The MARF (Alternative Fixed Income Market) is BME's multilateral trading facility in which mid-sized companies list promissory notes and bonds aimed at qualified investors. It has been operating since October 2013. To issue, you must appoint a registered advisor, provide audited accounts and a rating or solvency report, and draft a base information document.
What is MARF and how does it work
The MARF is a multilateral trading facility (MTF), not a regulated market, under the terms of Articles 42 and 68 of the Ley 6/2023. It is managed by BME through AIAF, its corporate debt market, and is supervised by the CNMV. It was created so that companies heavily dependent on bank credit could finance themselves in the market without assuming the requirements of an official market.
It is aimed at qualified investors. That is why the securities usually have a unit face value of 100,000 euros and admission does not require a prospectus approved by the CNMV: the issuer submits a base information document whose content the market does not verify. The securities are represented by book entries registered with Iberclear.
The MARF admits promissory note programs, with terms of between three business days and 24 months; medium- and long-term bonds and debentures; project bonds; securitizations; and green, social or sustainable issuances. If you want to list shares, BME's market for mid-sized companies is another: BME Growth, formerly the MAB.
Requirements for issuing promissory notes or bonds
| Requirement | What it involves |
|---|---|
| Legal form | The usual form is a public limited company, although limited liability companies have also issued. |
| Registered advisor | Mandatory. An entity admitted as a registered advisor of the MARF that supports the issuer in the admission and in compliance with its obligations. |
| Audited accounts | Audited annual accounts, in practice for the last two financial years. |
| Rating or solvency report | Issued by an agency registered with ESMA. Many promissory note programs rely on a solvency report on the issuer, without rating the promissory notes. |
| Base information document | It is required by Circular 1/2025, of 16 June, on the admission and exclusion of securities on the MARF. |
| Paying agent and placement agents | An entity that pays interest and principal, and collaborating entities that place the securities. |
| Ongoing disclosure | Annual accounts and publication of inside information and other relevant information on the market's website. |
How a promissory note programme works
It is the most common entry point. The issuer sets a maximum outstanding balance and, for one year from the registration of the base document, issues promissory notes when it needs them, with maturities that match its cash flow. The base documents published in 2025 show maximum outstanding balances of between 50 and 200 million euros. According to a study published by BME in 2021, setting up an issuance usually takes around one month, and most issuers repeat after the first.
Costs: what you pay
There is no single fee. The total cost is the sum of items that depend on the issuer and the size of the issuance:
- Registered Adviser and law firm: base document, contracts and support.
- Rating or solvency report: initial issuance and annual monitoring.
- BME fees: review of documentation and registration of each issuance, according to its fee circular.
- Paying agent, Iberclear and collaborating entities: payment, registration and placement fees.
- Audit and internal team: to comply with ongoing disclosure.
First-time issuances tend to be more expensive; when investors already know the issuer, the cost falls (BME, 2021). Ask for a fixed quote for each line item and compare it with the cost of bank loan at the same term before deciding.
Does the Listing Act affect you?
Not much. Since MARF targets qualified investors, its issuances were already outside the prospectus requirement of Regulation (EU) 2017/1129. The exemption of up to 12 million euros in force since 5 June 2026 matters above all to anyone who wants to offer securities to the public, including retail investors, without a prospectus. We explain it in what the CNMV prospectus is.
MARF or tokenized issuance
Both routes finance debt of mid-sized companies, but they start from different assumptions.
| Aspect | MARF | Tokenized issuance |
|---|---|---|
| Investors | Qualified investors; usual denomination of 100,000 € | Qualified investors and, through an authorized entity and with an exemption or prospectus, also retail investors |
| Entry requirements | Registered Adviser, audited accounts, rating or solvency report | Issuance document, ERIR and investor KYC; rating is not mandatory |
| Registry | Book entries at Iberclear | Distributed register maintained by an ERIR (art. 8 of Ley 6/2023 and RD 814/2023) |
| Reasonable amount | Programmes of tens of millions | Also medium amounts |
| Visibility | Public: relevant information on the market's website | Private, unless disclosed by the issuer |
| Trading | On the MTF, through market members | Transfer registered in the ERIR; multilateral only on infrastructures of the DLT Pilot Regime |
Decision criteria
The MARF fits if you have audited accounts with a track record, a size that justifies an advisor and a rating, and you are looking for recurring financing from institutional investors: a promissory note program renewed every year serves that purpose. Tokenized issuance fits if the amount is smaller, if you have your own investor base, or if you want to automate payments and registration; the pieces are in tokenized promissory note and tokenized bond for SMEs. They are not mutually exclusive: an issuer can start with a tokenized issuance and turn to the MARF when it gains size, or vice versa. The general process for a debt issuance is in bond issuance.
Not sure whether to choose a promissory note program on the MARF or a tokenized issuance? Take the issuance diagnosis (2 min) or request a proposal.
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 the MARF?
The Mercado Alternativo de Renta Fija is a multilateral trading facility managed by BME, operational since October 2013, in which medium-sized companies incorporate promissory notes, bonds, project bonds, and securitizations aimed at qualified investors. It is not a regulated market: incorporation requires a base information document, a registered advisor, and a rating or solvency report, but not a prospectus approved by the CNMV.
What requirements does the MARF set for issuing promissory notes?
At a general level: appoint a MARF registered advisor, provide audited annual accounts (in practice, for the last two fiscal years), a rating or solvency report from an agency registered with ESMA, and a base information document in accordance with Circular 1/2025. Promissory notes usually have a denomination of 100,000 euros and terms of between three business days and 24 months.
Can retail investors invest in the MARF?
As a general rule, no. The MARF is aimed at qualified investors, and issuance documents usually expressly exclude sales to retail investors in the European Economic Area. The usual unit denomination of 100,000 euros reflects that approach. An individual who wants exposure to that debt will do so, where applicable, indirectly, for example through funds.
What is the difference between the MARF and BME Growth?
Both are BME multilateral trading facilities for medium-sized companies, but they trade different instruments. The MARF is for fixed income: promissory notes, bonds, and securitizations for qualified investors. BME Growth, formerly the MAB, is for equities: shares are listed there, with share distribution requirements and a liquidity provider that the MARF does not require.
