BME Scaleup is the Bolsas y Mercados Españoles (BME) market for growth-stage companies. It has been operating since 2023 with reduced access requirements: public limited company, board of directors, registered adviser and audited accounts. For an issuer seeking capital, it is a route with a listing. Tokenized issuance is the alternative to raise funds without going to market.
What is BME Scaleup and where does it come from
BME Scaleup is a segment of BME MTF Equity, a multilateral trading facility (MTF) operated by BME. The CNMV authorized it in June 2023 and supervises it like the rest of Spanish MTFs. It is not a regulated market like the stock exchange: it is the entry tier, designed for companies that do not yet fit into BME Growth (BME, official market fact sheet).
The target profile is scaleups with a proven business model and revenue, from any sector. BME also targets family businesses and SOCIMIs that want to list with contained costs. The core decision for the issuer is simple: take on the obligations of a market in exchange for visibility and public valuation.
Admission requirements
The requirements are lighter than those of BME Growth, but they exist and affect the timetable. This table summarizes the main ones.
| Requirement | What BME Scaleup requires |
|---|---|
| Legal form | Public limited company, Spanish or foreign, with fully paid-up capital. |
| Corporate governance | Board of directors in place. |
| Registered advisor | Mandatory on admission and throughout the entire listing. |
| Accounts | Audited annual accounts. |
| Admission document | DIAM (Initial Market Admission Document), prepared with the registered adviser. |
| Liquidity provider | Optional, unlike BME Growth. |
| Free float | With no minimum free float comparable to that of BME Growth. |
| Activity | Product or service already on the market, with revenue. |
The central piece is the registered adviser. It assesses whether the company is ready, prepares the DIAM and then monitors compliance with reporting obligations. Before starting the process, ask two or three advisers for proposals and compare scope and fees.
What the issuer gets and which investor enters
Listing provides market valuation, visibility before customers and financiers, and a liquidity window for shareholders. In exchange, the issuer takes on periodic reporting, annual audit and the recurring cost of the registered adviser. BME targets this market mainly at investors with experience in capital markets. Retail investors can enter, but they are not the main target.
BME Scaleup versus tokenized issuance
The tokenized issuance represents shares, bonds or other instruments through distributed ledger technology. Registration is handled by an ERIR (entity responsible for registration and recording, the digital notary of the registry), a figure required by Spanish regulations (art. 8, Ley 6/2023; RD 814/2023). URSUS-3 Capital A.V. was the first authorized ERIR, in November 2024.
| Criterion | BME Scaleup | Tokenized issuance |
|---|---|---|
| What the issuer gets | Listing on an MTF and public valuation. | Digital register of securities and targeted fundraising, without listing. |
| Amount | No specific regulatory threshold; investor appetite determines it. | Up to 12 M€ in 12 months without a prospectus, if the exemption applies (Regulation (EU) 2017/1129, as amended by the Listing Act). |
| Timelines | Months of preparation: DIAM, audit and registered adviser. | They depend on the offer documentation and the process with the ERIR. |
| Typical investor | Professional and specialized, with occasional retail investors. | Professional or the issuer's own network, depending on how the offer is structured. |
| Recurring costs | Registered adviser, audit and reporting obligations. | Maintenance of the register and general corporate obligations. |
| Liquidity | Organized trading on the market itself. | Recorded transfers; an organized secondary market requires an MTF under the DLT Pilot Regime (Regulation (EU) 2022/858). |
Neither route wins in the abstract. Listing pays for visibility with ongoing obligations. Tokenized issuance pays for discretion with less organized liquidity. The full process for the latter is in how to issue a security token in Spain.
Decision criteria for the issuer
Look at BME Scaleup if you want public valuation, your shareholders ask for a liquidity window and you can sustain the market's annual cost. Look at tokenized issuance if you have a specific round, identified investors and a target of up to 12 M€ in 12 months. The two routes can be chained: first a private tokenized issuance, then the jump to the market. For SMEs with limited financing needs, the starting point is tokenization for SMEs.
Does your capital increase fit better in a market or in a tokenized issuance? Take the issuance diagnostic (2 min) or request a proposal. If you prefer to start by reading, download the 2026 guide.
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 is BME Scaleup?
BME Scaleup is a segment of BME MTF Equity, the multilateral trading facility operated by Bolsas y Mercados Españoles. The CNMV authorized it in 2023 as an entry market for growth companies. It requires a public limited company (sociedad anónima), a board of directors, a registered adviser and audited accounts, with lighter obligations than those of BME Growth.
What requirements does BME Scaleup ask for?
To be a public limited company (sociedad anónima) with fully paid-up capital, have a board of directors, appoint a permanent registered adviser, publish audited annual accounts and submit an Initial Market Access Document (DIAM). The liquidity provider is optional and no minimum free float comparable to BME Growth is required.
How does BME Scaleup differ from a tokenized issuance?
BME Scaleup provides listing on a market and requires ongoing reporting obligations. A tokenized issuance raises capital without listing: the securities are registered in a DLT-based registry managed by an ERIR, under Ley 6/2023 and RD 814/2023. A prospectus may not be required for up to 12 million euros in 12 months, if the exemption applies.
