Updated as of November 2026.
As of November 1, 2026, tokenization of securities in Spain relies on Law 6/2023, two royal decrees from 2023 and CNMV supervision. The CNMV register includes a single registered ERIR, URSUS-3 Capital, A.V., S.A., and 23 registered issuances for €93.7 million. The CNMV has also authorized two European Pilot Regime infrastructures: that of Securitize, in November 2025, and that of Bit2Me STX, in October 2026.
This map organizes each actor by role and gives the official source for each row. If you are going to issue tokenized securities, it helps you know who you will have to work with at each step and what role each one has. The method is at the end.
1. Regulator and regulatory framework
| Item | What it does | Source |
|---|---|---|
| CNMV | It supervises tokenized securities and keeps the ERIR register. It is the MiCA authority in Spain, except for Titles III and IV | CNMV, Financial Innovation |
| Law 6/2023 of 17 March | It allows securities to be represented on DLT systems (art. 6), requires an issuance document (art. 7) and an entity responsible for managing the registration and record, the ERIR (art. 8) | BOE-A-2023-7053 |
| Royal Decree 814/2023 | It develops the representation of securities and requires the ERIR to have a contingency plan (art. 5.2) | BOE-A-2023-22764 |
| Royal Decree 815/2023 | Creates in the CNMV the register of ERIRs for each issuance (art. 2.b) | BOE-A-2023-22765 |
| Regulation (EU) 2022/858 | Pilot Regime: DLT trading and settlement infrastructures, applicable from 23 March 2023 | EUR-Lex, CELEX 32022R0858 |
| Regulation (EU) 2023/1114 (MiCA) | Regulates crypto-assets that are not financial instruments (art. 2.4.a). It applies in full from 30 December 2024 (art. 149.2) | EUR-Lex, CELEX 32023R1114 |
| Law 7/2020 of 13 November | Regulates the controlled testing environment, the financial sandbox (art. 1) | BOE-A-2020-14205 |
Criterion: if your token is a transferable security, such as a share or a bond, the rule that applies to you is Law 6/2023, not MiCA.
2. ERIR in the CNMV register
| Entity | Status as of 1-11-2026 | Source |
|---|---|---|
| URSUS-3 CAPITAL, A.V., S.A. | Registered. Its first issuance was recorded on 7 February 2025 | CNMV ERIR Register |
| Bestinver Securities | Announced in the press (22-5-2026), not registered. It does not appear in the CNMV register of ERIRs as of 1-11-2026 | Bolsamanía, 22-5-2026 (press report); CNMV register of ERIRs |
The CNMV page is titled “Entities and infrastructures designated ERIR”, but as of the consultation date it only shows URSUS-3 (CNMV, ERIR register). The Pilot Regime infrastructures are responsible for the registration of the securities they admit to trading (art. 8.5 of Law 6/2023), and they do not appear in that list. We explain what an ERIR does in what an ERIR is.
Criterion: check the ERIR you are going to work with in the CNMV register. A press release is not enough.
3. Registered issuances
Each time an issuer appoints an ERIR for an issuance, the appointment is recorded in an official CNMV register (Royal Decree 815/2023, art. 2.b). As of 31 October 2026, there are 23, all under URSUS-3, for a total amount of €93,685,715. The details of each entry and the CSV are in the ERIR register in Spain.
| Year | Issuances | Bonds | Shares | Amount recorded |
|---|---|---|---|---|
| 2025 | 7 | 6 | 1 | €30,592,416 |
| 2026 (through 31 October) | 16 | 13 | 3 | €63,093,299 |
| Total | 23 | 19 | 4 | €93,685,715 |
By type, bonds total €81,612,900 (87.1% of the amount) and shares total €12,072,815 (12.9%). For shares, the amount may reflect represented capital rather than funds raised. The median issuance is €4.6 million, with a range from €50,000 to €7.99 million, and 12 of the 23 issuers have “SPV” in their name.
Example: if you prepare an issuance of bonds for €5 million through a special purpose vehicle, you are in the most common size and structure in the register. The debt route is detailed in the guide to debt and bond tokenization in Spain.
4. Pilot Regime infrastructures in the EU
ESMA publishes the list of infrastructures authorized under Regulation (EU) 2022/858 (ESMA, list of DLT infrastructures). We add Bit2Me STX at the end: the CNMV authorized it on 28 October 2026 as a DLT-based trading and settlement system, according to its press release of that date, and includes it in its list of market infrastructures. It does not yet appear in the ESMA list consulted.
| Operator | Infrastructure and type | Country and authority | From |
|---|---|---|---|
| CSD Prague | DLT Register, settlement system | Czech Republic, Czech National Bank | 11-10-2024 |
| 21X AG | 21X DLT-TSS, trading and settlement | Germany, BaFin | 3-12-2024 |
| 360X AG | 360X DLT MTF, multilateral system | Germany, BaFin | 29-4-2025 |
| UAB Axiology DLT | Axiology DLT TSS, trading and settlement | Lithuania, Bank of Lithuania | 9-7-2025 |
| LISE SA | LISE DLT TSS, trading and settlement | France, ACPR | 13-10-2025 |
| Securitize Europe Brokerage and Markets, S.V., S.A. | Securitize Europe DLT TSS, trading and settlement | Spain, CNMV | 26-11-2025 |
| Baden-Württembergische Wertpapierbörse GmbH | Seturion, trading and settlement | Germany, BaFin | 16-10-2026 |
| Bit2Me Security Tokens Exchange STX, A.V., S.A. | Bit2MeSTX, trading and settlement (shares and bonds on DLT) | Spain, CNMV | 28-10-2026 (CNMV press release) |
Criterion: a Pilot Regime infrastructure is used to trade and settle securities on DLT. Outside it, issuance and registration still go through an ERIR. The full framework is in the guide to the DLT Pilot Regime.
5. Crowdfunding platforms with tokenized securities
The CNMV register lists 27 crowdfunding service providers (CSPs) as of 1 November 2026. We have only been able to verify on their own website that one works with tokenized crowdfunding.
| PSFP | CNMV Register | What its website says |
|---|---|---|
| Adventurees Capital PFP, S.L. (website aliuscap.com, as Alius Capital) | No. 11, registered on 3-11-2023 | It presents itself as an “authorized European provider of tokenized crowdfunding services” |
The CSP route has a ceiling: Regulation (EU) 2020/1503 does not apply to offers from the same promoter that exceed €5 million over twelve months (Art. 1.2.c).
Criterion: if you publicly advertise a prospectus-exempt offer, Law 6/2023 requires an authorized entity to be involved, unless the placement is made through a CSP (Art. 36).
6. Tokenization technology providers
We describe each company using the words from its own website. A technology provider is not, merely because it is one, an entity registered in the CNMV registers. Below the table we note only the official CNMV registers and lists in which any of them is indeed listed.
| Company | What its website says |
|---|---|
| Allfunds Blockchain | “Software company dedicated to developing solutions for the entire investment funds sector,” with blockchain technology |
| Brickken (Brickken Solutions S.L.) | “Asset tokenization infrastructure for private markets” that unifies “issuance, compliance and lifecycle management” |
| HokenFi (Unknown Gravity S.L.) | “Software to issue financial instruments. We are only technology providers” |
| Metlabs | “Blockchain development company, real-world asset (RWA) tokenization and Web3 consulting for companies” |
| Token City (Token City, S.L.) | “It manages Blockchain digital assets. Its services allow issuing, managing and trading security tokens” |
Where they appear in the CNMV: Allfunds Blockchain and Token City are listed as promoters in the sandbox project list (cohorts 1 and 4, section 7). Token City European Exchange A.V., S.A., whose sole shareholder is Token City, S.L., is registered in the register of investment services companies as a securities agency (No. 334, since 6-2-2026).
Criterion: a technology provider does not replace the ERIR or the authorized entity. Ask each one which registered entities it works with and verify it in the registry.
7. Financial sandbox
The CNMV publishes the status of the projects in the sandbox under Law 7/2020 for which it is the competent authority (CNMV, Financial Innovation). These are the tokenization or DLT securities infrastructure projects:
| Cohort | Promoters | Project | Status |
|---|---|---|---|
| 1.ª | Renta 4 Banco, Renta 4 Gestora, Allfunds Bank, Allfunds Blockchain and Onyze Digital Assets | Issuance and custody of tokenized units of a fund | Completed |
| 1.ª | Sociedad de Bolsas, S.A. | Market Place: tokenized participating loans with the involvement of an investment services company | Completed |
| 1.ª | Sunblock Urban Token S.L. | Realfund: tokenization of a participating loan | Completed |
| 3.ª | Securitize, Inc. | DLT infrastructure to issue and trade MiFID II financial instruments | Completed |
| 4.ª | Allfunds Bank, S.A. | DLT multilateral trading facility for units of UCITS-type collective investment undertakings | In testing |
| 4.ª | Token City S.L. | Token City Exchange: issuance, trading and settlement, especially for SMEs | Completed |
| 5.ª | DEVTEAM, S.L. | Bit2me Security Tokens Exchange (STX), aimed at start-ups | Completed |
We leave out the projects on that list that do not deal with tokenized securities: digital identity, artificial intelligence, peer-to-peer loans and a fund that invests in lending protocols with stablecoins. The summary for issuers is in the guide to the CNMV sandbox.
Criterion: having gone through the sandbox does not amount to an authorization. Law 7/2020 expressly says so (Art. 4.2).
8. Associations
| Entity | What its website says |
|---|---|
| AEFI, Spanish Association of Fintech and Insurtech | Its goal is to create a favorable environment for fintech and insurtech startups and companies in Spain; it is organized into verticals, one of them for digital assets |
| Alastria | Public-private blockchain platform that brings together companies, academia and public administrations |
Method: what is included and where it comes from
- Cut-off date: 1 November 2026. Registered issuances as of 31 October 2026.
- What is included: rules, entities and projects related to the tokenization of transferable securities in Spain, and the infrastructures of the EU-wide Pilot Regime.
- Where each row comes from: CNMV registers (ERIR, issuances, PSFP, investment firms and infrastructures), its list of sandbox projects and its press releases, ESMA, BOE and EUR-Lex lists. Company and association descriptions come from their own websites.
- What is not included: crypto-asset providers under MiCA, investor-facing platforms and announcements not reflected in a register, except announced ERIRs, which we mark as such.
- Neutrality: HokenFi, publisher of this page, appears as one more row. No row is a recommendation or an assessment.
- Review: registers change. Before deciding, always check the official register we cite in each section.
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
How many ERIRs are there in Spain?
According to the official CNMV register consulted on 1 November 2026, only URSUS-3 Capital, A.V., S.A. is registered as an ERIR. Bestinver Securities' authorization was announced by the press on 22 May 2026, but it does not appear registered in that register. The Pilot Regime infrastructures are responsible for registering the securities they admit to trading, although they do not appear in the ERIR list.
Where can tokenized securities be traded in Spain?
On a trading venue, DLT securities can only be traded within the European Pilot Regime (Art. 6.2 of Law 6/2023). In Spain, the CNMV has authorized two infrastructures of this type: that of Securitize Europe Brokerage and Markets, with permission since 26 November 2025, and Bit2Me STX, authorized on 28 October 2026. The authorization alone does not indicate when each one began operating.
How much has been issued in tokenized securities in Spain?
CNMV entries total €93,685,715 across 23 registered issuances between February 2025 and October 2026. Nineteen are bonds and four are shares. For shares, the registered figure may correspond to the capital represented and not to the money actually raised, so it is best read as registered volume.
What is the difference between an ERIR and a tokenization technology platform?
The ERIR is the entity that the issuer appoints to maintain the register of DLT securities, and it must be authorized for the custody and administration of financial instruments (Art. 8.4 of Law 6/2023). Its appointment for each issuance is recorded in an official CNMV register. A technology platform provides the software, but it does not replace the ERIR or the authorized entity required in each case.
Does participating in the CNMV sandbox amount to having a license?
No. Law 7/2020 establishes that entering the controlled testing environment does not grant authorization to carry out a reserved activity. The CNMV publishes the status of each project and, when testing ends, a conclusions report. Any subsequent authorization is a separate procedure and must appear in the corresponding official register, so check it there.
