The History of the U.S. “W2” Employee and Spain’s DNV
Not everyone even knows what “W2” means, but in short it’s the taxation type of an employed person in the USA. US employment tax is always referred to by the number of the Tax Form they are given at the end of the working year. Simply put, the self-employed are issued a 1099, those who work for a company they don’t own get a W2. And to make it even more confusing, sometimes a company owner can “pay themselves” and they can do that via employment by their own company, issuing themselves a W2.
No, Spain does not consider those people to be “employed”, they consider them to be self-employed. Which is a whole other can of worms we aren’t opening today.
So the digital nomad visa/residency was originally created for both the employed and the self-employed. If you are employed, you likely pay a social security tax or fee that is taken from your paychecks, and some countries have an agreement with Spain that allows for citizens to go and work in Spain but continue to pay their social security tax to the country or origin. The US is one such country with this agreement - as are the UK, Russia, China, Chile, and Canada. There’s a document in each country we call the “Certificate of Coverage” (CoC for short - or A1 in some countries) that gets requested by the employer, and it’s set up to let the other government know the employee is moving there but exempt from the foreign social security. So when the DNV rolled out in late 2022, it was all systems go. Until it wasn’t.
Spain soon decided that the agreement and more specifically the “Certificate of Coverage” wording - specifically from the US - was wrong for them. Their first issue was that the certificate did not specify that it covered Remote Workers. It covers workers, but Spain wanted it to MENTION “remote”. The certificate was worded in the 1980’s, well before remote work was a thing, so of course it wasn’t mentioned - but a worker is a worker, right? Spain said, “WRONG.” They started denying all of the US employees who applied as employed and submitted the CoC. It soon became widespread knowledge that in order to obtain a DNV as a US citizen, you would need to be self-employed. There was also the option that your employer could register in Spain to pay SS on your behalf, but I know of exactly 2 people ever getting their company to do this.
That was, I think, mid-2023. Around April of 2025, some things were stirring. There were mumbles and buzzes of some US citizens submitting the CoC and being approved! In various Facebook communities, we started roll calls to get anyone who had done it to tell the stories, and one of the most influential and experienced DNV consultants (the iconic Richelle De Wit) let everyone know she had spoken to UGE and they CONFIRMED THEY WERE ACCEPTING THE US CoC! We celebrated. Blog posts were penned. Social Media was ablaze. It turned out that there had been a change of leadership within UGE, and their old director left - his replacement had begun accepting the US CoC for employees. From April/May 2025 onward, there was rejoicing far and wide.
Just over 6 months later, we got word of denials happening again. Over the CoC, again. It turned out that the old Director had been brought BACK to UGE… and with him came his old grudge against the wording of the US Certificate of Coverage. At first, it was denials. Then consultants and attorneys tested the waters with methods of submittal. They were using the phrase “remote work” anywhere they could work it in, knowing that had been a sore subject in the last regime with the old/new Director. UGE eventually held a conference and confirmed that they would only accept the US CoC again if it was submitted with a new requirement: a “Letter of Displacement” from the employer. What is that, you ask? It’s a letter from your boss stating that you are BEING SENT TO WORK FROM SPAIN for strategic reasons, by your employer. So that is what we started including, and those applications were accepted. That was around December of 2025, and ever since then, US Employees with a CoC AND A LETTER OF DISPLACEMENT have been accepted. That is, at the time of this post - April of 2026. Who knows what the future holds, though. There is a new version of the US CoC (and that whole agreement in general) that was accepted but never fully implemented, and they have talked about its release for years now. I suspect whenever that comes out, it will have all of the verbiage that satisfies Spain for good. But for now, it’s just going to continue to be a point of worry with US employees.
