge and competence (Art. 16, implemented by Order ECE/482/2019 and evidenced by certification), a staff training plan and, for intermediaries, professional liability insurance or a bank guarantee with the minimum cover under Delegated Regulation (EU) 1125/2014.
The application is filed online with the mandatory forms. The Bank of Spain decides within 3 months, and if that period ends without a decision, the application is deemed rejected (negative administrative silence). Registration carries no fee and is published in the register.
Toward the borrower, you must provide the FEIN and the FiAE, observe the 10-day reflection period and keep documentation for 6 years, in addition to complying with the LCCI conduct rules. Credit institutions and EFCs do not register as real estate lenders, as they are already authorized.
Key legislation, linked to the official text:
Legislation and links reviewed in .