Guides · Spanish company register

What the Spanish commercial register publishes about a company's directors, what it does not publish about its shareholders, who can see its beneficial owners since the 2022 ruling of the EU Court of Justice, and where to look for each

2026-11-09 · 10 min · guide

By BORMEAPI Engineering

The short answer: in Spain you can find out who runs a company, but usually not who owns it. A director's appointment has to be registered at the commercial registry, the Registro Mercantil, and is then published in the registry's official gazette, the BORME, so anyone can see it. Shareholders are a different matter. An SL keeps its own register of members, and an SA keeps one for its registered shares; the law opens these registers to members, not to the public, and the commercial registry does not record transfers of shares. The one owner the registry always records and the BORME publishes is the sole shareholder of a single-member company.

This guide goes through what each source says, what it leaves out and where to look. It describes how the register works; it is not legal advice.

Who runs a company under Spanish law

A limited company (sociedad limitada, SL) or a public limited company (sociedad anónima, SA) is managed by its governing body (órgano de administración). The law allows four forms of it (Ley de Sociedades de Capital, art. 210):

• a sole director (administrador único);
• several directors, each of whom can act alone (administradores solidarios);
• several directors who act jointly (administradores mancomunados);
• a board of directors (consejo de administración).

In an SA, joint management means two directors acting jointly; with more than two, they must form a board (art. 210.2).

As a rule, directors are appointed by the general meeting of the shareholders (art. 214.1). A director can itself be a company. It must then designate one natural person to carry out the duties of the post, and that designation is registered too (art. 212 bis).

The governing body is not the only group of people who act for a company. A company can grant powers of attorney to people who are not directors (apoderados). General powers have to be registered; powers for a specific act or for court proceedings do not (Reglamento del Registro Mercantil, art. 94.1.5.º). The appointment of auditors and of liquidators, who take over when a company is wound up, is registered as well (art. 94.1.4.º).

What is published about directors

A director's appointment takes effect when the director accepts it. It must then be presented for registration within ten days, stating who was appointed and, for the directors who represent the company, whether they can act alone or must act jointly (Ley de Sociedades de Capital, arts. 214.3 and 215). The registry enters the appointment on the company's sheet, and also the end of each appointment, whatever its cause (Reglamento del Registro Mercantil, art. 94.1.4.º).

The BORME then publishes it. Its first section carries the essential data of each registered act. For an appointment to the governing body or of a holder of general powers of attorney, that is the identity of the people appointed and their post; when an appointment ends, their identity and the post they held (Reglamento, arts. 388.1.9.º, 388.1.10.º and 421). A registered act can be relied on against third parties acting in good faith only from its publication in the BORME (Código de Comercio, art. 21).

In the BORME, an appointment reads like this (an invented example):

EMPRESA EJEMPLO SL. Nombramientos. Adm. Unico: APELLIDO APELLIDO NOMBRE.

The headings to look for are Nombramientos (appointments), Ceses/Dimisiones (terminations and resignations), Revocaciones (revocations) and Reelecciones (re-appointments). The post is abbreviated: Adm. Unico is a sole director, Adm. Solid. one of several directors who can each act alone, Adm. Mancom. one of several who act jointly, Consejero a board member and Apoderado a holder of powers of attorney.

Three things about this data matter before you rely on it.

1. Names, not ID numbers. The registry holds the identity document or tax number of each person or company appointed, but the regulation excludes it from publication in the BORME (Reglamento, art. 421.1). The BORME gives the name only, usually surnames first. Two people with the same name cannot be told apart from the BORME alone.
2. A built-in delay. Between the decision to appoint a director and the BORME notice come the acceptance, the filing, the registrar's review and the publication. The BORME shows what has been registered and published, not what was decided last week.
3. Changes, not a list. The BORME does not print a company's current governing body as a list. It has to be reconstructed from the published changes, and a missed notice or a change not yet published makes the reconstruction wrong.

Where to look up a company's directors

• The registrars' free directory. The registrars' free company directory identifies the people currently authorised to represent the company, either as its governing body or as members of it, and whether they can act alone or must act jointly (Código de Comercio, art. 17.5). It shows the present only, one company at a time.
• The BORME. Registered appointments, re-appointments, terminations and resignations are published in the BORME, free on boe.es. Its electronic edition has been the official one since 2009. The notices are organised by date and province, not by company, so finding one company's history means going through many daily issues.
• A nota simple. The registry's informational extract, ordered online at sede.registradores.org as a nota informativa mercantil, lists who represents the company: its directors and the holders of powers of attorney. A fee applies.
• A registry certificate. When you need formal proof of who the directors are, for a court, a notary or a bank, the certificate (certificación registral) is the only means of formally attesting to what the register records (Código de Comercio, art. 23.1). A fee applies here too.

What is not published: the shareholders

The registry is not a register of shareholders, and the BORME does not publish who holds the shares of a company.

• In an SL, the company itself keeps a register of its members (Libro registro de socios), with the original holders and every later transfer. Any member may examine it, and the governing body keeps it (Ley de Sociedades de Capital, arts. 104 and 105). The law gives no right of access to the public.
• In an SA with registered shares, the company keeps a share register that any shareholder may examine (art. 116).
• Transfers of shares in an SL must be made in a public document (art. 106), which in practice means before a notary. They are not among the acts that must be entered on the company's registry sheet (Reglamento, art. 94).

The founders are a partial exception. The deed of incorporation must state who they are (Ley de Sociedades de Capital, art. 22.1.a), and that deed is registered. But the data the BORME publishes about a new company are its name, address, capital, start of operations, objects, the structure of its governing body and the people who form it, and its auditors (Reglamento, arts. 387 and 421); its founding shareholders are not among them. And even where the founders are known, they may have sold their shares since.

For a listed company whose home Member State is Spain, a separate public source exists: shareholders must notify the company and the CNMV, the securities regulator, when their proportion of the voting rights reaches, exceeds or falls below one of the thresholds set by law, and the CNMV publishes these significant holdings in its register of regulated information (Real Decreto 1362/2007, arts. 23 and 38).

The exception: single-member companies

When one person or company holds all the shares, the company is a single-member company (sociedad unipersonal). Its incorporation as such, the declaration that it has become one, the loss of that status and every change of sole shareholder must be made in a public deed and registered, and the registration must state who the sole shareholder is (Ley de Sociedades de Capital, art. 13.1; Reglamento, arts. 174 and 203). That identity is among the data the BORME publishes (Reglamento, arts. 387.2, 388.2 and 421). The company must also state that it is a single-member company in all its documents, correspondence, order forms and invoices (Ley de Sociedades de Capital, art. 13.2).

In the BORME, look for Declaración de unipersonalidad (declaration of single-member status), Cambio de identidad del socio único (change of sole shareholder), Pérdida del carácter de unipersonalidad (loss of single-member status) and Socio único: followed by the name. The sole shareholder is often another company. Its own owners are then a new question, and the same rules apply to it.

Beneficial owners after the 2022 ruling

A beneficial owner (titular real) is the natural person who ultimately owns or controls a company. Spanish law counts anyone who owns or controls, directly or indirectly, more than 25% of the capital or the voting rights, or who controls the company by other means; listed companies subject to equivalent transparency rules are excepted. When no such person exists, the directors are treated as exercising control; if a director is a company, the natural person it has designated is treated as exercising that control (Ley 10/2010, arts. 4.2.b and 4.2.b bis).

EU law once required this information to be available to any member of the public. On 22 November 2022 the Court of Justice of the European Union declared that requirement invalid, holding that general public access is a serious interference with the rights to private life and to the protection of personal data (joined cases C-37/20 and C-601/20, Luxembourg Business Registers and Sovim).

Spain created its Registro Central de Titularidades Reales at the Ministry of Justice by Real Decreto 609/2023, in force since 19 September 2023. Its preamble cites the 2022 ruling, and its regulation (art. 5) sets three levels of access:

• Authorities that prevent and investigate money laundering, terrorist financing and related offences have free and unrestricted access, including past data and the percentages held.
• Businesses with anti-money-laundering duties under Ley 10/2010, such as banks, see the current information and can obtain a certificate, to meet their duty to identify beneficial owners. Their legitimate interest is presumed when they state a reason for the query that fits the register's purpose.
• Anyone else must demonstrate a legitimate interest, and can then see only, for each current beneficial owner, the name, month and year of birth, country of residence and nationality, and the nature of that beneficial ownership: whether it comes from ownership or from control of the company's management. The regulation presumes a legitimate interest for media and civil-society organisations connected with the prevention of and the fight against money laundering and terrorist financing, and for the company or the beneficial owner the query is about.

Access is electronic, with the requester identified and, outside authorities and those businesses, a request signed electronically (arts. 5.6 and 6). The register also has to take measures against automated searches and the copying of records (art. 5.1).

The register gathers information that other sources already hold, including the commercial registries. In 2018 a form was added to the filing of annual accounts on which companies identify their beneficial owners, where the order requires it (Orden JUS/319/2018). The practical result: there is no public list of who owns a Spanish company. To consult the central register, someone without anti-money-laundering duties must demonstrate a legitimate interest, or fall under one of the presumptions described above.

A checklist

• Who represents the company today? The registrars' free directory, or a nota simple.
• Who was a director in the past, and when did they leave? The BORME, notice by notice.
• Does the company have a sole shareholder, and who is it? The BORME, or a nota simple.
• Who are the other shareholders? Not public. The share register is open to the members; for listed companies, the CNMV publishes significant holdings.
• Who is the beneficial owner? The Registro Central de Titularidades Reales, on its access conditions: for anyone without anti-money-laundering duties, that means demonstrating a legitimate interest.
• Formal proof for a court, a notary or a bank? A registry certificate.

How BORMEAPI helps

BORMEAPI reads the company notices the BORME has published since 2009 and turns each one into an event of the company it concerns. Each event keeps the notice's original Spanish text, and each appointment, re-appointment, termination and resignation in it is an act with the role labelled in English (SOLE_DIRECTOR, BOARD_MEMBER, PROXY_HOLDER and so on).

On 8 November 2026, our data held more than 11.4 million records of a name in a role at a company, more than 5.9 million of them current as far as the published acts show. We list current officers for more than 1.9 million active companies, and a sole shareholder for more than 730,000: the last one we read in the BORME for each of them.

What each level gives:

• Company pages, free and without a key: the current directors and officers as derived from the published acts, up to 25 names per role.
• Free key: a company's events of the last seven days, appointments included, and the same for every company with act_type=APPOINTMENTS.
• Basic (€19 a month plus VAT): company snapshots with the current officers and the sole_shareholder; the companies and roles recorded under a person's name; event history for the last 365 days.
• Pro and Risk: the full archive since 2009, the state of a company as of a past date, and the companies that share an officer's name with a given company, now or in the past.

GET /v1/companies/{slug}
GET /v1/companies/{slug}/events?order=desc
GET /v1/events?act_type=APPOINTMENTS&province=MADRID
GET /v1/people/{name}/roles

The people lookup accepts a name in either order, with or without accents, and gives each role with the dates of the first and the last act in which we saw it. Because the BORME prints no ID numbers, a name alone cannot tell two people apart. The response's homonym_warning is true for names of fewer than three words and for partial matches, but a false value does not prove identity either: any match, and any link between companies through a shared name, is a lead to check, not an identification. A few names are masked at the request of the people concerned. Current officers are derived from the published acts, so a change that has not yet been published is not reflected.

None of this replaces the register. BORMEAPI is not a registry, does not hold shareholder registers and has no access to the beneficial ownership register. It reports what the BORME published. When you need a document with legal force, ask the registry for it.

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