La CNMV inicia la consulta del proyecto de Circular para ampliar el procedimiento de reclamaciones a las presentadas contra proveedores de servicios de criptoactivos y de financiación participativa

The consultation runs until 16 November 2026, and comments will normally be published. While this is a Spanish initiative, it reflects a broader European trend of bringing crypto and crowdfunding into mainstream investor-protection frameworks, so firms with Spanish clients or EU cross-border operations should monitor it closely. For compliance teams, the most immediate impact is scope: complaint handling will no longer be limited to traditional investment services.

Crypto and crowdfunding firms should begin gap analysis against CNMV expectations for receiving, investigating, responding to and reporting complaints. Traditional investment firms face lighter but still relevant changes, including revised forms, updated organisational references and modernised language. Actionable next steps: 1) Confirm whether your firm falls in scope, directly or via passporting.

2) Review complaints and enquiries policies, templates, escalation routes, recordkeeping and MI for crypto/crowdfunding exposure. 3) Assess training and resourcing needs, especially for Spanish-language and vulnerable-investor handling. 4) Consider submitting consultation comments by 16 November 2026 if the proposals create operational challenges.

5) Track the final Circular for implementation timing. Business opportunities include using robust complaint handling as a trust differentiator in crypto and crowdfunding, and deploying RegTech to standardise intake, workflow and reporting. Risks include compliance gaps, inconsistent customer outcomes and supervisory attention if procedures are not updated promptly.

Overall impact is moderate: procedural rather than prudential, but strategically important for investor-protection and crypto-sector compliance.