Key data
| Regulation | Circular 1/2026, of October 21, from the Bank of Spain, on the Central Credit Information Registry |
|---|---|
| Publication | October 30, 2026 |
| Entry into force | October 30, 2026 |
| Affected parties | Credit entities, payment entities and electronic money entities operating in Spain |
| Category | Business Regulation |
| Year | 2026 |
| Previous threshold | €3,000 (Circular 1/2013 and its 14 amendments) |
| New threshold | €1,000 (applicable from January 2, 2027) |
| Transitional regime | Until January 2, 2027 the limit of €3,000 remains in force |
Financial entities operating in Spain have a deadline: January 2, 2027 to adapt their CIR reporting systems to the new threshold of €1,000. Circular 1/2026 from the Bank of Spain, published on October 30, 2026, not only lowers that threshold, but consolidates all CIR regulations into a single text, replacing Circular 1/2013 and its fourteen amendments accumulated over the years.
The stated objective is to improve legal certainty and regulatory coherence, but the real operational impact is clear: more transactions reported, more reporting burden and information systems to review before the end of 2026.
What does this regulation establish?
Circular 1/2026 consolidates all regulations of the Central Credit Information Registry (CIR) into a single text, the Bank of Spain's register where financial entities report the credit risks of their clients. Until now, that regulation was scattered across Circular 1/2013 and its fourteen subsequent amendments, which generated legal uncertainty. The new circular unifies everything.
The specific changes it introduces are as follows:
| Aspect | Previous situation | New situation (Circular 1/2026) |
|---|---|---|
| Individual reporting threshold | €3,000 | €1,000 (from January 2, 2027) |
| Transitional regime | Not applicable | Until January 2, 2027 the limit remains at €3,000 |
| Entities in free provision of services | General transaction reporting | Will only report transactions with holders resident in Spain |
| Foreign branches with local legal restrictions | Sworn statement | Justifying statement (sworn statement is eliminated) |
| Pension and salary advances | General reporting | Only reported when they have the nature of a loan |
| Data module submission deadlines | Fixed deadlines | Greater flexibility in submission deadlines for certain modules to the Bank of Spain |
| Reference regulatory text | Circular 1/2013 + 14 amendments | Circular 1/2026 (single consolidated text) |
Economic and operational impact
The most relevant change from an operational perspective is the reduction of the reporting threshold. Moving from €3,000 to €1,000 means that entities will have to report all risk transactions exceeding that amount, which can triple or quadruple the number of records to report depending on the profile of the credit portfolio.
This has direct consequences in three areas:
- Information systems: The data extraction and submission engines to the CIR must be reconfigured to capture transactions from €1,000, not from €3,000.
- Compliance workload: A larger volume of records means more reviews, more reconciliations and more potential incidents to manage.
- Advance management: Pension and salary advances are no longer automatically reported; they are only reported when they have the nature of a loan, which requires more precise internal classification.
On the positive side, greater flexibility in submission deadlines for certain data modules can ease operational pressure during period closings. And the elimination of the sworn statement for foreign branches with local legal restrictions simplifies a procedure that generated friction.
Who does it affect?
- Credit entities operating in Spain (banks, savings banks, credit cooperatives, credit financial establishments).
- Payment entities operating in Spain.
- Electronic money entities operating in Spain.
- Entities in free provision of services with transactions with holders resident in Spain (will only report the latter).
- Foreign branches of Spanish entities that cannot report data due to local legal restrictions.
It does not directly affect non-financial companies or individuals, although the latter may see how more of their credit transactions are recorded in the CIR from January 2027 onwards.
Practical example
A payment entity that currently manages a portfolio of microloans and consumer loans with average amounts between €1,500 and €2,500 did not report any of those transactions to the CIR under the €3,000 threshold. With the entry into force of the new €1,000 threshold on January 2, 2027, all those transactions will become reportable.
If that entity has, for example, 10,000 active transactions in that range of amounts, it will have to adapt its systems to generate and send those additional records to the Bank of Spain. The transitional period until January 2, 2027 exists precisely to provide margin for this technical adaptation, but it is not a long period: less than three months remain from the publication of the circular.
On the other hand, if that same entity granted salary advances to its customers and reported them routinely, from now on it will only have to report them when those advances have the nature of a loan, which can reduce part of the reporting volume in that specific segment.
What should companies do now?
- Review CIR reporting systems to identify which transactions currently fall below €3,000 but exceed €1,000, and how many there are. This gives the real dimension of the impact.
- Plan technological adaptation before January 2, 2027: data extraction, transformation and submission engines must be reconfigured for the new threshold.
- Review the classification of pension and salary advances to determine which have the nature of a loan and are therefore still reportable, and which are not.
- Update internal compliance procedures to reflect the new single regulatory reference (Circular 1/2026), replacing any reference to Circular 1/2013 or its amendments.
- Verify the treatment of foreign branches with local legal restrictions: replace the sworn statement with the new justifying statement.
- Take advantage of greater flexibility in deadlines for submission of certain modules to optimize period closing processes and reduce operational pressure.
Frequently asked questions
When does the new €1,000 threshold in the CIR come into force?
The new individual reporting threshold of €1,000 is not immediate. Circular 1/2026 establishes a transitional regime that maintains the current limit of €3,000 until January 2, 2027. From that date, all transactions exceeding €1,000 must be reported individually to the CIR.
What regulation does Circular 1/2026 from the Bank of Spain replace?
Circular 1/2026 replaces Circular 1/2013 from the Bank of Spain and its fourteen subsequent amendments. The objective is to consolidate all Central Credit Information Registry regulations into a single text to improve legal certainty.
Do entities in free provision of services have to report all their transactions to the CIR?
No. According to Circular 1/2026, entities in free provision of services will only report transactions whose holders are resident in Spain. Transactions with non-resident holders are excluded from the reporting obligation.
Are salary and pension advances still reported in the CIR?
Only partially. From Circular 1/2026 onwards, pension and salary advances will only be reported when they have the nature of a loan. Advances that do not have that nature are excluded from the reporting obligation.
What happens with the sworn statement from foreign branches that cannot report data?
Circular 1/2026 eliminates the sworn statement that foreign branches had to submit when they could not report data due to local legal restrictions. Instead, they must submit a justifying statement, a less formal procedure and more suited to the operational reality of those branches.
Official source
Consult complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-22720
