Foreign Auditors in Spain 2026: Commission, 160 € Fees and Registration Deadlines in the ROAC

Key data

An auditor authorized in Germany, France or any other EU Member State—or even in a third country—cannot practice in Spain without first registering in the Official Register of Auditors of Accounts (ROAC). To do so, they must pass an aptitude test designed and graded by an official commission. The Order ECM/614/2026, of June 4, published on June 18, 2026, appoints the members of that commission and sets the conditions of the process.

The regulation takes immediate effect: it entered into force on the same day of its publication in the BOE, so any application submitted from that date onwards is already processed under this framework.

What does this regulation establish?

Order ECM/614/2026 regulates the composition and operation of the Evaluation Commission responsible for examining foreign auditors who request registration in the ROAC. Its main functions are:

• Design aptitude tests on Spanish audit regulations.
• Grade such tests.
• Issue the resolution that determines whether the auditor can register in the ROAC.

The commission is chaired by the General Subdirectorate of Audit Technical Standards of the ICAC (Institute of Accounting and Audit of Accounts), an organization dependent on the Ministry of Economy.

The process varies depending on the auditor's origin:

Resolutions can be appealed to the Ministry of Economy, which guarantees an administrative remedy if the auditor disagrees with the result.

Economic and operational impact

The direct cost of the registration process is 160 euros for exam fees. This amount is not refunded except in case of duplicate payment, so the auditor bears this expense regardless of the outcome of the test.

Beyond the fee, the most relevant operational impact is the deadline of up to six months to obtain a resolution. This means that a foreign auditor who wants to join a project in Spain must plan their authorization well in advance: if they submit the application on day 1, in the worst case they will not receive a response until day 180.

For auditors from third countries, the burden is greater: in addition to the test, they must demonstrate that there is reciprocity between their country and Spain (that is, that Spain recognizes Spanish auditors in that country) and have an address or representative in Spanish territory. This implies additional management costs and, potentially, the cost of establishing a local structure.

Who does it affect?

• Auditors of accounts authorized in any EU Member State who wish to practice in Spain.
• Auditors authorized in third countries (outside the EU) who want to register in the Spanish ROAC.
• International audit firms that incorporate professionals authorized abroad into their teams in Spain.
• Spanish companies that hire or subcontract audit services to foreign professionals not registered in the ROAC.
• Law firms and consultancies that advise foreign auditors in their authorization process in Spain.

Practical example

An auditor authorized in Portugal—an EU Member State—wants to join a Spanish firm to audit the accounts of local clients. To be able to practice legally, they must:

1. Submit their application for registration in the ROAC to the ICAC.
2. Pay the fee of 160 euros for exam rights. This amount will not be refunded even if they fail the test.
3. Pass the aptitude test on Spanish regulations, designed and graded by the Evaluation Commission chaired by the General Subdirectorate of Audit Technical Standards of the ICAC.
4. Wait for the resolution, which can take up to six months from the submission of the application.

If the result is unfavorable, they can appeal to the Ministry of Economy. If they were an auditor from a third country—for example, from Mexico—they would also need to demonstrate that there is reciprocity between Mexico and Spain, and provide an address or representative in Spanish territory before their application is admitted for processing.

What should foreign auditors do now?

1. Verify if you already have an application in progress: If you started a ROAC registration process before this order, check that your file is being processed under the new framework of the appointed commission.
2. Plan six months in advance: The maximum resolution deadline is six months. If you need to be authorized by a specific date, submit your application with that margin.
3. Prepare for the aptitude test: The commission evaluates knowledge of Spanish audit regulations. Identify areas of Spanish regulations that differ from those in your country of origin and focus your preparation there.
4. If you come from a third country, demonstrate reciprocity: Before submitting your application, verify that your country has reciprocal recognition with Spain and prepare the documentation to prove it.
5. Designate an address or representative in Spain (third countries only): If you do not have a presence in Spain, designate a representative before submitting your application to avoid it being rejected.
6. Keep the proof of payment of 160 €: Exam fees are non-refundable except for duplicate payment. Keep the receipt to prove payment in case of any issue.
7. Know the remedy available: If the resolution is unfavorable, you have the option to appeal to the Ministry of Economy. Check the applicable administrative deadlines so you do not lose that possibility.

Official source

View complete regulation in official source

Notice: 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-2026-13279