Registering the alias without an electronic certificate

To register an alias with the CNMC, someone has to be able to act electronically before its electronic office through a certificate valid in Spain. If the alias owner or their legal representative has no such certificate, they can designate another person or entity as an authorised representative through an authorisation letter.

This way, the owner's legal representative doesn't need to obtain a Spanish certificate: it's enough to sign the letter and authorise a person or entity that does hold an electronic certificate valid to act before the Spanish public administrations.

Types of authorisation letter

There's a different letter template depending on who the owner is. Each form shows the details to fill in and the responsible declarations that apply to the process:

• Spanish natural person or one legally resident in Spain
• Spanish legal entity
• Public Administration
• Foreign natural person
• Foreign natural person ESP-EN (with a section to complete in English)
• Foreign legal entity
• Foreign legal entity ESP-EN (with a section to complete in English)

Who must sign the authorisation letter?

It depends on who the alias owner is:

• If the owner is a natural person or a self-employed worker, the letter must be signed by the owner themselves.
• If the owner is a company, the letter must be signed by its legal representative or 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 a natural person with the authority to legally represent the company under the laws of their country.

The letter must also be accepted and signed by the authorised representative.

The owner's signature may be handwritten or made through one of the signature methods accepted in Spain. For foreign companies, the signature methods valid in their country of origin are also accepted.

Who can be the authorised representative?

It can be a person or entity that holds an electronic certificate valid and enabled to act in Spain.

The authorised representative can carry out actions before the Sender Alias Registry such as:

• requesting the registration of aliases;
• modifying, suspending or cancelling aliases already registered;
• providing documentation and responding to CNMC requirements;
• approving the requests submitted by origin providers;
• carrying out other necessary tasks related to the owner's aliases.

The authorisation is granted indefinitely, unless the owner expressly revokes it.

How to use the letter in the Sender Alias Registry

Once the letter is filled in and signed:

1. 1

   Access the process

   Go to the Gestión del Registro de Alias (Sender Alias Registry management) process at the CNMC's electronic office: https://sede.cnmc.gob.es/tramites/telecomunicaciones/gestion-del-registro-de-alias.

2. 2

   Applicant: «En representación de» (on behalf of)

   Select «En representación de» (on behalf of) and enter the details of the alias owner.

   

3. 3

   Request type: «Inscripción de Alias» (alias registration)

   Select «Inscripción de Alias» (alias registration).

   

4. 4

   Add the authorised representative

   In the «Representantes del titular» (Brand owner's representatives) section, add the details of the person or entity designated in the letter. Tick the «Autorizado» (authorised) option and attach the signed authorisation letter. Confirm with «Añadir Representante» (add representative).

   

If Instasent submits the request

Instasent can submit the alias registration request as the origin provider.

The authorisation letter does not automatically make Instasent the owner's authorised representative: the authorised representative will be exclusively the person or entity expressly designated in the letter.

If Instasent submits the request and the owner can't approve it directly through a certificate valid in Spain, the authorised representative can carry out the necessary actions before the CNMC on the owner's behalf.