Staff training
The law requires training to be the subject of an annual plan. Art. 29 Ley 10/2010, read with Art. 39 Real Decreto 304/2014, expressly calls for a plan anual of training measures, approved by the internal control body. Where risk is elevated or there are many new joiners, more frequent training may be needed.
Art. 29 Ley 10/2010 speaks of formación periódica — and that is not merely how the practice reads it. The statute requires in terms that "las acciones formativas serán objeto de un plan anual que, diseñado en función de los riesgos del sector de negocio del sujeto obligado, será aprobado por el órgano de control interno". Annual, risk-based training is therefore anchored directly in the law, not just recommended by SEPBLAC or common practice.
Beyond that, some factors can call for training more often:
The law does not prescribe a format. In our experience the training that carries furthest is the one built on case studies and concrete scenarios from agency work rather than on legal material alone — that is an observation from practice, not a legal requirement.
On the state of the law: Real Decreto 813/2026, de 7 de octubre (BOE-A-2026-20915) amended the exception catalogue in Art. 31.1 RD 304/2014 and removed Art. 35 — the dedicated internal control body — from it with effect from 28.10.2026. For small offices the outcome is unchanged, because Art. 35.2 itself governs when such a body is not required; the chain of norms, however, is now a different one.
Legal basis: Ley 10/2010, Art. 29; Real Decreto 304/2014, Art. 39
Practical tip: Schedule the training for the quietest part of your year, before your high season starts. That way the whole team is up to date before business picks up.
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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