In 2025, Spanish regulators have reinforced their control plans in the financial markets (CNMV) and telecommunications/digital services (CNMC).
For companies, particularly foreign entities, this means reviewing whether they are required to have legal or technical representation before each authority, depending on their activity. For instance, this may include investment services, marketing of foreign UCITS, notification as a telecommunications operator, or DSA compliance when there is no establishment within the EU.
CNMV: Greater Control over Financial Operators and Representatives
In its 2025 Activity Plan, presented on 26 February 2025, the CNMV set out 44 specific objectives that have guided its work throughout the year.
These objectives are organized into three strategic areas: effective supervision to protect investors, capital market development, and institutional transformation.
Furthermore, the plan strengthens areas that were not previously prioritized. This marks a clear shift in approach towards crypto-assets, sustainable finance, cybersecurity, artificial intelligence, and improvement of internal and regulatory processes.
As a result, some of these goals involve stricter requirements in several aspects, such as greater transparency, more frequent reporting obligations, and closer supervision of financial intermediaries.
Why does this affect legal representation?
The legal representative acts as the direct contact person before the CNMV, receiving notifications and handling documentation required by the supervisor.
Therefore, they must be equipped with the necessary technical expertise to respond appropriately.
In 2025, this role becomes a key element in ensuring regulatory compliance and avoiding penalties for communication failures or delays in submission.
If you would like to learn more, you can read our full article on the blog: Representation before the CNMV for Foreign Companies in Spain.
CNMC: notification/registration as an operator and representation before the electronic headquarters
Any party intending to supply networks or provide electronic communications services in Spain must notify the CNMC before commencing operations for registration in the CNMC Operators Register.
At the same time, faced with rapid technological progress, the CNMC has incorporated advanced tools. For example, big data and artificial intelligence to detect anti-competitive behaviors.
Relevance for Legal Representation
In electronic procedures, the representation of the legal entity must be duly accredited. When this is not the case, and neither the entity nor its representative has a registered address in Spain, the CNMC requires the appointment of a natural person in Spain for notification purposes.
Additionally, electronic procedures and registrations through the CNMC’s online platform require formal compliance, updated documentation, and smooth communication with the regulator.
The absence of valid representation, or the incorrect submission of powers of attorney, may lead to negative consequences. This could be financial penalties or license suspension.
To explore this topic further, we recommend reading our blog article: What is a Representative before the CNMC and what functions does he/she perform?
Coordination with Tax Representation
Although this alert focuses on the CNMV and CNMC, it is essential to note that legal representation before these authorities must be aligned with tax representation before the Spanish Tax Agency (AEAT).
This is particularly regarding invoicing submissions and international tax obligations.
Conclusion: 2025, the Year of Control and Compliance
Legal and tax representation before the CNMV and CNMC is a critical element for operating in Spain securely and in full compliance with regulations.
Consequently, foreign companies operating in Spain must adapt to an environment of increased supervision and transparency. It is no longer sufficient to simply appoint a representative; that representative must be qualified, duly authorized, and capable.
At LEIALTA, we offer comprehensive support to appoint, review, and maintain legal and tax representation before the CNMV, CNMC, and AEAT in Spain, ensuring regulatory soundness and operational reliability.
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