Quick answer
The financial sandbox is the controlled testing space created by Ley 7/2020. It allows innovative projects to be trialled, including issuances of tokenised securities, under the oversight of the CNMV, the Bank of Spain or the DGSFP, with safeguards for participants and without yet needing definitive authorisation.
For an issuer studying how to tokenise securities, the sandbox solves a specific problem: testing the model with the supervisor inside, before committing the investment of a full authorisation. Ley 7/2020, of 13 November, on the digital transformation of the financial system provides the legal basis for this regime and defines who may enter, how and with what guarantees (Ley 7/2020 on the digital transformation of the financial system).
What the controlled testing space is
The sandbox is a defined environment where a promoter trials a technology-based innovation applicable to the financial system, under the monitoring of the competent supervisor and in accordance with a protocol agreed case by case. It is neither a licence nor a seal of approval: it is a test bench with rules, limits and a defined duration. Participation does not prejudge whether the project will subsequently obtain the authorisation it needs to operate in the market (Ley 7/2020 on the digital transformation of the financial system).
Governance is multi-supervisor. Depending on the scope of the project, the CNMV intervenes, competent in securities markets and therefore in the tokenisation of financial instruments, together with the Bank of Spain or the Directorate-General for Insurance and Pension Funds. The General Secretariat of the Treasury coordinates the administrative entry procedure. This architecture explains why a single programme can host payments, insurance or securities-market projects with different supervisors.
Which projects fit
To gain entry, the project must provide a technology-based innovation applicable to the financial system and be sufficiently advanced: at least a minimum viable product that can be tested. It must also offer identifiable added value, for example in regulatory compliance, efficiency, protection of the financial-services user or improvement of supervisory tools. A concept-stage idea, with no development, does not meet the maturity threshold required (Ley 7/2020 on the digital transformation of the financial system).
How to apply
Entry is organised through calls. The programme runs in cohorts, with two half-yearly calls each year, usually in March and September. Each call opens a submission window through the electronic office of the General Secretariat of the Treasury, where the promoter files a standardised application accompanied by a project justification report.
The report is the decisive piece. It must describe the innovation, its degree of development, the risks to participants and how they are mitigated, and the added value pursued. The competent supervisors, the CNMV for securities projects, assess the applications and issue a preliminary evaluation; those that pass it move to the next phase. The selectivity is real: in the programme's first call, 67 applications were received and 18 projects obtained a favourable preliminary evaluation, distributed among the three supervisors.
Phases of the process
The journey through the sandbox is organised into three successive phases: entry, testing and exit.
Entry
This comprises the submission of the application and the report, the assessment by the competent supervisor and the decision admitting or rejecting the project. It is the phase that filters which initiatives proceed to testing.
Testing and protocol
Once the project is admitted, promoter and supervisor negotiate the testing protocol: the document that sets the scope of the trial, its duration, the volume and participant limits, the safeguards and the monitoring indicators. The protocol is the heart of the sandbox, because it translates the legal guarantees into concrete operating conditions for each case. The protocol must be signed within a maximum of three months from the entry decision. Only once it is signed do the real tests begin.
Exit
When the testing period ends, a results report is prepared and submitted to the supervisor. With it, the promoter may apply for authorisation to operate, adjust the model or abandon the project. Exit is not automatically a licence: it is the orderly closure of the trial and the documentary basis for the next steps before the supervisor.
Safeguards for participants
The regime requires that those taking part in the tests receive clear information that they are in a trial environment, give their consent and are protected against possible harm, with guarantee mechanisms set out in the protocol. These precautions are what allow testing in real conditions without passing on to the user the risks inherent to an experimental phase (Ley 7/2020 on the digital transformation of the financial system).
Tokenisation projects that have taken part
The Spanish sandbox has been a test bench for several securities-tokenisation initiatives supervised by the CNMV. The most advanced case is that of Bit2Me, whose security-token market project, Bit2Me STX, proposes an infrastructure where financial instruments are issued, placed, traded and settled on blockchain. In November 2024 it began testing with the issuance of a tokenised corporate bond by Valorix, for a total amount of 145,000 euros, with a nominal value of 1,000 euros per bond, a three-month maturity and a 3.25% coupon; the trial covered the full lifecycle of the security: issuance, trading and settlement.
Other financial institutions have used the sandbox to trial the tokenisation of investment products, such as a tokenised fund by BBVA. The common denominator of these projects is that the asset trialled is a financial instrument: that is why the competent supervisor is the CNMV and the underlying framework is that of the securities market, not that of MiCA (MiCA (Regulation (EU) 2023/1114), Art. 2(4); MiFID II (Directive 2014/65/EU)).
What it offers an issuer
For anyone planning a tokenised issuance, the sandbox offers three tangible advantages. The first is early dialogue with the CNMV: the supervisor gets to know the model while it can still be adjusted, which reduces the risk of a later rejection for design flaws. The second is the possibility of testing with real clients within a controlled perimeter, validating that the technical infrastructure and the legal flow work end to end. The third is documentation: the protocol and the results report build a solid file for the definitive authorisation application.
The sandbox also connects with the rest of the framework. What is trialled relies on the representation of securities through DLT and on the figure of the ERIR under Ley 6/2023, and the trading of tokenised securities at European scale is projected onto the DLT Pilot Regime (Ley 6/2023 (LMVSI); DLT Pilot Regime (Regulation (EU) 2022/858)).
Frequently asked questions
Does taking part in the sandbox amount to obtaining a licence?
No. The sandbox is a testing environment. Passing the trial does not grant authorisation to operate; it provides results and documentation with which the promoter can subsequently apply to the supervisor (Ley 7/2020 on the digital transformation of the financial system).
When can I submit a project?
Entry opens through periodic calls, with two half-yearly cohorts each year, usually in March and September, through the General Secretariat of the Treasury.
Who supervises a securities-tokenisation project?
The CNMV, as these are financial instruments. The Bank of Spain and the DGSFP take on the projects in their respective fields (MiFID II (Directive 2014/65/EU)).
How long does it take for the testing phase to begin?
After the entry decision, promoter and supervisor have a maximum of three months to sign the testing protocol; the tests begin once it is signed.
What this means for you
If your tokenisation project is mature enough to be tested, the sandbox is the route to do so with the CNMV inside and with bounded risk. It is advisable to prepare the report as if it were already the embryo of the authorisation file: a precise technical description, a risk and safeguards analysis, and a clear legal classification of the asset as a financial instrument. Aligning the trial from the outset with representation through DLT and the figure of the ERIR saves work when, once exit is passed, the time comes to apply for authorisation to operate.
This content is for general information and educational purposes only. It is not legal, tax or investment advice and does not replace consultation with a qualified professional. Regulation on tokenisation and crypto-assets evolves; always check the version in force of the rules cited in the BOE (boe.es) and EUR-Lex (eur-lex.europa.eu).
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