Choosing an ERIR in Spain is, these days, more planning than comparison: supply remains highly concentrated (Ursus-3 Capital was the first ERIR and, as of October 2026, the one on record in the CNMV registry), so the real decision is fitting into its schedule and preparing the documentation properly. The criteria that do depend on the issuer are deadlines, integration with the platform, and what part of the process each party takes on.
You have a security token issuance on the table and you're missing a piece: the ERIR. You know you need it, but no one has told you what criteria to use to choose it. Do you compare prices? Timelines? Integration with your platform? And here comes the uncomfortable nuance: as of October 2026 the offering is still highly concentrated (the CNMV registry includes Ursus-3 Capital, the first ERIR), so "choosing" looks more like "planning to get into its schedule." This guide gives you the real criteria to evaluate and contract your ERIR, today and when the market opens.
To choose an ERIR, evaluate five things: current CNMV authorization, cost structure (initial and recurring), registration timelines, technical integration with your platform and continuity of the registry.
The ERIR is the digital notary of your registry: it records who owns each security represented on blockchain and gives those entries legal effect, not just technical effect. It is a regulated figure, not just any provider. That is why the first filter is not price, it is authorization. Without valid registration with the CNMV, no other advantage counts (art. 8 Ley 6/2023, LMVSI, BOE-A-2023-7053; RD 814/2023, BOE-A-2023-22764).
What it means for you: before looking at rates, confirm that the entity is authorized. Then rank the rest of the criteria according to your calendar and your technical stack.
Criteria for evaluating an ERIR
An ERIR does one thing with legal effect: register. But around that function there are differences that affect your cost, your timeline and your operations. These are the criteria that matter.
Current CNMV authorization
It is the eliminating criterion. The entity must be registered and authorized to act as an ERIR under the regime of RD 814/2023. Check the registration in the CNMV's official registers and ask for the reference. An entity that is "processing" its authorization is no good for registering an issuance with legal effect today (RD 814/2023, BOE-A-2023-22764).
Cost structure
There are two blocks. An initial cost, linked to onboarding and registration of the issuance. And a recurring cost, for maintaining the registry while the security is alive. Ask for the breakdown separately. An "all-inclusive" fee without detail prevents you from comparing and makes it harder to budget for the life of the security, which can last years.
Timelines and schedule
Registration is not instant. It has a calendar, and that calendar depends on the entity's workload. Ask for the timeline from when you deliver the issuance document to effective registration. With only one entity in the market, the schedule is the real bottleneck, not the paperwork.
Technical integration
The registry lives in a distributed ledger technology (DLT) system. Your issuance platform must talk to the ERIR's system. Ask what formats it accepts, whether there is an API or the exchange is manual, and who validates the correspondence between what you record on-chain and what appears in its ledger. A manual integration multiplies errors and delays.
Continuity of the registry
The registry has to outlive the issuance. Ask what happens to your entries if the entity ceases, how a migration is done and what document retention guarantees it offers. The legal continuity of the registry is not an extra: it is the very reason for the figure's existence.
The first ERIR authorized in 2026: what it means for you
As of October 2, 2026, the entity listed in the registry of authorized ERIRs of the CNMV is Ursus-3 Capital, the first one (November 2024). Bestinver Securities announced in May 2026 its authorization as an ERIR, but it does not yet appear in the registry. This changes how you plan: today you hardly choose between options; above all, you plan to get into the schedule of the available entity.
It has three practical consequences. Capacity is finite, so the date of your registration depends on the queue. Your bargaining power on price and timelines is limited while competition is scarce. And your planning moves forward: reserving a slot early stops being prudent and becomes necessary.
What it means for you: treat the ERIR designation as one of the project's first decisions, not as a final formality. Get in touch before you have the rest finalized. The issuance document (art. 7 LMVSI) can be refined as you go, but the slot in the schedule cannot be improvised (art. 7 Ley 6/2023, LMVSI).
What to ask before signing
Bring these questions to the first meeting. The answers tell you more than any brochure.
On cost
What is the setup cost and the issuance registration cost? What is the recurring maintenance fee and how often is it billed? Is there a cost for registry amendments (transfers, increases, redemptions)?
On timelines
What is the timeline from delivery of the issuance document to registration? What is your availability this quarter? What do you need from me to start counting that timeline?
On integration and continuity
How does your registry connect to my issuance platform? What happens to the registry if you cease operations? How are the entries preserved and migrated?
Checklist and criteria classification
Use this table to score each candidate. When there is more than one entity, it will help you compare side by side.
| Criterion | What to confirm | Signal |
|---|---|---|
| CNMV authorization | Valid registration and reference in official registries | Viable if registered; not viable if “in process” |
| Initial cost | Setup plus issuance registration, itemized | Viable if there is a breakdown; gray area if it is a flat fee with no detail |
| Recurring cost | Registry maintenance and frequency | Viable if it is predictable for the entire life of the security |
| Timelines | Time to registration and availability | Gray area if the queue does not fit your calendar |
| Technical integration | API or manual exchange with your platform | Viable with API; gray area if everything is manual |
| Continuity | Cessation, migration, and document retention plan | Not viable if there is no clear answer |
What it means for you: authorization and continuity are knockout criteria. Cost and timelines are negotiable, but only when there is competition. Technical integration is where you can prepare the ground right now.
What to do now
Organize your decision into concrete steps:
- Review what this entity does and does not do in what an ERIR is, so you arrive at the meeting with the terminology clear.
- Place the ERIR within the full process with how to issue a security token in Spain and prepare your issuance document.
- If you are still deciding on the model, review the guide to asset tokenization for companies.
- Contact the authorized entity soon to book time and ask for the breakdown of costs and timelines in writing.
- Check the terms you are not familiar with in the glossary.
Frequently asked questions
How many ERIRs are authorized in Spain as of 2026?
One in the CNMV registry as of October 2, 2026: Ursus-3 Capital, the first entity authorized by the CNMV to act as an ERIR under RD 814/2023. That is why it is advisable to plan the designation early.
How much does it cost to engage an ERIR?
The cost is structured in two blocks: an initial one, for onboarding and registration of the issuance, and a recurring one, for maintaining the registry while the security is outstanding. Ask for the breakdown separately so you can budget for the entire life of the security.
Can I choose between several ERIRs?
Still very little: as of October 2026, the CNMV registry lists one designated entity, although Bestinver Securities announced its authorization in May. When there are several registered, evaluate current authorization, cost structure, timelines, technical integration and continuity of the registry, in that order of priority.
What do I need to submit to the ERIR to register my issuance?
The issuance document is the centerpiece: it identifies the security and its characteristics (art. 7 LMVSI). The registration period starts from its submission, so have it polished before booking a slot.
When should I choose the ERIR within the project?
Early. With only one entity available, scheduling is the bottleneck. Treat the designation as one of the first decisions, not as the last formality before issuing.
What happens to my registry if the ERIR ceases operations?
There must be a continuity plan: migration of records and document retention. It is a knockout criterion. If the entity does not give you a clear answer, do not sign.
Notice
Informational content. It does not constitute legal, tax or investment advice. HokenFi is a software and infrastructure provider; it does not provide regulated services. Check the current version of the rules cited in the BOE and EUR-Lex.
Cited regulations
- Ley 6/2023, de 17 de marzo, de los Mercados de Valores y de los Servicios de Inversión (LMVSI), arts. 7 and 8 (BOE-A-2023-7053).
- Real Decreto 814/2023, de 8 de noviembre, por el que se desarrolla la Ley 6/2023, en lo relativo a registros y régimen de la ERIR (BOE-A-2023-22764).
The list of registered entities, verified against the CNMV and with a review date, is in the registry of ERIRs in Spain.
