AssessmentPhase 1
Whether you are required to file
We check whether your entity is subject to systematic reporting or exempt under Article 27(3) of Royal Decree 304/2014.
The starting point.
SEPBLAC Monthly Declaration (DMO) of Transactions
The monthly declaration of transactions (DMO) is the systematic reporting that financial obliged entities send to SEPBLAC every month (Article 20 of Law 10/2010 and Article 27 of Royal Decree 304/2014): cash above €30,000, money remittances, transactions with designated countries and more. We help you set up the process, check what must be declared and regularize anything that was not filed on time.
Questions about the monthly declaration? We can help
Tell us what type of entity you are and what transactions you carry out, and we’ll tell you what you have to declare.
- Reply within 24 h
- No commitment
- Confidential
- Deadline
- From the 1st to the 15th of each month
- No transactions
- Semiannual nil declaration
- Cash
- Over €30,000
- Failure to file
- Serious infringement
How we help
The DMO, error-free and on time
The monthly declaration cannot be improvised on the 14th: it needs clean data, clear criteria and someone accountable for it.
MapPhase 2
Which transactions are covered
We review your transactions and identify which ones fall under each letter of Art. 27(1): cash, money remittances, designated countries, means of payment.
Letter by letter.
ProcessPhase 3
An internal procedure
We draft the procedure: who extracts the data, who reviews it, how split transactions are aggregated and who files.
In writing.
AccessPhase 4
Access to the application
We guide you through the Bank of Spain digital certificate and SEPBLAC’s DMO application.
Ready to file.
ReviewPhase 5
Checks before sending
We review the declaration before each submission during the first few months, so the process runs smoothly.
No formatting errors.
RegularizationPhase 6
If it was filed late
If there are months that were not filed, we prepare the written explanation and regularize the outstanding declarations.
The sooner, the better.
Scenarios
When you need to review your DMO
These are the situations that raise the most questions.
New
You have just obtained your license
A newly authorized payment institution, electronic money institution or currency exchange business has to start declaring.
Nil
You have had no transactions to declare
You still have to report it: the semiannual nil declaration is also mandatory.
Late
There are months you have not filed
They must be regularized with a written explanation, before an inspection detects them.
Inspection
SEPBLAC has asked you for information
Systematic reporting is one of the first things reviewed in an inspection.
What the law says
The monthly declaration by the numbers
Figures from Art. 27 of Royal Decree 304/2014, Law 10/2010 and SEPBLAC’s information on systematic reporting.
Royal Decree 304/2014, Art. 27(1)(a)
€30,000
Physical movements of cash, traveler’s checks or bearer instruments issued by credit institutions above that amount.
Royal Decree 304/2014, Art. 27(1)(b)
€1,500
Physical movements of cash or bearer instruments in money remittances above that amount.
Royal Decree 304/2014, Art. 27(1)(c)
€30,000
Transactions with residents of countries or territories designated by Ministerial Order, or transfers to or from them, above that amount.
SEPBLAC · deadline
Days 1–15
The declaration is filed between the 1st and the 15th of each month and covers the previous month’s transactions.
SEPBLAC · no transactions
Semiannual
If there are no transactions to declare, this is reported every six months, between the 1st and the 15th of the following month (Art. 27(1) of Royal Decree 304/2014).
Law 10/2010, Art. 52(1)(j)
Serious
Failure to comply with systematic reporting is a serious infringement, with a minimum fine of €60,000 (Art. 57(1)).
Not sure what you must declare each month?
We review your transactions and leave you with a DMO process that runs on its own.
Frequently asked questions
SEPBLAC monthly declaration: common questions
What is the SEPBLAC monthly declaration of transactions?
It is the systematic reporting provided for in Article 20 of Law 10/2010: every month, obliged entities report certain transactions to SEPBLAC, whether or not there is any suspicion. It is different from suspicious transaction reporting, which is triggered by indications of suspicion and made without waiting for the following month.
Who is required to file the DMO?
The obliged entities listed in Article 2(1) of Law 10/2010, except those exempted by Article 27(3) of Royal Decree 304/2014: insurance brokers, financial advisory firms (EAF) and the entities under letters (k) to (y). In practice, it mainly affects financial institutions: banks, life insurers, investment firms, fund management companies, payment and electronic money institutions, currency exchange businesses and postal money order services.
Which transactions must be declared?
Those listed in Article 27(1) of Royal Decree 304/2014: physical movements of cash or bearer instruments over €30,000; in money remittances, physical movements over €1,500; transactions with countries designated by Ministerial Order over €30,000; movements of means of payment under Article 34 of the Law; aggregated information on money remittances and cross-border transfers; and anything else determined by Ministerial Order.
When is it filed?
Between the 1st and the 15th of each month, covering the previous month’s transactions, according to SEPBLAC’s information. If there are no transactions to declare during an entire six-month period, a semiannual nil declaration is filed between the 1st and the 15th of the month following that period.
How is it filed?
Through SEPBLAC’s DMO application, for which the obliged entity needs a digital certificate issued by the Bank of Spain. The format and data details are set out in SEPBLAC’s instructions on systematic reporting.
What happens if I file the declaration late?
According to SEPBLAC, a late declaration must be accompanied by a written explanation from the representative or an authorized person, submitted through the Bank of Spain’s electronic registry. It is best to regularize as soon as possible: failure to comply with systematic reporting is a serious infringement (Article 52(1)(j) of Law 10/2010).
How are split transactions treated?
SEPBLAC sets the criteria for aggregating transactions that amount to the splitting of a single transaction (Article 27(2) of Royal Decree 304/2014). Splitting a transaction to stay below the threshold does not avoid the declaration.
Who is responsible for the DMO within the entity?
The SEPBLAC representative, who is the point of contact with the Executive Service. From October 28, 2026, under Royal Decree 813/2026, the representative and up to two authorized persons are appointed by means of a formal self-declaration (declaración responsable). We explain this on our SEPBLAC representative page.
Practical guide
How to organize the monthly declaration
A reliable DMO rests on three pillars: data, criteria and an accountable person.
Monthly extraction
A report that pulls each month’s transactions for each letter of Art. 27(1).
Written rules
Thresholds, aggregation of split transactions and designated countries, in writing.
Who files
The representative or an authorized person reviews and submits before the 15th.
Your DMO in 10 steps
- Check whether your entity is required to file or exempt under Article 27(3) of Royal Decree 304/2014.
- List the transactions in your business that fit each letter of Art. 27(1).
- Set the thresholds and the criteria for aggregating split transactions.
- Prepare a report that extracts those transactions from your systems each month.
- Obtain the Bank of Spain digital certificate for the DMO application.
- Designate who prepares the declaration and who reviews it before it is sent.
- File the declaration between the 1st and the 15th of each month.
- If there are no transactions in a six-month period, file the semiannual nil declaration.
- If you miss a deadline, file the declaration with its written explanation as soon as possible.
- Keep the acknowledgment of receipt for each submission and have the process reviewed in your external expert report.
Source: Law 10/2010 (Arts. 20, 52 and 57), Royal Decree 304/2014 (Art. 27) and SEPBLAC’s information on systematic reporting.
Working glossary
Key concepts of the monthly declaration
These terms appear in Article 27 of Royal Decree 304/2014 and in SEPBLAC’s instructions.
DMOProcedure
Monthly declaration of transactions
Common name for systematic reporting to SEPBLAC.
Law 10/2010, Art. 20.
SystematicObligation
Systematic reporting
Periodic reporting of certain transactions, whether or not there is any suspicion.
Royal Decree 304/2014, Art. 27.
NilProcedure
Semiannual nil declaration
Notice that there have been no transactions to declare in the six-month period.
Days 1–15 of the following month.
SplittingCriterion
Split transactions
Transactions broken into parts that are aggregated as if they were a single one.
Royal Decree 304/2014, Art. 27(2).
DesignatedCountries
Designated countries or territories
Countries set by Ministerial Order whose transactions are declared above €30,000.
Royal Decree 304/2014, Art. 27(1)(c).
Art. 34Cash
Declared means of payment
Movements of means of payment subject to prior declaration, which are also included in the DMO.
Royal Decree 304/2014, Art. 27(1)(d).
RepresentativePerson
SEPBLAC representative
The entity’s point of contact with SEPBLAC, responsible for its reports.
Royal Decree 304/2014, Art. 35.
CertificateAccess
Bank of Spain certificate
Digital certificate the obliged entity needs to use the DMO application.
According to SEPBLAC.
ExemptScope
Exempt entities
Insurance brokers, financial advisory firms and the entities under letters (k) to (y) of Art. 2(1).
Royal Decree 304/2014, Art. 27(3).
Playbook
What to declare, by type of transaction
Cash or bearer instruments
When it is declared: physical movement over €30,000, unless credited or debited to the customer’s account.
Legal basis: Royal Decree 304/2014, Art. 27(1)(a).
Money remittances
When it is declared: physical movement of cash or bearer instruments over €1,500.
Legal basis: Royal Decree 304/2014, Art. 27(1)(b).
Designated countries
When it is declared: transactions or transfers over €30,000.
Legal basis: Royal Decree 304/2014, Art. 27(1)(c).
Means of payment under Art. 34
When it is declared: movements subject to prior declaration.
Legal basis: Royal Decree 304/2014, Art. 27(1)(d).
Aggregated information
When it is declared: money remittances by country and agent, and cross-border transfers by country.
Legal basis: Royal Decree 304/2014, Art. 27(1)(e) and (f).
Common DMO mistakes
These are the errors we see most often in reviews.
- Not filing the semiannual nil declaration when there are no transactions.
- Not aggregating split transactions.
- Filing late without a written explanation.
- Relying on a single person without a written procedure.
- Confusing the DMO with suspicious transaction reporting.
Contact
Book a call
Tell us what type of entity you are, what transactions you carry out and whether you have outstanding months, and we’ll tell you how to organize your DMO.
Systematic reporting under Law 10/2010 and Royal Decree 304/2014
Updated October 16, 2026
Article 20 of Law 10/2010 requires obliged entities to report certain transactions to SEPBLAC at the intervals determined, and also to report when there have been none. Article 27 of Royal Decree 304/2014 specifies which ones: this is what is known as the monthly declaration of transactions, or DMO.
What is declared
Physical movements of cash or bearer instruments over €30,000; in money remittances, over €1,500; transactions with designated countries over €30,000; movements of means of payment under Article 34 of the Law; aggregated information on money remittances and cross-border transfers; and anything set by Ministerial Order (Art. 27(1)).
Who declares
All obliged entities, except insurance brokers, financial advisory firms and those under letters (k) to (y) of Article 2(1) of Law 10/2010 (Art. 27(3)). You can check who is an obliged entity in obliged entities under Law 10/2010.
How and when
According to SEPBLAC, the declaration is filed through the DMO application, with a Bank of Spain digital certificate, between the 1st and the 15th of each month. If there are no transactions, the semiannual nil declaration is filed between the 1st and the 15th of the month following the six-month period. A late declaration is accompanied by a written explanation submitted through the Bank of Spain’s electronic registry.
What happens if you do not comply
Failure to comply with systematic reporting is a serious infringement (Article 52(1)(j) of Law 10/2010), with a minimum fine of €60,000 (Art. 57(1)). If you face an inspection, we can help you with your defense in the sanction proceedings.
Where it fits
The DMO is part of the AML manual and is filed by the SEPBLAC representative. The external expert report checks every year that the process works.