Portfolio Stock Exchange is a multilateral trading facility (MTF) based in Spain. It is managed by European Digital Securities Exchange, S.V., S.A., a securities firm registered with the CNMV. The CNMV authorized its internal operating rules on 30 June 2022, for equity and fixed-income securities, and the market began operating in 2023. As of 1 November 2026, its own website shows 32 equity issuers with a joint market capitalization of €2,774.9M, almost all SOCIMIs.
If you manage the finances of an SME and are considering listing on a market, the admission price is only one part of the decision. What each market requires of you, who will be able to buy your securities and what liquidity you can expect all matter. This guide compares Portfolio with BME Growth, BME Scaleup, the MARF and a private issuance of tokenized securities, using data from the CNMV, BME and the entity itself.
What Portfolio Stock Exchange is and who manages it
An MTF is a trading venue regulated by MiFID II, different from a regulated market such as the Madrid Stock Exchange. The CNMV lists “Portfolio Stock Exchange (MTF)” in its register of market infrastructures, with European Digital Securities Exchange, S.V., S.A. as the governing company (CNMV, register of infrastructures). That company appears in the CNMV register as a securities firm, with number 314 since 13 January 2023.
In the infrastructure profile, the CNMV classifies Portfolio as a multilateral trading facility and states that its main products and operations are “shares and bonds”. The CNMV press release of 30 June 2022 refers to “securities admitted for the first time in equity and fixed income” (CNMV, press release). Its September 2023 market rulebook admits transferable securities, money market instruments and units or shares in collective investment institutions, always represented by book entries (3.2 and 3.3.1). Its website also presents segments for commercial paper and securitizations. The operator provides trading, custody and the paying agent function through the same entity.
What it means for you: listing on Portfolio is not listing on a stock exchange in the strict sense. It is an MTF, like BME Growth or the MARF, with its own admission rules and an operator supervised by the CNMV.
Status as of 1 November 2026
The most recent official figures are from the CNMV. At the close of 2024, Portfolio had 15 listed companies and €1,139M in aggregate market capitalization. At the close of 2025, there were 25 companies, according to the CNMV's 2025 annual report.
The entity's website, consulted on 1 November 2026, shows two blocks. These are the entity's own data, not the CNMV's, and they change daily:
- Shares: 32 issuers and €2,774.9M in total market capitalization. Of these, 29 include “SOCIMI” in their listing name and one is a venture capital company.
- ETPs and debt: 25 issues with a total volume of €836.1M. All have a French ISIN except one, which has an international ISIN.
What it means for you: today Portfolio is above all a market for SOCIMIs. If your company is industrial or technological, ask the operator for examples of comparable issuers before deciding.
Requirements for listing your company
The requirements come from the September 2023 market rulebook, which is the version published in the CNMV profile. The main ones are:
- Governance: the issuer must have a board of directors, with suitable directors and officers (section 5.2.1.3).
- Securities: represented by book entries, freely transferable and, if they are shares, fully paid up (3.3).
- Mandatory adviser: there is no BME registered adviser role. You must have a Legal Trusted Partner (a law firm) or an MTF Advisor approved by the operator, during admission and while your securities are listed (5.1).
- Financial information: audited accounts for the last two financial years, or a pro forma balance sheet if the company is newly incorporated (3.4.3). Sufficient working capital for the following 12 months (5.2.1.4).
- Document: an approved prospectus or, failing that, the issuance document under article 7 of Law 6/2023 (3.4.3).
- Articles of Association: if the delisting is not approved unanimously, the company must offer to buy the shares of anyone who did not vote in favor (5.2.1.9).
- Size: there is no minimum. If your shares are already listed on another MTF, your market capitalization must be less than €1,000M (5.2.1.1).
The rulebook does not set a minimum free float percentage. The liquidity provider is an agreement between the issuer and a market member, not an admission requirement (4.9).
What it means for you: before applying for admission, check three things: two years of audited accounts, adapted articles of association and an advisor approved by Portfolio.
What the listing process is like
- You complete the pre-admission form on the web platform and pay the application fee (3.4.2).
- The participants department assesses the application and the market council pre-approves or rejects it, stating whether the reason can be remedied.
- You sign the issuer agreement and upload the documentation: registered articles of association, corporate resolutions, accounts, prospectus or issuance document and shareholder register (3.4.3).
- The board decides on admission (3.4.4). The first listing can be carried out through a public offering, private placement or direct listing (3.4.1).
The regulations do not set a maximum resolution period. Portfolio's website mentions admission within two months: this is the entity's own figure, not a regulatory commitment.
How much it costs to list on Portfolio
The fees in this section come from Portfolio's 2023 fee prospectus, registered with the CNMV under number 337 and in force since 13 January 2023. It is the only one shown in the operator's profile as of 1 November 2026. Its amounts are the maximums published on that date, excluding VAT, so the actual price may be lower: ask for it in writing.
| Item (maximums from the 2023 prospectus) | Shares (except SOCIMIs) | Debt |
|---|---|---|
| Application fee | €5,000 | €5,000 |
| Trading fee (covers 12 months) | 0,125% of market capitalization, with a maximum of €300,000 | 0.0025% of the amount issued, between €2,000 and €20,000 |
| Annual maintenance fee (from the second year) | €5,000 | €5,000 |
| Annual custody fee | €20,000 | €20,000 |
| Registration with the DCV, annual | 0.70 basis points of market capitalization | 0.60 basis points of the amount issued |
SOCIMIs have their own tiers: 0,125% up to €120 million in market capitalization, €155,000 between €120 and €300 million, and €200,000 above that. If your shares already trade on another trading venue, the trading fee is zero. On top of that come the advisor fees, the auditor fees and, if you hire one, the liquidity provider fees, which do not have a public fee schedule.
Example with figures: an S.A. with a market cap of 30 million
Suppose a public limited company (S.A.) that is not a SOCIMI, with a market capitalization of €30 million. Using the maximums in the 2023 fee prospectus for Portfolio and Circular 1/2025 on BME MTF Equity fees, the charges would be:
| Market | Entry fee | Annual fee | Paid separately |
|---|---|---|---|
| Portfolio | Up to €64,600: application fee, €37,500 trading, €20,000 custody and €2,100 DCV | Up to €27,100 from the second year | Legal Trusted Partner or MTF Advisor |
| BME Growth | €15,800: €3,000 processing fee, €11,000 fixed and €1,800 variable | €6,500 (minimum fee) | Registered advisor and liquidity contract |
| BME Scaleup | €13,000: €1,500 processing fee, €10,000 fixed and €1,500 variable | €5,000 | Registered advisor |
The listing price is not the whole story. Portfolio includes custody and DCV registration in its fees. BME fees cover admission, maintenance in the trading system and information dissemination; the registered advisor and liquidity provider are contracted separately. On BME Growth, if your security has no published financial research, the market arranges one for an annual fee of €8,000. Criterion: ask for full three-year quotes, with all annual fees included.
Portfolio, BME Growth, BME Scaleup, MARF or tokenized issuance
| Portfolio | BME Growth | BME Scaleup | MARF | Private tokenized issuance | |
|---|---|---|---|---|---|
| Type | MTF of a securities firm | MTF, a segment of BME MTF Equity for growing SMEs | MTF, a segment of BME MTF Equity | BME's fixed income MTF | Not a market: private placement with DLT registration by an ERIR (art. 8 of Law 6/2023) |
| Company size | No minimum; less than €1,000M if it comes from another MTF | Market capitalization below €1,000M and significant revenue | Companies that already sell and generate revenue; no minimum free float | Any issuer able to issue fixed income | S.A. for shares; an S.L. only bonds, up to twice its equity unless guarantees |
| Main requirements | Approved adviser, two years of audited accounts, prospectus or issuance document | Registered advisor, €2M held by shareholders with less than 5%, independent expert valuation | Registered adviser, expert valuation, access document or prospectus | Registered advisor per issuance, two years of audited accounts, base information document, minimum denomination of €100,000 | Issuance document (art. 7) and designated ERIR; prospectus if the offer is not exempt |
| Published market costs | Maximums in the 2023 prospectus: application €5,000, trading 0,125% and €25,000/year plus DCV | €14,000 plus 0.06‰ listing fee; between €6,500 and €25,000/year | €11,500 plus 0.05‰ listing fee; €5,000/year | For bonds: study €4,000-20,000, listing €2,000-20,000, maintenance from €2,000/year | No public fee: ERIR, advisory and platform are quoted case by case |
| Liquidity | Order book; optional liquidity provider | Mandatory liquidity contract | Voluntary liquidity contract | Securities for qualified investors only | No trading venue; ERIR registers the transfers |
| Timing | No regulatory deadline; its website mentions two months | The board decides within a maximum of three months | Maximum of three months | The circular does not set a deadline | Median of 78 days between the Commercial Registry and the entry with the CNMV (23 issuances) |
Sources for the table: Portfolio rules and fees published by the CNMV; Circular 2/2026 of BME Growth, Circular 1/2025 of BME Scaleup and Circular 1/2025 on BME MTF Equity fees; Circulars 1/2025 and 1/2022 of the MARF; Law 6/2023 and the Companies Act. The prospectus exemption threshold is €12 million in the EU over twelve months from 5 June 2026 (Regulation (EU) 2017/1129, art. 3.2, as amended by Regulation (EU) 2024/2809).
How to decide
- You want capital with a broad shareholder base: BME Growth requires a minimum free float and a liquidity contract, so it suits companies that already have dispersed shareholders. We explain it in the former MAB, now BME Growth.
- You are looking for a first step without minimum free float: compare BME Scaleup with Portfolio. Scaleup costs less in fees; Portfolio integrates custody and DCV.
- You need debt from institutional investors: the MARF is designed for that, with a minimum denomination of €100,000.
- You have few identified investors and do not need to list: a tokenized private issuance avoids market fees, although it does not provide a secondary market. The ERIR registry in Spain shows what the 23 registered issuances have been like so far.
If you choose the last option, HokenFi is software for preparing tokenized issuances under Law 6/2023; the full process is in the guide to issuing a security token in Spain.
Common mistakes
- Compare only the admission fee. In Portfolio, custody and the annual fee matter; in BME, the registered adviser and the liquidity contract.
- Assuming that an MTF provides liquidity. The market offers the trading system; liquidity depends on there being buyers and sellers.
- Taking tokenized securities to Portfolio. Its rules require book-entry records, and Law 6/2023 only allows DLT securities on a trading venue within the European Pilot Regime (art. 6.2).
- Planning an exit with an S.L. Interests in a limited liability company are not securities (art. 92.2 of the Companies Act): to list shares you need an S.A.
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
Is Portfolio Stock Exchange a stock exchange or a regulated market?
No. It is a multilateral trading facility, a MiFID II category distinct from regulated markets such as the Madrid Stock Exchange. The CNMV approved its internal rules in June 2022 and includes it in its list of market infrastructures. Its governing company is a securities firm registered with the CNMV, which supervises its activity.
What minimum size does my company need to list on Portfolio?
Its rulebook does not set a minimum market capitalization or a minimum percentage of shares in public hands. It does require a board of directors, audited accounts for two financial years or a pro forma balance sheet if the company is new, one year of working capital and an adviser approved by the operator. To issue shares, the company must be a public limited company.
How much does it cost to list shares on Portfolio?
The 2023 fee prospectus registered with the CNMV sets a maximum of €5,000 for the application and 0,125% of market capitalization for first-year trading, capped at €300,000. After that there are fixed maintenance and custody fees and a proportional registration fee. These are maximums published in 2023, excluding VAT and advisor fees.
How does Portfolio differ from BME Growth?
BME Growth requires a registered advisor, a liquidity contract and that shareholders with less than 5% hold at least €2 million. Portfolio does not require minimum free float or a liquidity provider, but it does require an approved law firm or advisor. Its fees include custody and registration with the depositary, which is why its annual fee is higher than BME's.
Can I trade blockchain-issued securities on Portfolio?
As they stand, no: its published rulebook requires securities to be represented by book entries. On a trading venue, Law 6/2023 only allows DLT securities within the European Pilot Regime. In Spain, the CNMV has authorized two systems of this type: Securitize, licensed since November 2025, and Bit2Me STX, authorized on October 28, 2026.
