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TOOL · SECURITY TOKEN OFFERING

Estimate the framework and phases of your STO

Estimator · Security Token Offering

Requirements, phases and timeline of your STO

Answer 4 questions about your tokenized issuance and get the applicable regulatory framework, the requirements, the phases with indicative timelines and the cost components. The exact figure is set in a tailored quote.

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STO cost: what drives the cost of issuing a security token in Spain

There is no single price: the cost of issuing a security token in Spain depends on four components (legal and regulatory, ERIR and custody, technology and audit, compliance and operations), a fifth one if you want a secondary market, and on whether the offering needs a prospectus. The estimator gives no figure. From four answers, it shows the applicable framework, the requirements and phases of your issuance and the cost components to budget for; the amount is set in a tailored quote.

How the estimator works

  • The asset. If you pick shares, debt or a fund, it treats the token as a financial instrument: MiFID II, Spain's Law 6/2023 (LMVSI) with registration through an ERIR, and MiCA excluded (Art. 2(4)(a) of Regulation (EU) 2023/1114). For real estate or another asset, it leaves the classification open: it depends on the right the token carries.
  • The amount. It offers three ranges: under €1M, €1M to €8M and over €8M. It flags a "likely prospectus" only above €8M, when the offering reaches retail investors and the asset is not a fund. It notes that Regulation (EU) 2017/1129 now exempts offerings below €12M (Art. 3(2)(b), applicable since June 5, 2026), while Art. 35.2.b of Law 6/2023 still says €8M.
  • The investors. An offering only to qualified investors needs no prospectus, whatever its size (Art. 1(4)(a) of Regulation 2017/1129). If you include retail investors, it adds investor protection measures and, when the offering is exempt from the prospectus, the requirement in Art. 36.1 of Law 6/2023: if it is advertised to the public, a firm authorized to provide investment services must be involved.
  • The secondary market. If you want one, it adds the DLT Pilot Regime (Regulation (EU) 2022/858) and one more cost component, and warns that admitting the tokens to a regulated market requires a prospectus (Art. 3(3) of Regulation 2017/1129).

The result lists the baseline requirements (issuance document, ERIR, custody and AML/KYC under Spain's Law 10/2010), six phases with qualitative timelines and the cost components, without amounts.

What it does not do

It is for guidance only and is not legal advice. It does not calculate amounts or timelines in days. It does not decide whether a real estate token is a financial instrument; the MiCA or MiFID II classifier covers that. Nor can it anticipate whether the CNMV, Spain's securities regulator, will require a prospectus due to the complexity of the issuer or the instrument (Art. 36.3 of Law 6/2023).

Further reading

Frequently asked questions

Why doesn't the estimator give a fixed price?

Because each component depends on the scope: an offering with a CNMV-approved prospectus does not cost the same as an exempt one, and one with a secondary market does not cost the same as one without. The amount is set once the project is scoped.

Do I need a prospectus to issue a security token in Spain?

Not necessarily. You are exempt if the offering is addressed only to qualified investors (Art. 1(4)(a) of Regulation (EU) 2017/1129) or if it is not subject to notification under Art. 25 (passporting to other Member States) and its total amount in the EU is below €12M over 12 months (Art. 3(2)). Law 6/2023 still sets €8M (Art. 35.2.b), so between those two figures you should confirm with the CNMV.

What is an ERIR and why does it always appear?

It is the entity that administers the registration and record of the securities on the distributed ledger. Art. 8.4 of Law 6/2023 requires the issuer to appoint it in the issuance document, and it must be an entity authorized for the activity in Art. 126(a) of that law.

Official sources

Framework verified as of October 14, 2026. For a quote on your issuance, talk to us.