Circular 2/2026 from the National Commission for Markets and Competition: new features introduced to the Alias Register

Circular 2/2026, of 5 June, issued by the National Commission for Markets and Competition (hereinafter, its Spanish acronym, CNMC), amends Circular 1/2026, of 18 March, which regulates the Alias Register, and aligns its deadlines with Order TDF/558/2026, dated 4 June, which extends until 15 September 2026. the start of the obligation to block messages containing unregistered aliases.

This circular introduces significant changes to the alias registration procedure, strengthening the role of representation and updating the technical requirements for applicants and providers.

The main new development is that alias holders may act in the register through representatives, proving such representation by means of a letter of authorisation in accordance with the template published by the CNMC, signed by the holder or their legal representative.

The thresholds for bulk alias registration—reserved for source providers (PROs) needing to register aliases for at least 20 different holders, or a volume of at least 50 entries—are also adjusted, and a valid digital certificate is now required not only from the applicant but also from all representatives acting in the register.

The CNMC will also make a permanent test environment available to registered providers so that they can adapt their systems and download data from the Alias Register; the transitional provisions of Circular 1/2026 relating to the initial bulk upload process and the original testing period thus being repealed.

In view of the above, it is advisable to review internal procedures for registering aliases, to check whether a representative is acting on your behalf and, if so, to prepare the relevant supporting documentation, as well as bearing in mind that the obligation to block messages containing unregistered aliases will not come into force until 15 September 2026.