Board
A single counterpart
Security, custodians and regulatory evidence in the same conversation.
An agency investing its clients' savings. DORA already applies, with MiFID II beside it.
What the CNMV and the client ask of an automated portfolio manager, and how it can serve more people without standing up another technical team.
Technical analysis
Calendar
The licence is already there. So is DORA. Growth is what stays open.
Public dates from the supervisor and the sector. The 2030 plan is what firms in the sector have written, not a commitment.
17 Jan 2025
DORA in force
It includes investment firms, securities agencies among them.
Regulation (EU) 2022/2554, arts. 2.1.e and 64
1–29 Mar 2026
ICT provider register
The CNMV asked for the register with data as of 31 Dec 2025. That year's window is closed.
CNMV | reporting guide, 12 Feb 2026
24 Sep 2026
Dutch in Belgium
Firms in the sector open the service in another language, with a local custodian and local tax.
Sector blog, 24 Sep 2026
2 Nov 2026
Published scale
One manager in the sector is above €6.45bn and 184,000 clients, with France and Belgium already open.
Public statistics, 2 Nov 2026
2030
Belgium the sector is planning
Firms in the sector plan to reach €200m managed in Belgium, from about €30m.
Sector blog, 24 Sep 2026
What they ask
Four questions that repeat on every account and every review.
What the client, the custodian or the CNMV asks, the rule behind it, and what a technology partner leaves ready.
What they ask
The rule
What we prepare
01Does this portfolio fit me?
MiFID II, art. 25: suitability before managing
What we prepare |The test flow, with evidence of when it was taken
02Who holds my funds?
Custody at a bank, off the firm's own balance sheet
What we prepare |The custodian integration and a balance reconciliation
03Which ICT providers do you use?
DORA, art. 28: the register of third-party arrangements
What we prepare |The register, ready for the filing the CNMV asks for
04Where is my data?
GDPR on the test and on the client's wealth
What we prepare |Access, processors and retention, written down
The challenge
Several lines, several countries and one authorisation.
What this profile pays for today
- A suitability test on every account, before any money moves
- DORA already applies to the investment firm, with proportionality
- Custody at different banks depending on the client's country
- Funds, pensions, cash and insurance on the same stack
- The same due-diligence questions on every round
- An ICT-risk report for the supervisor, every cycle
What we propose
One technology partner for all four lines at once.
A single counterpart answers the board, the CNMV and the team that opens accounts.
CNMV
Evidence ready
The ICT-provider register and incidents, without rebuilding them each cycle.
Technical team
Capacity that adds
Reinforcement on resilience and integrations, without replacing the in-house team.
Expected impact
More clients served with the same team.
What changes when the ICT register, the custodians and due diligence stop taking the product team.
- ×1.5
- clients the firm can serve by the end of the period, versus staying without a partner
- −22 pts
- of technical time that returns to product and clients
- 6 → 1
- technical areas, one counterpart
Illustrative scenario, not a forecast. Index 100 = clients the firm can serve in Nov 2026. Assumption: freed time goes back to product and account opening.
Its market
Investment firms and a bank in the same shop window.
Four ways to offer an indexed portfolio in Spain. The licence is not the same in all four.
DORA
applies to investment firms, securities agencies included (art. 2.1.e)
CNMV
€6.45bn
is what one automated manager in the sector exceeds, with more than 184,000 clients (2 Nov 2026)
Public statistics
2030
firms in the sector plan to reach €200m managed in Belgium
Blog, 24 Sep 2026
Firms in the sector
Finizens
Indexed-fund and ETF portfolios. Investment firm no. 267
inbestMe
Fund and ETF portfolios. Investment firm no. 272
MyInvestor
Indexed portfolios delegated to a fund manager (no. 237)
Indexa Capital
Fund portfolios, pensions and cash accounts. Investment firm no. 257
A firm that combines funds, pensions, cash and a second country has more technical surface than one that only runs a single portfolio.
How we would solve it
A continuous rhythm, not a project with an end date.
Each pass leaves the register and the test in a state the supervisor can read.
- 01
Diagnosis
Suitability, custodians, access, data and ICT providers.
- 02
Audit
A report the board and the CNMV can both read.
- 03
Implementation
We fix it with their team, without replacing it.
- 04
Watch
A warning when a new custodian or a rule moves the roadmap.
Benefits and advantages
What this profile gains from the first quarter.
01
DORA in daily work
ICT risk, incidents and providers, in a register that stays current.
02
Traceable suitability
Every account records what was asked and when.
03
Custodians without friction
The same operation works with more than one depositary bank.
04
Short due diligence
One technical report for the next round or the next country.
05
One partner
Funds, pensions, cash and insurance, in the same relationship.
06
The team on the client
Technical time goes back to product and account opening.
Three ways to cover it
| Hire in-house | Several vendors | Globodain as partner | |
|---|---|---|---|
| Getting started | Months of hiring | Weeks per vendor | From the diagnosis |
| Counterparts | One, with gaps | One per area | One, for everything |
| Cost | Fixed and high | Scattered | Predictable |
| MiFID and DORA view | Depends on the hire | Fragmented | Complete |
| Evidence for the CNMV | Still to build | Separate | In one report |
Why Globodain
Capabilities that apply to an investment firm like this.
Scope note: mentioning regulated environments describes applicable capabilities, not a proven track record in portfolio management.
- 01
Cybersecurity
Access and security on a platform that holds client wealth.
- 02
Resilience
A technical reading of DORA: ICT risk, incidents and third parties.
- 03
Suitability
The MiFID II test flow, with evidence on every account.
- 04
Integrations
Custodians and banks connected without duplicating the client's balance.
- 05
Technical audit
Data, infrastructure and integrations in one report.
- 06
Watch
Early warning when a rule changes onboarding or the custodian.
Scope and limits
So it is clear from day one.
What we bring
- Technical audit, implementation and continuous watch
- A report of findings and priorities
- A stable counterpart, not a one-off vendor
What we do not do
- We do not certify regulatory compliance
- We do not issue certificates or seals to third parties
- We do not replace legal advice: we complement it
Certifications and legal advice belong to authorised third parties. We provide technology support: audit, implementation and watch.
Does your case look like this profile? We analyse it with you.
This analysis was built from public sources on the sector. If yours looks similar, Rubén Ayuso will analyse it with you and prepare one for your case.
A study built from public sources on the sector. It does not describe a specific company and was not prepared with one. The companies named are examples: it implies no relationship and no involvement on their part. It is not legal advice and not a contractual commitment.
