July 2026 DNV Updates
Well, another month, another onslaught of changes made to Spain’s Digital Nomad Visa/Residency program by the UGE - Spain’s Large Business Unit, the office where your applications and renewal applications go to hopefully be approved.
On 24 July, the UGE director Luis Esteban-Manzanares Fernández-Roldán (say that 10 times aloud fast…) was a guest at a small dinner conference in Madrid where he presented DNV information for the first half, and took questions for the second half. This was a small group of around 50 attorneys from across Spain, and a very esteemed colleague of ours was one of them. Keith Gorman, of LM Lawyers, who has been working closely with UGE and on DNV submissions for the whole duration of the residency, has tracked the changes every month of every year very closely and always makes sure to communicate with the DNV community after updates. A lot of you may already know Keith, some have even been referred to us by him for Review & Submittal services, so you know he is a very trusted and respected professional in the Digital Nomad-o-sphere. On to what he brought back for us from the conference:
Interesting points:
The largest amount of applications is currently coming in from Russian Citizens, followed by US Citizens
UGE is working on updating software, improving connectivity with the Police for TIEs, Social Security, the MoFA and the EES system.
Some TIE appointments are being allocated automatically upon approval already! This is rolling out slowly to more cities but is a big improvement and huge help.
Soon there will be new application forms to make them easier to process, as well as a one-page form for all family members.
Fraud has become a major issue, with fake documents. The National Police have also confirmed this is happening broadly in all immigration applications, with estimates of hundreds of thousands of documents being falsified.
Because of this, UGE has become very strict on documentation and insists on documents being government-issued and apostilled or, for bank documents, signed or stamped to prove authenticity. They are aware it is a problem for some countries to obtain these documents but stated they cannot adapt for every country.
In 2025, there were only 3 people at UGE working on renewals - and now, even with 12 people working on them, it is not enough, and there will be delays.
Denials continue to rise for the above reasons and also because people are using out-of-date lists, making mistakes on application forms, fee forms (tasas), missing documents, missing parts of documents, etc. Since UGE is heavily overloaded, if the application is not perfect, it has a higher chance of being directly denied.
There are huge numbers of appeals in, most with very little chance of approval. Unfortunately, many gestors or lawyers unfamiliar with the Digital Nomad program and UGE tend to offer this as a solution to a badly presented application. Remember that an appeal is ONLY won when you have proved beyond a doubt that UGE MADE AN ERROR. If the error was not theirs, the appeal will be denied. And they take 5, 6, 7+ months to finish an appeal, also. If you are denied and you can re-submit with the correct items, that is always the best route.
NOW FOR THE CHANGES:
INITIAL APPLICATIONS:
Bank Statements: This change is OFFICIAL now. They must be either
signed by the bank,
rubber-stamped by the bank, or
notarised.
Notary declarations are accepted. One bank certificate/summary can be used for all other bank statements of the same account owner and account.
Notary declarations are accepted (Spanish notary or from country of origin). One bank certificate/summary can be used for all other bank statements of the same account owner and account.
Physical Copies od Documents: UGE may request an applicant to present the original paper document to verify it is genuine. The UGE has never had to do this before but has decided it may be necessary when they doubt the authenticity of a document.
3 Years’ Experience Requirement: Despite rumours, a work contract by itself is not complete proof of that experience. A government-issued document is required, preferably a work life history, apostilled and translated. If no work history document exists from your country, notarized and then apostilled tax return documents from those 3 years must be used.
Sole Business Owners: While technically you can apply as the owner of your own business, it causes a conflict with the paperwork (work contract), implies you are at the place of business, and later creates significant issues with your taxes. Third-party contracts are required with business clients, together with all supporting documentation. Applying as a contractor or employee is the more straightforward option and recommended in all cases.
Job Titles/Remote Positions: Any job title or description related to running the production or employees of a company is considered to involve, at least in part, on-site work (which is prohibited). Senior management, HR, production, facility management, etc. all imply being where the action is, at the office. These will not be approved without extra proof that you are 100% remote, and instead an alternate title should be used. For example, the General Manager of a bakery, production plant, or store is not a "remote" job. But marketing, accounting, or software development at the same bakery could be…
Autónomo Registration (RETA): Self-employed individuals are expected to register within a very short period after approval. The Director mentioned this can technically be done within 48 hours and without the need for a Digital Certificate. Basically, when approved, register quickly and keep all appointments (citas) and receipts to show you are in the process in the event the process is drawn out by something beyond your control.
RENEWALS
If you work for the same company with the same contract as the original application, the renewal is more straightforward and much less supporting documentation is needed.
If you have changed client or employer, it is similar to an original application, needing all the documents required relating to the new business client/employer. If you are switching from autónomo to employed, that is a whole entirely new application.
TWO YEARS OF TAX RETURNS: This is a new requirement for all renewals. It’s your last 2 Spanish tax returns, the yearly one (IRPF), though if you are renewing in less than 3 years from the original you may not have 2 and that is OK. UGE said this requirement was put in place for 2 reasons:
Many people originally applied, were approved, left Spain, and remained outside the country for most of the time. These people will now not be able to renew.
To check that your gross income meets the minimum requirements. Many people applied and then reduced their income to only a few hundred euros per month. These people will now not be able to renew.
AUTÓNOMO REGISTRATION AFTER INITIAL APPROVAL:
This is a major change and was not a requirement originally. However, many people are receiving denials or requerimientos about it at renewal now. There is no exact time given for how long is considered too long, but there have been at least five reports at this time of people who took four months to register being asked to provide an explanation. Our assumption at present is that 3 or less months is being accepted, and more than that is being asked to fix it or outright denied. We have seen both cases. There are solutions to this issue, but they depend on the individual case and what has happened:
The initial registration can be backdated. Many gestors do not know how to do this, and it can take 2–3 weeks, with fines and back payments due. This is a stressful process and the approximate total of the fines and back-pay is around €4,000. You retroactively lose the Tarifa Plana (the discounted €80/month social security you paid for the first year) and have to pay back the full year of the difference between €80 and what you would have been paying in full, plus more tax and fees.
If you have documentation to show why you delayed (appointments, Social Security requirements, etc.), this can be used to justify the delay. We are assuming also if you applied in Spain and left to return to your country of origin for a little while, that proof of being out of the country until you came back and registered would also suffice.
There are other solutions depending on your situation, whether you work as an employee or contractor, whether there was a break in your application, etc. Check with your DN specialist.
SUMMARY
Always use an updated checklist (we keep ours updated, as does Keith and as do around 4-5 other DNV Specialists - if you’re with a big attorney firm, who do not concentrate only on DNV, you are taking your chances with outdated materials)
Have a consultation with an experienced Digital Nomad professional.
Don't cut corners or assume the UGE will make an exception or understand why you do not have a document. Provide exactly what is required in the format they require.
Don't apply directly as a business owner. If this is recommended to you by any professional, get a second opinion. Someone not submitting DNVs on a regular basis may think this will work.
If renewing, check when you registered as an autónomo. If it was more than 3 months after approval, check what it would take to correct the gap or assess if your situation will qualify to explain and prove instead of backdating the registration.
As always, we are here for questions of any kind - via Email at info@youbelongabroad.com, or our Facebook Page.
