LOPIVI: the sexual offences certificate in Spanish clubs

Every season, thousands of Spanish clubs ask coaches, instructors and volunteers for the same document: the negative certificate from the Central Sex Offender Registry (Registro Central de Delincuentes Sexuales). It arrives by email as a PDF, as a phone photo or on paper, and someone has to check it is for the right person, recent enough, and really says "no records".

This article explains what Spanish law requires, how the certificate is obtained and verified, and what can and cannot be automated.

What the LOPIVI saysCopy Anchor Link

Organic Law 8/2021 of 4 June on the comprehensive protection of children and adolescents against violence (LOPIVI) sets the requirement in Article 57:

• 57.1. To access and carry out any profession, trade or activity involving regular contact with minors, a person must not have a final conviction for offences against sexual freedom and integrity or for human trafficking. Whoever seeks access must prove it by providing a negative certificate from the Central Sex Offender Registry.
• 57.2. Regular contact means activities, paid or unpaid, that by their nature involve repeated, direct and regular (not merely occasional) contact with children; and in any case, activities whose main recipients are minors.
• 57.3. Companies and organisations may not employ people with records in the Registry in those activities.

The following articles set out the consequences: Article 58 for employees (no hiring if there are records; if records appear later, termination or a change of role) and Article 59 for volunteers, who must also provide the negative certificate. Article 59.3 leaves the penalty regime for breaches of Article 57.1 to the autonomous communities.

What about sport?Copy Anchor Link

Sport is not exempt because it is leisure or voluntary. Article 57.2 expressly includes unpaid activities, and Article 48 imposes extra obligations on organisations that regularly run sports or leisure activities with minors: applying action protocols, setting up a monitoring system and appointing a child protection officer (Delegado o Delegada de protección).

In practice, a youth team coach, a sports camp instructor or a volunteer who travels with an under-12 team every week fit the definition. One-off collaborations need a case-by-case assessment. The Ministry of Justice notes that the AEPD, in its Report 0401/2015, reads the requirement as referring to roles that by nature involve regular contact with minors as their main recipients (Ministry of Justice).

How the certificate is obtainedCopy Anchor Link

According to the Ministry of Justice e-office:

• It can be requested by individuals, legal entities (with a representative certificate) and representatives of minors.
• Online, with Cl@ve (Spain's e-ID system) or an electronic certificate (FNMT, electronic DNI). Without them, you can start the request online and prove your identity later at an office.
• As a general rule it is issued immediately. For minors, usually within 24 hours, with a maximum of ten working days.
• When a public authority asks for it, the citizen may decline to provide it if they authorise the authority to consult the data internally.
• For organisations there is TeAutorizo, an e-office application to obtain the certificates of citizens who have authorised it.

The certificate shows whether sexual offences are on record at the date of issue. Article 57 does not set a validity period, so the maximum age you accept is your organisation's (or your federation's) decision. Write it into your protocol and apply it consistently.

The Secure Verification Code (CSV)Copy Anchor Link

The certificate PDF carries a Código Seguro de Verificación (CSV, Secure Verification Code). The e-office states that bodies, organisations or third parties receiving the electronic certificate must check its validity in the "Verification of documents via CSV" section by entering that code.

The verification guide describes the steps:

1. Go to sede.mjusticia.gob.es, sexual offences certificate procedure.
2. Click "Tramitación On-line sin Certificado Digital" in the verification block.
3. Enter the Secure Verification Code.
4. Enter the holder's identity document number and click "Consultar".
5. The original certificate is downloaded.

Typographical confusionsCopy Anchor Link

The Ministry's user manual for this verification gives two useful hints:

• The first three characters of the code are SD:.
• Depending on the typeface, capital i, lowercase L and the number 1 can be confused, as can zero and capital O.

The manual's own example, SD:jJi7-B6jl-OZ03-7E1I, mixes upper and lower case. So when you copy the code, keep the case exactly and, if verification fails, try those substitutions before treating the certificate as fake.

Why not automate verification on the e-office?Copy Anchor Link

The same manual includes a step "enter the word shown in the image": a CAPTCHA. Its purpose is for a person to perform the lookup. Automating it by bypassing that control means circumventing a security measure of a public authority, and we neither recommend it nor do it. If you need volume, use the official route: have the person authorise your organisation through TeAutorizo, or have a person run the check with the data already prepared.

What you can safely automate is everything before that:

• that the document is a sexual offences certificate (not a general criminal record certificate, another document or a random screenshot),
• that the holder matches the registered person,
• that the issue date meets your maximum age,
• that it states no records,
• and that the CSV has been read in a plausible format, ready to copy.

That way the person verifying on the e-office only pastes the code and the ID number instead of opening PDFs one by one.

How Constaia does itCopy Anchor Link

Constaia has a dedicated type, es_sexual_offences_certificate, which extracts holder_name, holder_id, issue_date, has_records (boolean) and csv_code. It applies deterministic checks on those fields: the holder's NIF check letter, age of the document (max_age_days) and CSV format. With holder you compare against your registration data, with normalised names (accents removed, flexible surname order).

curl https://api.constaia.com/v1/analyze \
  -H "Authorization: Bearer $CONSTAIA_API_KEY" \
  -F file=@certificate.pdf \
  -F 'options={
    "expect": "es_sexual_offences_certificate",
    "checks": {
      "max_age_days": 90,
      "holder": { "full_name": "Laura Pérez Gil", "document_number": "12345678Z" }
    },
    "storage": "none",
    "language": "en"
  }'

What Constaia does not do:

• It does not verify the certificate on the Ministry of Justice e-office and does not bypass its CAPTCHA. It gives you the CSV it read so the official check is quick.
• It does not prove the PDF is authentic. A correct reading and a plausible CSV format do not replace verification on the e-office.
• It does not decide whether an activity involves "regular contact": your protocol does.

The max_age_days: 90 in the example is only illustrative. More in Checks and the document type catalogue.

Checklist for your clubCopy Anchor Link

• Identify which roles (paid or volunteer) involve regular contact with minors.
• Define in writing the maximum certificate age you accept.
• Check holder, date and result of each certificate, and verify the CSV on the e-office.
• Record the date and result of the check. Consider whether you need to keep the PDF or whether that record is enough.
• Remind employees of their duty to report records that appear later (Art. 58.2).
• Appoint the child protection officer if your organisation regularly runs activities with minors (Art. 48).

If you want to try extracting the certificate and its CSV with your own documents, create a free account: it includes 250 credits a month.