The Royal Decree Law No. 11/2018 has recently reformed Law 10/2018 of 28 April on the Prevention of Money Laundering and the Financing of Terrorism.

An additional provision now requires all-natural persons and legal entities to register in the commercial register in case they provide one or more of the following services (as provided for in Article 2.1.o of Law 10/2018 of 28 April on the prevention of money laundering and the financing of terrorism):

  • Constitution of companies or other legal entities
  • Performing managerial functions
  • Member of the Board of Directors
  • non- counselor secretary of boards
  • External advice to companies
  • Partners in a foundation or similar positions
  • trusteeship
  • Shareholder for third parties
  • Provision of postal addresses, company headquarters, address for notifications of authorities


The Royal Decree 11/2018 provides with a legislative vacancy by 3 September 2019 (see Article 4 of the Additional Provision).

In addition to this obligation, a document must also be attached when submitting the annual accounts to the company register which shall contain, among others: the number of transactions made, the type of service provided, the volume of invoices, etc.

The non-registration of the above mentioned information in the commercial register until 3rd of September 2019 may constitute a minor infringement of Article 53, which may result in a fine of up to € 60,000 (Article 58).

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