The ENISA loan is a public participating loan from €25,000 to €1,500,000, unsecured. As a general rule, it is repaid over up to 7 years, with a grace period of up to 2. Its interest has two tranches: one-year Euribor plus a spread that depends on the rating, and a second tranche linked to your profitability, with a cap. It requires your equity to equal at least the amount you request.
If you need more than your equity allows, or on a different timeline, you have alternatives that do not dilute your shareholders. They are a participating loan with investors you already know, crowdlending through an authorized platform and the issuance of tokenized bonds. We compare them using data from enisa.es and the BOE consulted on 1 November 2026.
What lines does ENISA offer in 2026
If you are looking for the Young Entrepreneurs, Entrepreneurs or Growth lines, they do not currently appear as separate products on enisa.es. The website publishes a general line, Financing for startups and SMEs, and four sectoral programs whose fact sheets repeat the main conditions of the general line (amount, term, grace period and opening fee):
- Digital Women Entrepreneurs: technology SMEs in which one or more women have a significant role in ownership, management or the board.
- AgroInnpulso: innovative or technology-based SMEs in the agri-food chain.
- Audiovisual and Cultural and Creative Industries: audiovisual, video games and cultural and creative industries with a digital focus.
- Innovation x Climate: climate resilience solutions or companies affected by a civil protection emergency.
The general line is funded by the Entrepreneurship and SME Fund (FEPYME), which ENISA manages. The programs rely on agreements with ministries or, in the case of Innovation x Climate, on the Reinicia+ FEPYME DANA PLUS mechanism, and each one links to its own standard loan agreement.
Guidance: choose a sectoral program only if you meet its specific requirement. Term and grace period match the general line; confirm the specific spread in each program's agreement.
ENISA loan terms: amount, interest, term and grace period
| Concept | Condition (general line, according to the ENISA fact sheet) |
|---|---|
| Amount | From €25,000 to €1,500,000; ENISA assesses, among other factors, your equity and financial structure |
| First tranche | One-year Euribor plus a spread that ENISA sets each year based on the rating; quarterly settlement |
| Second tranche | The company's return on equity minus the first tranche; zero if negative and with a cap based on the rating |
| Term | As a general rule, up to 7 years, with quarterly principal amortization |
| Grace period | Up to 2 years for repayment of principal |
| Fees | 0.5% opening fee. For early cancellation, voluntary or due to a change of control, the second tranche the loan would have generated over its entire life, minus what has already been paid; the operational guide calculates it at the maximum rate |
| Guarantees | None in addition to the project itself |
ENISA does not publish its spread table on its website. The FEPYME operational guide linked from the page (PDF from August 2025) set a spread from 4.00% (rating A1) to 6.00% (C3) and a cap on the second tranche from 4.50% to 6.50%. Since ENISA reviews the spread every year, ask for the current table before calculating.
The standard policy linked by ENISA reviews Euribor once a year using the official figure published in the BOE. As a guide, the one-year Euribor for September 2026 was 3,247% (Bank of Spain, BOE of 2 October 2026).
For the second tranche, the standard loan agreement measures profitability as profit before tax divided by average equity, subtracts the first tranche and adds caps linked to profit and net equity. ENISA settles it once a year using your financial statements; if you do not submit them on time, it applies the maximum rate.
The operating guide adds maximum limits by rating, lower for companies with no track record, and adjusts the amount based on your equity. According to ENISA, the loan does not appear in the CIRBE.
Interest is a deductible expense for Corporate Income Tax. Net financial expenses have a general limit of 30% of operating profit, but up to €1 million per year are always deductible (LIS, art. 16.1). The exception is participating loans between companies in the same group (art. 15.a).
Guidance: calculate your cost using the maximum rate of the second tranche. That is what you will pay if things go well, and also the basis for the fee if you repay early or if control of your company changes.
ENISA requirements: equity is key
- A commercial company incorporated in Spain, with its tax domicile in Spanish territory.
- SME: fewer than 250 employees and revenue below €50 million or a balance sheet below €43 million.
- Equity at least equal to the amount you request.
- Any sector other than real estate and finance.
- An innovative business model and a solid business plan.
- Financial statements for the last financial year filed and being up to date with the tax authority and Social Security.
- Audited accounts if you request more than €300,000.
- Comply with the principle of doing no significant harm to the environment (DNSH).
While the loan is outstanding, you cannot deplete the company's capital. You also cannot distribute dividends or reduce capital without ENISA authorization if that affects the loan's viability.
ENISA does not publish a decision period. After submitting the application, you have 30 days to upload the documentation; otherwise, the application lapses (ENISA application guide for 2025).
If your equity is not enough, increase it before applying. The operational guide gives more weight to recent shareholder contributions when calculating the amount.
ENISA compared with other non-dilutive debt options
| Criterion | ENISA loan | Private participating loan | Crowdlending (PSFP) | Tokenized bonds |
|---|---|---|---|---|
| Amount | €25,000 to €1,500,000, without exceeding your equity | No legal cap; depends on your lenders | Up to €5M per developer in 12 months | In an S.L., up to twice its equity if there is no collateral |
| Cost | Euribor + spread based on rating and a capped second tranche; 0.5% arrangement fee | The rate you agree, with a variable portion and, if you wish, a fixed portion | Campaign rate and platform fees | The coupon you set, plus law firm and ERIR |
| Term | Up to 7 years, with up to 2 grace period | Agreed | That of each campaign | That of the issuance |
| Guarantees | No additional ones | Agreed | Depending on the project and the platform | Those you offer |
| Dilution | No | No, unless agreed capitalization | No | No; an S.L. cannot issue convertibles |
| Who invests | ENISA, with FEPYME funds | Few people you already know, with no advertising | The public, with the protections of the regulation | The investors in your offering; with advertising, an entity authorized for investment services is involved |
| Timing | No published decision period; 30 days to upload documentation | As long as the contract takes | Platform review and campaign | Issuance document and registration with the ERIR |
Private participating loan
It is the same legal instrument as the ENISA loan, with private lenders (we explain it in what a participating loan is). The interest has a variable part based on your activity and may include a fixed part. You can only repay it early if you increase your equity by the same amount. It ranks after ordinary creditors and counts as equity in capital reduction and liquidation (Royal Decree-Law 7/1996, art. 20).
Raising repayable funds from the public in the form of loans is reserved for credit institutions (Law 10/2014, art. 3.1). That is why this route works with a few lenders you already know and without advertising. With HokenFi, each contract is recorded in a digital register of participating loans that serves as evidence, without issuing securities and without going through an ERIR.
Crowdlending through a PSFP
An authorized crowdfunding service provider (CSP) publishes your project and opens it to the public. The Regulation (EU) 2020/1503 applies to offers of up to €5 million per project owner in 12 months (art. 1.2.c). If a non-sophisticated investor invests more than €1,000 or 5% of their net worth, whichever is higher, the platform must warn them of the risk, obtain their express consent and check that they understand it (art. 21.7). The rate and fees depend on each campaign. You can find more context in what crowdlending is.
Tokenized bonds under Law 6/2023
You issue negotiable securities represented with distributed ledger technology. You need an issuance document and an ERIR to keep the register (Law 6/2023, arts. 6.1, 7 and 8.4). A S.L. can issue without changing its legal form, up to twice its equity if there are no guarantees, but not convertible bonds (Capital Companies Act, art. 401.2).
If you publicly advertise an offer exempt from a prospectus, an entity authorized to provide investment services must be involved, unless you place it through a CSP (Law 6/2023, art. 36). We explain this in tokenized bond for SMEs.
A vocabulary note: a “tokenized participating loan” is not a security under Law 6/2023. The token only represents and proves the contract. If you want a negotiable security, the instrument is the bond.
Example: an SME that needs €300,000
An industrial S.L. with six years of activity needs €300,000 for a production line. It has average equity of €400,000 and expects a profit before tax of €60,000, 15% of that equity. We assume ENISA grants it €300,000 with rating B2, although ENISA decides the rating and the amount. For the cost we use the B2 values from the 2025 operational guide: spread of 5.00% and cap for the second tranche of 5.50%.
With ENISA. It meets the equity requirement and does not need an audit, because it is not requesting more than €300,000. If Euribor remained at 3,247%, the annual cost would be:
- Arrangement fee: €1,500, one time only.
- First tranche: 3,247% + 5.00% = 8,247%, that is, €24,741 per year.
- Second tranche: 15% − 8,247% = 6,753%, capped at the assumed cap of 5.50%, that is, €16,500.
- Total in a good year: €41,241, 13.7%. In a year with no profit, only the first tranche: €24,741.
For the first two years it pays only interest. After that it repays €15,000 per quarter for five years.
With the alternatives. These figures are assumptions for comparison, not market data:
- Private participating loan: ten people from its network lend €30,000 each at a fixed 3% plus 10% of net profit. With a net profit of €45,000, it would pay €9,000 + €4,500 = €13,500 per year.
- Crowdlending: at a rate of 9%, €27,000 per year in interest, plus the fee set by the platform.
- Tokenized bonds: 300 bonds of €1,000 at 8% over four years, with repayment at maturity, amount to €24,000 per year plus the law firm and the ERIR. With €400,000 of equity, the S.L. could issue up to €800,000 without guarantees.
The decision. ENISA makes sense if your equity covers the amount and you value the unsecured grace period; with high earnings, the second tranche makes it more expensive. The issuance fits if you need more than ENISA gives you, want a fixed cost or already have interested investors. The routes can be combined: ENISA presents itself as a co-financier, and a prior capital increase raises the equity it requires, including if an S.A. does so with tokenized shares.
Common mistakes
- Asking for more than your equity covers.
- Calculating the ENISA cost using only the first tranche.
- Forgetting the fee for early repayment or for a change of control, which is calculated at the maximum rate of the second tranche.
- Announcing a private participating loan on social media: raising repayable funds from the public is a reserved activity.
- Issuing bonds from an S.L. above twice its equity without guarantees.
To see the full map of options without a bank, review our guide to alternative financing for companies.
This content is informative and educational. It does not constitute legal, tax or investment advice. Verify the current version of the rules in the official sources before making decisions.
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
Does the ENISA loan dilute shareholders?
No. ENISA does not take an equity stake or intervene in management. In return, during the life of the loan it asks you to report relevant changes in the corporate structure or in the management body, avoid undercapitalization and not pay dividends or reduce capital without its authorization when that could compromise the viability of the transaction.
Can a newly created company apply for an ENISA loan?
It can, but confirm it with ENISA first. Its 2025 application guide covers newly created companies and requests the accounts for the last three financial years only if they exist. The current line fact sheet, by contrast, requires the accounts for the last financial year to have been filed. If your company has not yet closed any financial year, ask whether you can apply and with what amount limit.
Can I repay the ENISA loan early?
You can, but it has a cost. For early repayment, ENISA charges a fee equivalent to the second tranche the loan would have accrued until maturity, minus what has already been paid for that item. Its operational guide calculates it at the maximum rate. The same formula applies if ENISA declares early maturity due to a change in the majority control of your company.
Do I need a prospectus or an investment services entity to issue €300,000 in tokenized bonds?
Normally a prospectus is not required, because that amount is well below the exemption thresholds. An authorized entity to provide investment services is also not mandatory if you do not promote the offer to the general public with advertising. For an issuance not admitted to trading, you do need the issuance document and to appoint an ERIR, and your company must respect the limits of the Companies Act.
