Banco de España Registro de entidades: PIs, EMIs, agents
The Banco de España Registro de entidades is the official public record of who may provide payment and e-money services in Spain, under what status, and with which services, branches and passports. For a payment or e-money institution it is a working tool: it is where the market sees your authorisation, where your agents and distributors become legal, and where you check a counterparty before you sign. This article is about using the register, not about obtaining a licence.
1. What the Registro de entidades is
The Registro de entidades is the Banco de España (BdE) register of institutions supervised by the BdE or by the European Central Bank. The BdE states that registration is mandatory before certain regulated financial activities can be carried on, and that the register shows each institution’s authorised activities and every change to its data over time. Consulting it is free.
In June 2026 the BdE announced a relaunched register website at app.bde.es/rbe_spa, with a stronger search engine, structured data on type, roles, status and activities, and alert subscriptions. The search page shows the date of the last update and accepts a name, the BdE register code, or an identifying document such as a NIF or LEI.
Two features matter for compliance work. The register keeps historical as well as current data, so you can see an entry as it stood on a given date. And a revoked registration is not deleted: the entity stays with the status baja, the date and the reason.
Agents sit in a companion application, the Registro de agentes. The BdE also publishes downloadable files, including payment service providers, e-money distributors and providers relying on the exclusions in Royal Decree-law 19/2018, each with its own reference date.
2. Legal basis
- Royal Decree-law 19/2018 (RDL 19/2018), the Spanish transposition of PSD2. Article 13 requires payment institutions to be entered in the BdE special register before starting activity and makes the register public online. Article 14 brings exempt payment institutions into the same register.
- Royal Decree 736/2019. Article 5 lists what the register records — payment institutions, their branches and agents in Spain and other member states, account information service providers, exempt entities, the services each may provide and the safeguarding method — and requires it to be updated without delay. Revocations are notified to the European Banking Authority (EBA), and the register links to the EBA register.
- Law 21/2011 on electronic money and Royal Decree 778/2012, whose Article 5 does the same for e-money institutions: registration before operating, activities, branches and agents, the member states served under free provision, and the safeguarding method.
Directors and general managers go in a separate BdE register of senior officers, not in the entity entry.
3. How to read an entry
Each block of an entry answers a different due diligence question.
- Código BE — the registration code at the BdE. In the payment and e-money entries we checked it is a four-digit number; some other categories, such as EEA credit institutions in free provision, carry alphanumeric codes. Search by it and quote it in correspondence with the BdE.
- Identifying documents — the NIF and, where recorded, the LEI or home-country code. Match these, not the name, against your onboarding file.
- Registered as — the role and its date: entidad de pago, entidad de dinero electrónico, entidad de pago exenta según art. 14 RDL 19/2018, account information service provider, branch of an EEA payment or e-money institution, or EEA institution in free provision. An exempt institution is not interchangeable with an authorised one.
- Parent entity and country of origin — for a branch, the head office and home state, which tells you who authorised the firm.
- Activities — each payment service coded by the numbering of Article 1.2 RDL 19/2018 (for example 3.C for credit transfers or 5.B for acquiring), plus e-money issuance, distribution and redemption, each with a start date.
- Countries of operation — outbound passports by country, with the mode (free provision, branch, agents or distributors) and start date.
- Safeguarding — the method, such as deposit in a separate account, and when it was recorded.
- History — variations by effective date: registration, deregistration, name or address changes, activities, cross-border activity, administrators and identifying documents.
The BdE also lists entities with a current aviso, a warning or note attached to an entry. Read it before relying on the entry.
4. Agents: the Registro de agentes and the two-month rule
Agents are not shown inside the principal’s entry. The Registro de agentes holds agents declared by credit, payment and e-money institutions and can be searched both ways: an institution’s agents, or the principal behind an agent.
The principal files. Under Article 23.1 RDL 19/2018 it gives the BdE the agent’s name and address, the AML controls that will apply, the identity and fitness of the agent’s managers, the services entrusted and any unique identifier. Article 13 RD 736/2019 adds the institution’s AML procedures and its procedures for selecting and training agents, which the BdE forwards to SEPBLAC.
Article 23.2 RDL 19/2018 sets the timing: within two months of receiving the information, the BdE tells the institution whether the agent has been registered. The agent may start only after registration, and the BdE refuses registration if doubts about the information remain.
Registration does not shift liability. The institution is fully responsible for its agents, and Article 14 RD 736/2019 requires it to control them at least once a year, publish an up-to-date agent list on its website, attach that list to its annual accounts, and ensure agents tell users whom they act for. E-money institutions follow the same rules for payment services, but Article 14.2 RD 778/2012 forbids them to issue e-money through agents.
5. E-money distributors are registered too
Article 14.3 RD 778/2012 lets an e-money institution distribute and redeem e-money through persons acting on its behalf, but those distributors must be registered with the BdE before they operate. The institution notifies the distributor’s name, address, administrators and managers, and any unique identifier. The BdE publishes the list.
For an operator used to the French regime, where domestically mandated distributors are not registered with the supervisor, this is the point to recalibrate: in Spain a distributor missing from the BdE list is a finding, not an expected gap.
6. Passports, the EBA register and which source to trust
Outbound passports start at the BdE. Under Article 22 RDL 19/2018 a Spanish institution notifies the BdE before using a branch, free provision or agents in another member state; after a positive assessment the BdE forwards the file to the host authority within one month, and the branch or agent may begin once registered. Article 10 RD 778/2012 applies the same procedure to e-money institutions, distributors included.
Inbound passports start at the home supervisor. Under Article 9 RD 736/2019 and Article 11 RD 778/2012 the BdE can raise concerns within one month of the home authority’s communication; an approved branch is entered in the register and may start, and one that has not started within a year may be removed. EEA institutions operating through agents can be required to appoint a central contact point.
The BdE’s search page adds an instruction: to check whether an institution from another member state provides payment services in Spain without an establishment or through an agent, consult the EBA register. That register rests on Article 15(1) PSD2 and Regulations (EU) 2019/410 and 2019/411; national authorities supply and update its data at least daily, and the EBA states it has no legal effect.
| Source | Kept by | What it shows | Use it to |
|---|---|---|---|
| Registro de entidades | BdE | Spanish PIs, EMIs, exempt PIs, AISPs, EEA branches; services, passports, safeguarding, history | Verify a Spanish firm or an EEA branch in Spain |
| Registro de agentes | BdE | Agents declared by credit, payment and e-money institutions | Gate agent go-lives; find an agent’s principal |
| Distributors list | BdE | Distributors declared by e-money institutions | Check every e-money point of sale is declared |
| EBA register | EBA, from national data | PIs, EMIs, agents, branches, AISPs, exempt and excluded providers EEA-wide | Check EEA firms serving Spain without a branch or through agents |
If the two disagree about a Spanish firm, the BdE register is the national record. For an EEA firm, the home register is authoritative.
7. Using the register for counterparty checks
- Search by NIF or LEI; confirm name, trade names, historical names and address.
- Confirm the role fits the relationship: authorised, exempt, AISP, EEA branch or free provision.
- Check the activity codes and start dates against what you are contracting for.
- Read any aviso and the recent variation history.
- For an EEA firm, verify on the home register and the EBA register.
- For an agent, confirm the principal in the Registro de agentes; for an e-money point of sale, check the distributors list.
- Save the entry with the BdE update date in the file, and repeat at each periodic review.
Where a formal record is needed, the BdE electronic office runs a procedure for queries and certificates on registered entities (code ES_BDE_C463_P81).
8. Keeping your own entry right
The register reflects what was authorised, notified or communicated, so a wrong entry is fixed through the filing route:
- Institutional data. RD 736/2019 requires substantial changes to the authorisation file to be reported without delay (Article 2.6), bylaw changes to be communicated or authorised (Article 6), senior appointments to be notified (Article 5.7), and a change of safeguarding method to follow Article 16.1.
- Agents. Changes and terminations are declared by you as principal, not by the agent.
- Passports. Changes abroad repeat the passport procedure; for an inbound EEA branch the change starts at home (Article 9.5 RD 736/2019).
The BdE publishes no dedicated correction form or turnaround time. Quote the código BE, use the channel of the underlying filing, and recheck the entry history until the variation appears.
9. Worked cases
An agent network that wants to launch next week
Facts: a Spanish payment institution signs agency contracts with 30 outlets for money remittance, files the agent information, and the commercial team wants the outlets live in ten days.
What the rule says: the BdE has two months to register each agent, and an agent may start only after registration (Article 23.2 RDL 19/2018).
What the practitioner does: holds the launch, checks the Registro de agentes outlet by outlet, activates access only when each entry appears, and updates the website agent list.
Outcome: no unregistered activity, and an audit trail showing each go-live followed the register.
A partner “authorised in Spain”
Facts: an e-money institution authorised in another member state offers card issuing to a Spanish payment institution’s customers and describes itself as authorised in Spain.
What the rule says: it serves Spain under its home authorisation and a passport; the BdE points to the EBA register for EEA firms acting without an establishment.
What the practitioner does: finds no Spanish branch in the BdE register by LEI, then confirms the passport and activity on the home and EBA registers, recording all three checks with dates.
Outcome: the file shows a passported firm and identifies the supervisor that would act.
Prepaid cards sold in shops
Facts: a Spanish e-money institution sells prepaid cards through shops that load and redeem balances; an audit finds only part of the chain on the BdE distributors list.
What the rule says: Article 14.3 RD 778/2012 requires distributors to be registered before they operate.
What the practitioner does: suspends loading and redemption at the undeclared shops, notifies them, and reconciles the distribution inventory against the BdE list.
Outcome: the gap is remediated as a breach, and the reconciliation becomes a recurring control.
10. FAQ
Is the Registro de entidades free to consult?
Yes, and the search page shows the date of the last update.
What is the código BE?
The institution’s registration code at the Banco de España. Search by it and quote it when you contact the BdE about your entry.
When may a new agent start operating?
Only once registered. The BdE has two months from receiving the information to tell the institution whether the agent is registered.
Are e-money distributors registered in Spain?
Yes. Article 14.3 RD 778/2012 requires registration before a distributor operates, and the BdE publishes a list.
Where do I check an EEA firm operating in Spain without a branch?
The BdE points to the EBA register; the home authority’s register is authoritative.
What happens to an entry when a licence is revoked?
It stays in the register with the status baja, the date and the reason, and the revocation is notified to the EBA.
11. What to do, today
- COO: pull your own entry and confirm role, activity codes, passports and safeguarding match your authorisation file.
- Head of partnerships: make a dated BdE, home-register and EBA check a precondition for every payment counterparty.
- Agent network owner: gate every go-live on the Registro de agentes and plan launches around the two-month window.
- E-money product owner: reconcile every distribution point against the BdE distributors list.
- Compliance: keep the website agent list and the annual-accounts annex in step with the register, and control agents at least annually.
Related: REGAFI, the French register · PSD2 agents and distributors: register and liability · Safeguarding in Spain under Article 21 RDL 19/2018 · PSP registers compared across the EU
