BME Growth is the name that the former Mercado Alternativo Bursátil (MAB) has had since 3 September 2020. It is a multilateral trading facility of BME, registered by the CNMV as an SME growth market, on which medium-sized companies and SOCIMI are listed with lighter requirements than those of the Stock Exchange.
This guide summarizes what it is, what it requires today under the market's own rules, how much it costs according to published fees and when a tokenized issuance without listing fits best.
What is BME Growth and what does the name mean
BME created the MAB in 2006 as a multilateral trading facility (MTF) for smaller companies. On 3 September 2020, after obtaining CNMV recognition as an SME growth market, the European SME Growth Market category provided for in MiFID II, it was renamed BME Growth. The name refers to that category. If a document talks about the MAB, read BME Growth: it is the same market with the current brand.
Today BME Growth is a segment of BME MTF Equity, alongside BME Scaleup. The SME growth market designation is set out in article 76 of the Ley 6/2023 del Mercado de Valores: the CNMV may register as such the MTFs or segments that request it and meet the requirements, including that at least half of their issuers are SMEs. The category allows issuers to benefit from lighter documentary burdens that European regulations reserve for these markets.
BME Growth is not a regulated market. The Mercado Continuo is the trading system of the Stock Exchanges, which are regulated markets: admitting shares there requires a prospectus approved by the CNMV (art. 35 of Ley 6/2023) and broader transparency obligations. On BME Growth, if there is no public offering, admission can be done with an information document reviewed by the market itself.
Requirements for listing on BME Growth
They are set by BME Growth Circular 2/2026, approved on 27 April 2026, which replaces Circular 1/2025. These are the requirements as set out in it:
| Requirement | What Circular 2/2026 requires |
|---|---|
| Issuer and securities | Public limited companies, Spanish or foreign, with fully paid-up capital, shares represented by book entries and no restrictions on their free transferability. Also SOCIMI and analogous foreign real estate vehicles; BME cited Mexican FIBRAs as an example when opening this option in 2025 (more in tokenization in Mexico). |
| Activity | Already marketing products or services and generating significant revenues. |
| Size | Market capitalization below 1,000 million euros. |
| Track record | Without 24 consecutive audited months, forecasts for the current and following financial year approved by the board of directors. |
| Continued listing | With less than two years of operations, principal shareholders, directors and executives undertake not to sell during the year following admission. |
| Articles of association | Notification of 5 % holdings and their multiples within four business days, disclosure of shareholder agreements, purchase offer to shareholders if delisting is approved without unanimity and offer to all in the event of a change of control (more than 50 %). |
| Dissemination | Shares held by shareholders with less than 5 % of capital must add up to an estimated value of no less than 2 million euros. In a SOCIMI, 2 million or 25 % of the shares. |
| Registered advisor | Appointed from among those registered in the market register. |
| Liquidity | Liquidity contract with a financial intermediary. |
| Valuation | Report by an independent expert, unless there has been a placement in the previous six months that sets a reference price. |
| Documentation | Prospectus registered with the CNMV if there is a public offering; otherwise, an Admission Information Document. If the company has been on BME Scaleup or another market for at least 18 months, a Reduced Information Document is sufficient. |
| Accounting | IFRS or national accounting standards if the company is from the European Economic Area; IFRS or US GAAP otherwise. |
| Timeline | The market must issue its decision within a maximum of three months from the application. |
Two practical consequences for a Spanish SME. A private limited company must convert into a public limited company before applying for admission. And shares represented in DLT would have to be converted into book-entry form, which is the form required by the circular; Ley 6/2023 allows that change under the terms set by the regulation (art. 6.3).
Registered adviser and liquidity provider
The registered adviser supports the company during admission and throughout its time on the market: assesses whether it meets the requirements, assists with the information document and advises it on its disclosure obligations. Ley 6/2023 allows MTFs to require this role (art. 72) and BME regulates its registration and functions in a specific circular.
The liquidity provider is the financial intermediary that signs a liquidity contract with the company to facilitate trading in its shares. The circular allows that contract to follow the model that the CNMV may approve, if applicable. It is mandatory on BME Growth; on BME Scaleup, voluntary.
Neither has a public fee schedule: each firm sets its own fees. Before starting, ask two or three registered advisers for proposals and compare scope, team and annual cost.
How much does it cost to list on BME Growth
The part charged by the market is published in Circular 1/2025 on BME MTF Equity fees, dated 26 May 2025:
| Concept | Fee on BME Growth |
|---|---|
| Application processing | 3,000 € for initial admission |
| Admission | 11,000 € fixed plus 0.06 per thousand of market capitalisation based on the first price |
| Annual maintenance | 0.05 per thousand of market capitalisation at the close of the previous financial year, with a minimum of 6,500 € and a maximum of 25,000 € |
| Financial analysis | If the stock has no published research, BME arranges one with an annual fee of 8,000 € |
Illustrative example: a company that joins with 50 million euros in market capitalization would pay the market about 17,000 € to enter (3,000 for the file, 11,000 fixed and 3,000 variable portion) and the minimum of 6,500 € per year for maintenance, because 0.05 per thousand would give only 2,500 €. To that are added the costs not set by BME, which usually weigh more: registered adviser, liquidity provider, audit, independent valuation, legal advice and the internal reporting team. Calculate the total cost of staying listed, not just the exit cost.
BME Growth, BME Scaleup or tokenized issuance
BME Growth is above BME Scaleup, BME's own entry tier, and below the Stock Exchange. Tokenized issuance is something else: it does not provide listing, it provides a digital register of the security and targeted fundraising.
| Criterion | BME Growth | BME Scaleup | Tokenized issuance |
|---|---|---|---|
| What the issuer gets | Listing on a market for expanding SMEs | Listing on the entry segment | Securities registered on DLT and targeted fundraising, without listing |
| Legal form | SA with shares in book-entry form | SA with shares in book-entry form | SA for shares; SA or SL for debt; in the case of an SL, with the limit of twice its own funds unless guaranteed (art. 401 of the Ley de Sociedades de Capital) |
| Minimum free float | 2 M€ held by shareholders with less than 5 % | Not required | Not applicable |
| Intermediaries | Registered adviser and liquidity provider, mandatory | Registered adviser mandatory; liquidity voluntary | ERIR designated in the issuance document (art. 8 of Ley 6/2023 and RD 814/2023) |
| Document | Prospectus or Information Document for Incorporation | Prospectus or Initial Market Access Document (DIAM) | Issuance document, with prospectus or exemption |
| Market fees | 3,000 € + 11,000 € + 0.06 per thousand; maintenance from 6,500 to 25,000 € per year | 1,500 € + 10,000 € + 0.05 per thousand; maintenance of 5,000 € per year | No market fee; ERIR and platform according to contract |
| Liquidity | Trading on the market with liquidity provider | Trading on the market; optional liquidity provider | Registered transfers; an organized secondary market requires an MTF under the DLT Pilot Regime (Regulation (EU) 2022/858) |
BME Scaleup fees come from the same fee circular (excluding the specificities of SOCIMIs). The comparison between going public and issuing a security token, in more detail, is in IPO vs STO.
BME Growth or tokenized issuance: what problem does each solve
BME Growth solves two things well: giving the company visibility and reputation and creating a market in which shareholders can sell. What it does not solve so well is raising a specific amount for a specific project on a one-off basis: for that, the permanent structure it requires can be disproportionate.
A tokenized issuance represents shares or bonds through distributed ledger technology, is registered by an ERIR and raises funds in a targeted way, usually among professional investors or those in the issuer's circle. As of June 5, 2026, an offer of up to 12 million euros over 12 months may be exempt from prospectus under the Prospectus Regulation amended by the Listing Act, with a Member State option of 5 million; the CNMV indicates that the Spanish implementation is pending.
To decide, the useful question is not which is better, but what you are looking for:
- That current shareholders can sell and that the company gains reputation with customers and banks: an organized market does something that an issuance does not.
- Raising a specific amount for a project without permanently changing how the company operates: a securities issuance comes with less recurring structure.
- Both: they are not incompatible over time. You can raise first and consider the market when size justifies it; the reduced route of Circular 2/2026 also makes it easier to move from BME Scaleup to BME Growth after 18 months.
What does not work is choosing by the label. Listing imposes a permanent structure; issuing, a transaction with its own framework. The process for the latter is in how to issue a security token in Spain, and the approach for mid-sized companies, in tokenization for SMEs.
Related: MARF, its fixed income equivalent.
Are you considering listing or raising financing without going to market? Take the issuance diagnostic (2 min) or request a proposal.
This content is informative and educational. It does not constitute legal, tax, or investment advice. Check the current version of each regulation in the BOE and on EUR-Lex.
HokenFi is a software and infrastructure provider; it does not provide regulated services (CASP, ESI, EAF, or ERIR). This article is informative and does not constitute financial or legal advice.
Frequently asked questions
What does BME Growth mean?
It is the current name of the Mercado Alternativo Bursátil (MAB). Since 3 September 2020 it has been called BME Growth, after obtaining from the CNMV the European category of SME growth market (SME Growth Market). It is a segment of BME MTF Equity, BME's multilateral trading facility, on which growing mid-sized companies and SOCIMIs are listed.
Is BME Growth a regulated market?
No. BME Growth is a multilateral trading facility supervised by the CNMV and registered as an SME growth market, not a regulated market like the Stock Exchanges. That is why admission without a public offering can be done with an Information Document for Admission instead of a prospectus approved by the CNMV, and disclosure obligations are lighter than in the Continuous Market.
What is the difference between BME Growth and the Continuous Market?
The Continuous Market is the trading system of the Spanish Stock Exchanges, which are regulated markets: admission requires a prospectus approved by the CNMV and broader transparency. BME Growth is a multilateral trading facility for companies with a market capitalization below 1,000 million euros, with tailored requirements: registered adviser, liquidity provider and a minimum free float of 2 million euros.
What requirements does BME Growth ask for to list?
According to Circular 2/2026: be a public limited company with paid-up capital and shares in book-entry form, have significant revenue and a market capitalization below 1,000 million, appoint a registered adviser, sign a liquidity contract, provide an independent valuation and that shareholders with less than 5% add up to at least 2 million euros. Without 24 months of audited accounts, forecasts must be submitted.
How much does it cost to list on BME Growth?
According to Circular 1/2025 on BME MTF Equity fees, the market charges 3,000 euros for the admission file, 11,000 euros plus 0.06 per thousand of market capitalization for admission and annual maintenance of 0.05 per thousand, with a minimum of 6,500 and a maximum of 25,000 euros. Separately, there are the registered adviser, the liquidity provider, the audit and legal advice.
