How to Set Up a Crowdfunding Platform in Spain

Four pillars: a company with a sound structure and fit and proper shareholders, the CNMV ECSP license, a flow of funds through a payment institution, and a compliance framework (AML/CFT, investor protection, KIIS). Technology matters, but it is the wrapper around all of the above.

You cannot launch and raise real money without authorization: it is a reserved activity.

There is no single figure. The cost combines the prudential safeguards under Article 11 (the higher of €25,000 or one quarter of fixed overheads), the cost of the application and its structuring, the technology and the flow of funds with the payment institution.

The biggest jump in cost usually comes from the decision on funds: working with a third-party payment institution and applying for your own license are very different scenarios.

Realistically, 6 to 9 months. The CNMV has 25 working days to assess whether the application is complete and 3 months to decide once it is, but most of the time goes into preparation beforehand and responding to requests for information.

The technology can be developed in parallel, as long as the regulatory design is settled first.

If your platform intermediates loans or securities for investment purposes, yes: you need the ECSP license.

Donation-based and reward-based platforms (such as Kickstarter), which offer no financial return, fall outside the regime. They do not need authorization, although they must still comply with consumer, data protection and tax rules.

Not necessarily. There are three routes: in-house development, third-party software (specialized SaaS) or a white-label model on an infrastructure that is already authorized. Each option has different implications for critical outsourcing, dependency and control.

The CNMV requires technology outsourcing to be documented: contracts, SLAs, security and an exit plan.

Not if that beta raises real money from investors. Providing crowdfunding services without authorization is an infringement, not a product test.

What you can do is validate demand with landing pages, waiting lists and preliminary agreements with project owners, and move the technology forward, while the license application is being processed.

Yes. The ECSP license comes with an EU passport: once your platform has been authorized by the CNMV and entered in the ESMA register, it can provide services in other EEA States through a simple notification between authorities, with no new local licenses.

The CNMV assesses the fitness and experience of the management body and the key functions: at a minimum, heads of compliance, AML/CFT and risk management, with real capacity to perform their roles.

You do not need a large workforce, but you do need suitable people and a clear allocation of responsibilities: an empty organization chart will not get the application through.

The usual model combines fees charged to project owners (a percentage of the amount raised, or a success fee), fees charged to investors (management or entry fees) and, in crowdlending, margins or fees linked to the loans.

The pricing policy must be stated in the program of operations and be consistent with how conflicts of interest are managed: the way you charge cannot compromise the objectivity of project selection.

With a white label, you operate on the infrastructure and, sometimes, under the umbrella of a third party that is already authorized: you start sooner and with lower upfront costs, but you depend on that provider and give up margin. With your own license, you have full control and a regulatory asset, in exchange for more time and investment. The choice depends on your ambition, your runway and your product strategy.

It is a common way in: working with an existing ECSP, or channeling projects to it, without holding the license yourself. It lowers barriers, but limits control and the business model. It is often an intermediate step before deciding on your own license.

The Spanish financial sandbox lets innovative projects be tested in a controlled, supervised environment, with safeguards for participants. It does not replace the license, but it can help validate novel aspects of the model before final authorization. We assess it case by case, depending on the project.

Shareholders with a significant holding undergo a suitability assessment: good repute, no relevant prior record and transparency about the origin of their holding. The CNMV wants to know who is behind the platform and to be sure there are no conflicts or reputational risks.

Yes. The Regulation allows an additional service of individual portfolio management of loans: the investor sets parameters and the platform allocates their funds automatically. It must be stated in the program of operations and is subject to stricter disclosure and control requirements.

Tokenization adds another layer: depending on the rights attached to the token, it may be a transferable security (securities market rules) or a MiCA crypto-asset. It is not incompatible with a crowdfunding platform, but each instrument has to fit within its own framework. We cover this under crypto services and tokenization.