Marketing for financial advisers: what the CNMV allows on your website

A financial adviser can market themselves on their website, on Google and on social media if they are registered with the CNMV, Spain’s securities regulator, or are an agent of an entity that is. Their advertising cannot promise returns and must show the risks in a font size at least equal to the predominant one. And they can only call themselves “independent” if they analyse a broad range of products and do not keep payments from third parties.

Below you will find who is who, a table of 34 phrases and pieces with their verdict and their rule, and the mandatory details with their article. Then the page map, the form and what is worth measuring. The rules were checked in the BOE (Spain’s Official State Gazette), in EUR-Lex and on the CNMV website on 2 October 2026. Where we are interpreting the rules, we mark it as cautious approach; where we are describing our own method, as our approach.

Your legal status, not your job title, decides what your website can say

The law does not regulate a profession called “financial adviser”. It regulates a service, investment advice, and who can provide it (Law 6/2023, art. 125.1.g). The CNMV describes it as giving personalised recommendations to a client about transactions in financial instruments (list of financial advisory firms, EAF).

In the table, LMVSI is Law 6/2023 (Ley de los Mercados de Valores y de los Servicios de Inversión) and RD 813 is Royal Decree 813/2023 (Real Decreto 813/2023) on investment firms.

If you are on the payroll of a bank or a broker (agencia de valores), you are not an agent: the rule excludes employees (RD 813 art. 14.2.a). Cautious approach: what you publish about their products may be advertising by your entity, which must have a marketing communications policy (CNMV Circular 2/2020, rule 6). Check your LinkedIn posts about products with your entity before publishing them.

Competitors with their own registration are few in Castellón and Valencia. As of 2 October 2026, the CNMV lists 93 EAFs and 60 EAFNs across Spain. Going by the postcode of their registered office, 6 EAFs and 3 EAFNs are in the Province of Valencia. In the Province of Castellón there are no EAFs and there is 1 EAFN. This is our own count from those 2 lists.

Without registration you cannot win clients, whatever you call yourself

Only authorised entities can market investment services and win clients, either themselves or through their agents (LMVSI art. 129.1). That reservation requires habitual activity, and the activity is habitual when it comes with advertising (RD 813 art. 8). Cautious approach: a website that offers investment advice is already one of those advertising activities.

The acronyms have their own protection. “Empresa de Asesoramiento Financiero”, “EAF” and “EAFN” are reserved for registered firms, as is any name that could cause confusion (LMVSI art. 129.2 and 129.3). If the CNMV requires you to stop and you are still using them 30 days later, it can impose coercive fines of up to €500,000, which can be repeated (art. 129.4; RD 813 art. 9.1). Providing a reserved service without authorisation is also a very serious infringement (LMVSI art. 289).

And plain “financial adviser” (asesor financiero)? We have not found a CNMV position on that expression. What decides is the activity: if you offer personalised investment recommendations, you need authorisation, whatever you call it. Cautious approach: if you are an agent, a lawyer or a tax adviser, write your actual status next to those words.

8 changes from 2025 and 2026 that affect your website and your ads

8 new developments affect an adviser’s website or advertising. Almost all of them reappear in the table and in the checklist.

• Influencers (December 2025). The CNMV added to its questions and answers on MiFID II when a paid collaborator is winning clients (question 22.2, press release).
• Reviews on your website (December 2025). They must refer to services used in the 30 calendar days before the review (Consumer Protection Law (Ley de Consumidores), art. 20.4).
• Personalised offers (December 2025). If an automated system personalises offers of financial products, you must disclose the parameters and the data sources (Unfair Competition Law (Ley de Competencia Desleal), art. 27.9).
• Customer service (December 2025). Investment firms must resolve complaints within one month and say so on their website (Law 44/2002, art. 29.5). Previously the limit was 2 months, under Order ECO/734/2004, whose article 10 was repealed by Law 10/2025. That law gives 12 months to adapt, and it is not clear whether that period applies to this time limit. Cautious approach: have your website up to date before 28 December 2026.
• Guide for finfluencers (May 2026). The CNMV explains when a video or a post is an investment recommendation and what it must include (press release).
• Bank advertising (May 2026). In 2025 the Supreme Court annulled part of Order EHA/1718/2010 over a procedural defect. Order ECM/531/2026 reintroduced it. It affects anyone advertising revolving credit.
• Simulators (June 2026). The CNMV clarified which methodology to use for future return scenarios in any simulation, with negative and positive scenarios (question 7.1).
• Cuenta de Ahorro e Inversión Financia Europa (September 2026). Royal Decree-Law 26/2026 adds this savings and investment account to Law 6/2023. Its name is reserved, and only credit institutions, broker-dealers and brokers (sociedades and agencias de valores) can offer it. In addition, it cannot be marketed until a ministerial order comes into force (LMVSI arts. 341.3 and 343; eleventh final provision). Congress must decide on its validation within 30 days (Constitution, art. 86.2).

Still to come is the EU retail investment strategy, with new rules on marketing communications and finfluencers. The Council and the European Parliament agreed on it in December 2025. As of 2 October 2026 it had not yet been published in the Official Journal of the EU. It will apply 30 months after that publication (Council of the EU). Until then, the rules in this article apply.

4 texts set the rules for your advertising

Your website is advertising as soon as it invites people to sign up for an investment service. Circular 2/2020 covers advertising on the internet “in any of its forms” (rule 2.a). It leaves out, among others, corporate campaigns that only raise awareness of the entity (rule 3.2.a). It also leaves out pre-contractual or objective information on the website (rule 3.2.d). Cautious approach: treat every service page as advertising.

1. Law 6/2023. All information for clients, advertising included, must be fair, clear and not misleading, and advertising must be identifiable as such (art. 200.2).
2. Delegated Regulation (EU) 2017/565. Its article 44 spells out those principles: risks alongside benefits, conditions for past and future returns, tax warnings and no using the supervisor as an endorsement. It applies directly.
3. Order EHA/1717/2010 and Circular 2/2020. They develop those principles for any medium, and the BOE shows no changes to either since 2020. The whole Circular binds investment firms, such as an EAF, and its annex binds anyone advertising investment services in Spain (rule 4.1). An EAFN is not an investment firm, but the law subjects it to the same requirements as an EAF (LMVSI art. 128.5.a; RD 813 art. 5.1). Cautious approach: if you are an EAFN, comply with the whole Circular too.
4. The Bank of Spain rules, if you are a bank’s agent and advertise deposits or loans. Order EHA/1718/2010 requires the word “publicidad” (advertising) on every advertising leaflet and the TAE (annual percentage rate) if you mention cost or return (art. 4.1 and 4.5.a). Circular 4/2020 requires the piece to say in what capacity the agent is acting (annex III.1.2).

On top of these come the rules for any advertiser: the Unfair Competition Law, the Consumer Protection Law and the Information Society Services Law (LSSI).

What happens if you break the rules. You do not need prior authorisation to advertise (Circular 2/2020, rule 9.1). But the CNMV can require you to withdraw or correct an ad, and you have 3 working days to comply or make representations (rule 9.4). Advertising that breaches these rules is a serious infringement if it is occasional and a very serious one if it is not (LMVSI art. 290). A serious one can cost up to €300,000 or, if higher, three times the profit obtained, among other amounts (art. 313.1).

Yes, no and with care, phrase by phrase

Use this table to review your website, your ads and your profiles. Abbreviations: LMVSI is Law 6/2023; RD 813, Royal Decree 813/2023; R565, Delegated Regulation (EU) 2017/565; C2/2020, CNMV Circular 2/2020. Q&A are the CNMV’s questions and answers on MiFID II. LCD is the Unfair Competition Law (Ley de Competencia Desleal); LGDCU, the Consumer Protection Law (Ley General para la Defensa de los Consumidores y Usuarios). “Cautious” marks an approach of our own, not a rule.

The mandatory details on your website, with their article

All of them are required by law except those marked as cautious. In practice, it makes sense to gather them in the footer, the legal notice and a “Client information” page.

For any status:

1. Name or company name, address and email, and another means of direct contact (LSSI art. 10.1.a).
2. Your tax ID (NIF) (art. 10.1.e) and, if you are a company, your Companies Register details (art. 10.1.b).
3. If you are an EAF or EAFN, your registration and who supervises you: your CNMV number and the name of the supervisor (LSSI art. 10.1.c). If you are an agent, see point 15.
4. Whether prices include taxes, when you publish rates (LSSI art. 10.1.f).
5. Whether you verify the reviews you show, and how (LGDCU art. 20.4).
6. Privacy information next to each form (GDPR, art. 13).

If you are an EAF or EAFN:

7. “EAF” in your name and in all your advertising (LMVSI art. 129.2; RD 813 art. 7.1). If you are an EAFN, “EAFN” in your name (RD 813 art. 7.2). On the CNMV list, EAFNs that are individuals appear under their name only: cautious approach, add “EAFN” next to it on your website.
8. Whether your advice is independent or not, and why. Also which range of products you analyse and what relationship you have with their issuers (R565 art. 52; RD 813 art. 143.1.a). You must give this before providing the service: the website is the natural place for it (cautious).
9. How you are paid: your fees and any third-party payments, with their amount or their calculation method (LMVSI art. 216.2; RD 813 art. 143.1.c). Informing clients before the service is mandatory; publishing it on the website is a cautious approach.
10. A customer service section that is easy to find. With postal and email addresses, the one-month time limit for resolving complaints, channels, rules and opening hours (Law 44/2002, art. 29.5). The law names investment firms; if you are an EAFN, the cautious approach is to publish it anyway.
11. A summary of your conflicts of interest policy (R565 art. 47.1.h). It is provided before the service; publishing it on the website is a cautious approach.
12. If you are an EAFN, that you cannot provide services in other EU countries. The client must accept this in writing before signing up (RD 813 art. 5.5). Flagging it on the website avoids surprises (cautious).
13. If you work with agents, the fact that you do (R565 art. 47.1.e). Clients are informed before the service. Cautious approach: say so on the website too, with their names, so the client can check them.

If you are an agent:

14. Your status as an agent, the entity you represent and the scope of your authority (RD 813 art. 18.2). If you are a bank’s agent, the entity, unambiguously (RD 84/2015 art. 21.5).
15. The register in which you are entered: the CNMV or the Bank of Spain (cautious; where each agent registers is set by LMVSI art. 130.3 and RD 813 art. 15.3).
16. A link to your entity’s customer service department (cautious).

Outside the website, if you are an EAF or EAFN:

• A marketing communications policy approved by your board (C2/2020 rule 6). If you are small and advertise little, on non-complex products, it can be simplified (rule 6.3).
• A record of your advertising for 5 years: each campaign, with its pieces, dates and review (C2/2020 rule 7). A simplified version is also allowed (rule 7.4).

Recommended, though not mandatory: a link to your entry in the CNMV register or in the Bank of Spain’s. The CNMV advises investors to check its registers before investing, and the Bank of Spain register if they deal with a bank’s agent (authorised entities). Putting it one click away is a sign of trustworthiness that costs nothing.

Page map: one per need, not per product

People looking for an adviser do not type “investment advice services”. They type “what do I do with the money from selling my company” or “I have inherited a fund portfolio”. And Google gives more weight to trustworthiness on topics that can affect someone’s financial stability (Google Search Central).

2 rules for using it. Our approach: better 3 complete need pages than 8 half-finished ones. And no page cloned per city: Google treats having several pages aimed at cities that lead to the same place as doorway abuse. If you see clients in Castellón and in Valencia, one page per real office.

This map is approved before the design: it is the basis of a web design built to win clients.

The form qualifies with bands, not with exact wealth

A form with name, email and message treats someone with €20,000 in a deposit the same as someone who has just sold their company. A form that qualifies asks a few closed questions:

1. What you need: retirement, family business, inheritance, second opinion or other. These are the pages on your map.
2. What amount you would like us to review, in broad bands and optional. For example: under €100,000, €100,000 to €500,000, over €500,000.
3. When you need it: now, in the next 3 months or I am just looking into it.
4. Town, so you know whether you can see them in person.
5. How did you hear about us?
6. Contact details and preferred channel.

At first contact, do not ask for an ID (DNI), exact balances, account numbers, statements or holdings. The GDPR requires data to be limited to what is necessary (art. 5.1.c). Cautious approach: the bands tell you whether the enquiry fits your minimum without asking for a figure nobody wants to give a stranger.

2 caveats:

• The form is not the suitability assessment. Before recommending anything, you must know the client’s financial situation, objectives and experience (LMVSI art. 204.1). That belongs in the first meeting, not on the website.
• The newsletter, only with permission. You can only send advertising by email to someone who is not a client if they asked for it or authorised it (LSSI art. 21).

How to turn more visits into meetings is what we work on in conversion and CRO.

Reviews and testimonials: what the client says becomes your advertising

The reviews on your Google Business Profile are written by clients on Google. Asking for them is allowed, under the rules we explain in how to get Google reviews. The problem starts when you turn them into advertising.

• On your website, if you show reviews, explain whether you verify that they come from clients and how you process them. They must refer to services used in the 30 calendar days before the date of the review (LGDCU art. 20.4).
• On social media, if you share what a client posts highlighting the advantages of your service, you are responsible for that content even if you did not write it (C2/2020 annex I.12).
• No testimonials with figures. “With them I made 12%” talks about past returns and does not meet the conditions of article 44.4 (cautious approach).
• Invented or commissioned reviews, never (LCD art. 27.8).

When you reply, do not confirm that the writer is your client or give details of their case (cautious approach). Thank them for their feedback and offer a private channel.

Google Ads, social media and influencers: the platform checks too

Search engines, social networks and media must check that anyone advertising investment services is authorised before publishing. They must also check that the advertiser is not among the entities the CNMV has warned about (LMVSI art. 246.3). For the platform, failing to do so is a very serious infringement (art. 290).

Google Ads. In Spain, Google has required its financial services verification since 24 January 2023. The regulators it accepts include the CNMV and the Bank of Spain (list of bodies). Most advertisers first go through G2RS’s external verification, and their details must match the register exactly. If you are an agent, ask your entity: Google treats those who advertise with the approval of an authorised advertiser as “approved third parties”, and does not ask them for G2RS. Campaign structure and budget are covered in Google Ads for service SMEs.

Influencers. You can pay a creator to spread your advertising if you pay them a fixed amount per piece, even if it includes a small success bonus (Q&A 22.2). The CNMV sees client acquisition, which is reserved for authorised entities, in 2 cases. The first, if you pay them per client or per volume brought in. The second, if they answer their followers’ questions about your service, even on a fixed fee. And you are always responsible for who you choose and what they publish.

Make it clear that it is advertising: ESMA asks for words such as “Advertising” (Publicidad) or “Paid partnership” (Colaboración pagada), not just hashtags (factsheet for Spain). Paid promotion that is not identified as such is misleading (LCD art. 26.1). If the warnings do not fit, they can go in a secondary piece, with a notice such as “click on the image for more information” (C2/2020 annex I.10).

Your own posts. Giving an opinion on whether a security will go up or down, or recommending a strategy, can be an investment recommendation. The CNMV guide for finfluencers explains what it must include: who prepared it, date and time, reliable sources and conflicts of interest. From professionals and experts, and an adviser is one, it also asks for the investment horizon, the risk warnings and a summary of the methodology. A “this is not advice” disclaimer does not protect you if you make a recommendation to a specific person.

Unauthorised firms (chiringuitos): make checking you a one-click job. The CNMV warns that some unauthorised entities cite it to convey security (warnings). Others disguise themselves as advisory contracts (guide on unauthorised firms). Your answer: your registration number in plain view and a link to your entry. Cautious approach: search for your trading name in the warnings search tool every few months, in case someone copies it.

What to measure: meetings and contracts, not visits

The 5 basic numbers are in how to measure the enquiries from your website: enquiries, enquiries that fit, clients, value and cost per client. In financial advice, add 3 more:

• Enquiries per need. How many come from each page on the map. It tells you which page to write next.
• From enquiry to first meeting, and from meeting to contract. The cycle is long: measure it by quarter, not by week (our approach).
• Cost per meeting in ads. Our approach: it is more useful than cost per click, because a meeting has already passed your filter.

To know how much you can pay for a client, use the customer value calculator. Every quarter, also check what AI assistants answer when someone asks for an adviser in your town, with the 15-minute test. And keep a dated copy of every ad and every version of your landing pages: if you are an EAF or EAFN, that archive is your advertising record.

What to do on Monday

1. Look up your entity in the register of the CNMV or the Bank of Spain. Copy the exact number and compare it with your footer, your legal notice, your LinkedIn and your Google Business Profile.
2. Search your website, your ads and your profiles for these words: “guaranteed”, “risk-free”, “independent”, “the best”, “free”, “return”, “CNMV”. Rewrite each phrase using the table.
3. Measure your warnings. If they are smaller than the main text or sit in the footer, make them bigger and move them up.
4. Write the “How we work and what it costs” page: independence, range, fees and third-party payments.
5. Open your customer service section. If it says “2 months” or “two months”, change it to one month.
6. If you are an agent, put your entity’s name next to yours on your website, your Google Business Profile and LinkedIn.
7. Create a folder with every ad and every page version, each with its date. It is the basis of your advertising record.
8. Before your first campaign, apply for Google’s verification.

If we work together at NOR studio, we prepare every text with this table in view, and you or your compliance officer sign it off before it is published. On our page for insurance brokerages and financial advisers we explain how we approach a website that wins clients within these rules.