Who is exempt from the annual external expert exam?

The following are exempt from the external expert exam: (1) sole traders and individual professionals — natural persons carrying on the activity in their own name —; (2) insurance brokers; and (3) obliged entities under letters i) to u) of article 2.1 which, including their agents, employ fewer than 10 people and whose annual turnover or balance-sheet total does not exceed €2 million. The size exemption is lost if the entity belongs to a corporate group exceeding those figures.

Letters i) to u) cover, among others, currency exchange, real estate, auditors and tax advisers, notaries and lawyers, company service providers, casinos, jewellery, art and the trade in goods: in other words, most non-financial obliged entities. A company in that space with 10 or more employees, or more than €2 million in turnover, must pass the exam every year.

Two nuances we see constantly in practice:

• Being exempt from the exam is not being exempt from the law. Customer due diligence, the special examination of unusual transactions, suspicious transaction reporting and record keeping remain fully enforceable.
• The exemption is lost as you grow. The year your headcount reaches 10, your turnover passes €2 million — or your company joins a group — the exam becomes mandatory.

Not sure which side of the line your company is on? It is a two-minute check with your headcount and turnover figures.

Legal basis:

• Art. 28.1 of Ley 10/2010
• Art. 31.1 of RD 304/2014

Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.

Does this affect you? We will confirm it in a two-minute call → Contact · +34 91 110 28 29

Related:

• What the external expert exam is
• Is your company an obliged entity?
• Penalties under Ley 10/2010
• All frequently asked questions