What is CIRBE — the Spanish credit-risk register?

CIRBE — the Central de Información de Riesgos del Banco de España — is Spain’s central credit-risk register. Every Spanish-licensed lender feeds it monthly with the credit exposures it holds; every Spanish lender queries it before opening a new exposure. It is the data backbone of credit decisions in Spain, and one of the oldest still-running data services at Banco de España.

1. What CIR / CIRBE is

CIR — sometimes referred to as CIRBE when emphasising the institution that operates it — is the Central de Información de Riesgos held at Banco de España. It records every credit exposure of Spanish-resident lenders above a low de-minimis threshold: loans, credit lines, guarantees, derivatives, repos. Aggregated by debtor, the file gives a complete picture of someone’s borrowing position across the Spanish financial system.

The legal basis is Ley 44/2002 (the “Reform Law”) and BdE Circular 1/2013, which set the format and frequency. CIR feeds — and is fed by — the EU’s AnaCredit framework, the centralised analytical credit dataset run by the ECB.

2. Who feeds CIR

All Spanish-resident lenders:

• Banks (CRR institutions)
• Specialised lending establishments (EFCs)
• Branches in Spain of foreign credit institutions
• Where applicable, large EMIs/PIs that hold credit exposures (uncommon — most do not)

Pure payment-only EMIs and PIs typically do not lend, and so are not in CIR scope. The moment an EMI starts extending credit to its customers — a credit-line product, an overdraft, or a buy-now-pay-later structure — CIR enters scope.

3. What is reported

For each exposure, monthly:

• Debtor identification — NIF, sector code, group of connected clients
• Exposure amount, currency, drawn vs. undrawn
• Type of operation (loan, line, guarantee, derivative, repo)
• Maturity
• Collateral and guarantees
• Default status and impairment

BdE distinguishes a “declaración reducida” (reduced declaration) for smaller filers from the “declaración normal” full version. The reduced version captures fewer fields and is open to lenders below thresholds; the full version is the default for most CRR-banks.

4. Querying CIR

Two query routes:

• Lender query — a Spanish lender investigating a prospective borrower. Returns the borrower’s aggregated exposures across all reporting institutions, anonymised at the level of “X amount with Y other lenders”.
• Borrower query — any natural or legal person can request their own CIR record from BdE, free of charge, to see what is held about them.

Lender access is controlled — purpose-bound to credit-decision use, logged, and audited.

5. CIR and AnaCredit

CIR pre-dates AnaCredit by decades. When the ECB rolled out AnaCredit, BdE rebuilt CIR’s reporting taxonomy to feed AnaCredit upstream. In practice, a Spanish lender files one set of credit-exposure data; BdE re-shapes it into the AnaCredit submission to the ECB. This keeps a single national source of truth and avoids parallel filings — an unusually elegant supervisory plumbing decision.

6. What to do, today

• If you are a payment-only EMI or PI, you are almost certainly out of CIR scope. Confirm by mapping your products against the credit-exposure definitions in Circular 1/2013.
• If you offer credit (overdrafts, lines, BNPL), build CIR reporting into your product roadmap from day one. Retro-fitting an exposure data model is painful.
• Treat the CIR file as the source of truth for AnaCredit too — designing both flows separately is a common waste of build time.

7. FAQ

Related: What is DTE? · What is EDITRAN? · What is SEPBLAC?