Documentation and audit trail
Under Art. 25.1 Ley 10/2010, after five years ordinary internal access is limited to the agency's control bodies — including any technical prevention unit — and, where applicable, those instructed with its legal defence. The statutory access and information rights of SEPBLAC and other competent authorities remain unaffected.
The period runs from the end of the business relationship or the completion of the transaction — not from when the file was opened.
In practice this has a consequence that is often missed: a complete file that the whole team can still open in year seven is not a compliant file. Unrestricted access by ordinary staff after the first five years is not compatible with this restriction, even where the documentation itself is complete.
Legal basis: Ley 10/2010, Art. 25.1
Practical tip: This provision concerns permission management, not file-keeping — which is why it is readily overlooked, since it plays no part when the file is opened. An agency that assigns access rights once and never revisits them breaches, five years later, a rule nobody had in mind when the rights were granted.
AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.
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