Fund Distribution in Spain, Andorra & Portugal: A Guide for International Managers

For an international asset manager, Iberia is an attractive but tightly regulated market. Before a single meeting can take place or a factsheet can be sent, the fund must be authorised for marketing with the local regulator. This guide outlines how fund distribution works across Spain, Portugal and Andorra, and where the main obligations lie.

You cannot market a fund in Spain until it is registered with the CNMV

This is the single most important point for any manager entering Spain. A fund may not be marketed to investors in Spain until it has completed the notification procedure with the Comisión Nacional del Mercado de Valores (CNMV) and appears in its register of foreign collective investment schemes marketed in Spain. Marketing activity carried out before that point is not permitted.

For a UCITS domiciled in another EU member state, this is done through the European passport: the manager’s home regulator notifies the CNMV, and marketing may begin once that notification is complete. For a non-UCITS fund (an alternative fund, or AIF), the route is different and more restrictive, and the conditions depend on the type of investor being targeted. [The exact documentation and timelines should be confirmed with compliance and against current CNMV guidance.]

The regulatory framework: MiFID II and SFDR

Distribution in the EU is governed principally by MiFID II (Directive 2014/65/EU), which sets the rules for how investment services are provided, how clients are classified, and the standards of conduct that apply. Client classification matters: the obligations differ significantly depending on whether the end investor is a retail client, a professional client or an eligible counterparty.

Alongside MiFID II, the SFDR framework classifies funds by their sustainability profile — commonly referred to as Article 6, Article 8 and Article 9 products. Managers marketing in Iberia should be clear about how each of their funds is categorised, as this affects disclosure obligations and how the fund can be presented.

Portugal and Andorra: not one single market

Portugal follows the same EU logic as Spain: a UCITS is passported and marketing is supervised by the CMVM. The mechanics are broadly equivalent to the Spanish process, with local notification requirements to observe.

Andorra is a different case. It is not part of the EU or the EEA, so the European passport does not apply, and the country operates its own regime for the distribution of foreign funds. Any plan to market in Andorra should be treated separately. [Andorra’s specific requirements should be confirmed with local advisers.]

The role of a tied agent

Many international managers enter Iberia through a local partner rather than building their own regulated presence. Working with a tied agent of an authorised investment firm gives access to the market and to distribution platforms without the manager having to establish and license its own entity. South Hub Investments acts as a tied agent of Ursus-3 Capital A.V., S.A. (CNMV reg. no. 251), representing selected international managers to professional investors across Spain, Portugal and Andorra.

South Hub Investments acts as the local distribution partner for international managers entering the region: see our service for institutional fund distribution in Spain, Portugal and Andorra.

Who actually buys foreign funds in Iberia

The buyer base is more concentrated than the population would suggest, and understanding its shape helps a manager focus its effort where it will count. In Spain the pools that matter are the large bank-owned asset managers and their fund-of-fund and multi-manager desks, independent discretionary and advisory managers, occupational pension schemes and their consultants, insurance balance sheets, private banks and their approved-product committees, and a growing set of multi-family offices concentrated in Madrid and Barcelona. Portugal is smaller and more centralised in Lisbon, with pension funds, insurers, and the discretionary desks of the main banking groups doing most of the allocating. Andorra is a distinct and well-established market in which private banking relationships play a central role.

What Iberian selectors look for

Selectors in both countries are generally rigorous, well-resourced and genuinely long-term in outlook, and their due diligence is thorough by design. A recognisable strategy with a clear philosophy travels better than an idiosyncratic one. Track record is examined over full cycles rather than trailing twelve months. Team stability and the presence of the named manager matter, as does capacity discipline. Practical eligibility criteria come up early: is the fund registered locally, is there a share class the platform can trade, is the vehicle UCITS, what is the SFDR classification, what is the minimum, and is there an intermediary who can service the relationship in the local language and time zone.

Choosing between a third-party marketer, a platform and your own team

These are complementary options rather than competing ones, and most managers end up using more than one. Building a local team gives full control, and makes sense once the asset base justifies fixed salaries, licensing and infrastructure. Fund platforms are the operational backbone of the Iberian market: they give a manager efficient access to a very large number of distributors, and for many local buyers a platform listing is simply how business gets done. A third-party marketer or tied agent contributes established relationships, local licensing cover and a variable cost structure. In practice the platform handles the plumbing and the commercial partner handles the dialogue, and the two work best together.

What a distribution mandate typically covers

A well-drafted mandate defines the territory, the investor segments in scope, the specific funds and share classes covered, exclusivity and its limits, how introduced accounts are attributed and for how long, reporting cadence, the compliance framework under which marketing is carried out, term and termination, and what happens to trail economics after termination. Ambiguity about account attribution is the most frequent source of later disputes, so it is worth spending time on that clause specifically.

Timeline from decision to first allocation

A realistic sequence looks like this. Structural and regulatory decisions and share-class registration occupy the first one to three months. Preparing local materials, the European MiFID Template, SFDR annexes and due-diligence responses runs alongside it. Systematic introductions begin once registration is confirmed, and initial meetings typically lead to a monitoring period rather than an allocation. Inclusion on approved lists and first allocations commonly follow twelve to twenty-four months after the first meeting, with meaningful scale later still. That timetable reflects the depth of the due diligence involved rather than any reluctance to allocate, and managers who plan for it tend to be rewarded for their patience.

Common mistakes international managers make

Treating Spain and Portugal as a single market with a single buyer list. Beginning outreach before registration is complete. Registering a share class that local platforms cannot actually trade. Sending a different person to every meeting. Relying on English-only materials for wealth and private-banking channels. Underestimating how much of the decision is made in the monitoring period after the meeting, when nobody is asking questions. And withdrawing after four quarters, just as the groundwork begins to pay off.

Frequently asked questions

Can I market a fund in Spain before CNMV registration?
No. Marketing may begin only once the share class appears in the CNMV register of foreign collective investment schemes authorised for marketing.

Does one registration cover Spain, Portugal and Andorra?
No. Spain and Portugal each require their own notification and registration under the EU passport, and Andorra sits outside that regime with its own rules for foreign funds.

Do I need a UCITS, or can I distribute an alternative fund?
Both are possible, but UCITS reach a far wider Iberian buyer base. Alternative funds are generally limited to professional investors and involve a different notification route.

What does a third-party marketer typically charge?
Arrangements vary and usually combine a retainer with a share of the revenue on assets introduced. Terms depend on the strategy, the exclusivity granted and the expected fundraising effort, and are agreed case by case.

Is English enough for investor materials?
For most institutional and professional investors, yes. Private banking, advisory and wealth channels expect Spanish or Portuguese, and some investor-facing documents must be available locally as a condition of registration.

This page is general information, not legal or investment advice. Regulatory requirements change and depend on the specific fund and investor type. Any distribution plan should be validated with qualified compliance and legal advisers before proceeding.

Related insights

• What Is MiFID II? A Plain Guide for Asset Managers
• MiFID II for Foreign Managers Entering Spain
• SFDR Explained: Articles 6, 8 and 9
• How to Distribute a UCITS Fund in Iberia