Who in the office needs the training — only agents, or support staff too?

Everyone with access to client files, who deals with clients or takes part in processing transactions needs it — agents, assistants, back-office staff and, where applicable, the managing director. For bookkeeping without client contact the circle can be drawn more narrowly on a risk basis; that is not a blanket exemption.

Art. 29 Ley 10/2010 requires obliged entities to train al personal. The term is to be read broadly: it covers anyone who, in the course of their work, handles information about clients or transactions that is relevant to preventing money laundering.

Specifically covered:

• Estate agents — they have direct client contact.
• Assistants and reception — they work on client files, enter KYC documentation and communicate with clients.
• Back office and administration — they check contracts, manage documents and liaise with notaries.
• Managers and owners — they are responsible for organising compliance and must know the duties.
• Interns and temporary staff — as soon as they have access to client data, however briefly.

The circle can be drawn more narrowly — on a risk basis and with reasons, not as a blanket rule — for:

• Bookkeeping alone, provided no client contact data or transaction details are handled
• Purely technical IT staff, provided the contents of KYC files are not visible to them

These exceptions are to be assessed on a risk basis, not treated as absolute.

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 (as amended by Real Decreto 813/2026)

Practical tip: In many agencies it is German-speaking support staff who have the first contact with German buyers. Training them is essential, because they are often the ones requesting the first KYC documents.