To register an alias with the CNMC, someone must be able to complete the process electronically through the CNMC Electronic Office using a certificate that is valid in Spain.
If the alias owner or its legal representative does not have such a certificate, they may appoint another person or company as an Authorized Representative by signing a Letter of Authorization.
This means that the legal representative does not need to obtain a Spanish electronic certificate. Instead, they must sign the Letter of Authorization and authorize a person or company that holds a valid electronic certificate and can act before Spanish public authorities.
Types of Letters of Authorization
Each template includes the information that must be completed and the corresponding declarations required for that specific procedure.
Modelo Persona fĂsica extranjera ESP-EN Complete the English section.
Modelo Persona jurĂdica extranjera ESP-EN Complete the English section.
Who must sign the Letter of Authorization?
This depends on the type of alias owner:
If the owner is an individual or self-employed professional, the Letter of Authorization must be signed by the owner.
If the owner is a company, the letter must be signed by its legal representative or by a person with sufficient authority to act on behalf of the company.
If the owner is a foreign company, the letter must be signed by an individual who is legally authorized to represent the company under the laws of its country.
The Letter of Authorization must also be accepted and signed by the Authorized Representative.
The owner may sign the letter by hand or using any signature method accepted in Spain. For foreign companies, signature methods that are valid in their country of origin are also accepted.
Who can act as the Authorized Representative?
The Authorized Representative may be an individual or company that holds an electronic certificate that is valid and authorized for use in Spain.
The Authorized Representative may carry out actions before the CNMC Alias Registry such as:
requesting the registration of aliases;
modifying, suspending or cancelling registered aliases;
submitting documentation and responding to CNMC requests;
approving applications submitted by Origin Providers;
completing any other procedures required to manage the ownerâs aliases.
The authorization is granted for an indefinite period unless it is expressly revoked by the owner.
Example: a foreign company
If the alias owner is a foreign company, such as a US LLC:
the company is the alias owner;
an individual with sufficient authority to represent the company signs the letter on its behalf;
the letter authorizes another person or company that holds a certificate valid in Spain.
The company does not authorize its own legal representative. The legal representative signs on behalf of the company and authorizes a third party to act electronically before the CNMC.
How to use the Letter of Authorization in the Alias Registry
Once the letter has been completed and signed:
Access the Alias Registry Management procedure through the CNMC Electronic Office.: https://sede.cnmc.gob.es/tramites/telecomunicaciones/gestion-del-registro-de-alias
âSelect âActing on behalf ofâ (En representaciĂłn de) and enter the alias ownerâs details.
â
Under âApplication typeâ (Tipo de solicitud), select âAlias registrationâ (InscripciĂłn de Alias).
â
In the âOwnerâs representativesâ section (Representantes del titular), enter the details of the person or company appointed in the Letter of Authorization.
â
Select âAuthorizedâ (Autorizado).
Attach the signed Letter of Authorization.
Confirm by clicking âAdd representativeâ (Añadir representante).
If Instasent submits the application
Instasent may submit the alias registration application as the Origin Provider.
The Letter of Authorization does not automatically make Instasent the alias ownerâs Authorized Representative. The Authorized Representative will only be the person or company expressly appointed in the letter.
If Instasent submits the application and the owner cannot approve it directly using a certificate that is valid in Spain, the Authorized Representative may complete the required procedures before the CNMC on behalf of the owner.
â