Category: Immigration and Asylum

Before we begin: this is a draft, not current law

This is not yet applicable law. These are drafts of a Royal Decree that would amend Royal Decree 1155/2024. Until it is published in the Official State Gazette (BOE), the criteria may change and there is no automatic right to this regularization. Even so, the second draft already makes it possible to identify with considerable precision what the reform is intended to do and which requirements may decisively affect you.

Quick comparison: 12 important changes in the second draft compared with the first

Below are the changes that, because of their practical impact, should be on the radar of anyone who could potentially benefit (people in an irregular administrative situation, asylum or statelessness applicants, and minors in the family unit).

1) Se “separan” dos vías con más nitidez

• Route 1 (Transitional Provision 5): intended for people who submitted an application for international protection or statelessness before 1 January 2026.
• Route 2 (Transitional Provision 6): creates an extraordinary regularization route for people who were in Spain before 1 January 2026 and have not applied for asylum.

2) Nuevo requisito fuerte: 5 meses de permanencia previa para ambas vías

The draft introduces a requirement to have remained in Spain continuously during the five months preceding the application.

3) Documentación de identidad: se exige copia completa y “en vigor”

4) Incompatibility with other stay or residence procedures is tightened

4) Se endurece la “incompatibilidad” con otros trámites de estancia/residencia

5) Provisional work authorization: maintained and clarified

5) Trabajo provisional: se mantiene y se concreta mejor

• From the admission of the application for processing, the applicant is provisionally authorized to reside and work, both as an employee and on a self-employed basis, until a decision is issued.
• The notification must state that it authorizes work.
• The definitive authorization takes effect retroactively from the date of the application.
• 6) Express three-month maximum deadline and negative administrative silence

6) Plazo máximo de 3 meses y silencio negativo expresos

A maximum period of three months is established, with an adverse administrative decision deemed to apply if no decision is issued within that period.

7) Antecedentes penales: más matices, más “puertas” si el certificado no llega

• The Spanish and EU criminal-record databases will be checked by the administration.
• There may be an exemption from submitting a certificate from the third country in certain cases (for example, five years in Spain or evidence already provided without leaving the country).
• 8) Expulsion or return: closure and revocation in specific cases, where applicable

8) Expulsión/devolución: archivo y revocación en casos concretos (si aplica)

El segundo borrador no se refiere a “cualquier” expulsión o devolución. Cuando habla de “determinadas infracciones”, acota expresamente los supuestos a las infracciones del art. 53.1.a) y 53.1.b) de la Ley Orgánica 4/2000 (LOEX):

• Article 53.1.a) LOEX — Irregular stay: remaining in Spain without stay or residence authorization (for example, exceeding the authorized period of stay, or having lost or allowed the authorization to expire and continuing to remain in Spanish territory).
• Article 53.1.b) LOEX — Working without authorization, where required: carrying out employed or self-employed work without the corresponding work authorization.

In these cases, if there is an expulsion or return proceeding based on those infringements, granting the authorization would result in the proceeding being closed and, where applicable, the order being revoked.

9) Family: the logic changes, and so may the people who benefit

9) Familia: cambia la lógica (y puede cambiar a quién beneficia)

The focus is on:

• minor daughters and sons,
• adult daughters and sons with a disability requiring support or with an objective incapacity,
• cohabiting first-degree ascendants.

What “cohabiting first-degree ascendants” means (Transitional Provision 6) and when it can be used

• First-degree ascendants = mother and/or father (those legally recorded as parents).
• Cohabiting = genuine and verifiable cohabitation (normally demonstrated through a joint or historical municipal registration certificate; and, if necessary, supported by contracts or bills, health or education records showing the address, and social-services reports).
• This criterion acts as a “family anchor” for the person applying for extraordinary regularization under Transitional Provision 6 when, in addition, they meet the draft’s general requirements (presence before 1 January 2026, five months of prior residence, valid identity documents, etc.).

Clear examples (common cases)

1. You have no authorization and live with your mother or father, who have authorization (legal residence):
   • Yes: you could fit within Transitional Provision 6 by using the “cohabiting first-degree ascendant” anchor, provided that you meet the rest of the draft’s requirements.
   • Your mother or father does not need to apply for this authorization if they already have a valid residence permit.
2. You have no authorization and live with your mother and/or father, and they also have no authorization (everyone is in an irregular situation):
   • You could apply under Transitional Provision 6 using the “cohabiting ascendant” anchor, in addition to meeting the general requirements.
   • Your mother or father do not automatically obtain authorization simply because they live with you. For your ascendants to regularize their status through this route, each person would have to submit their own application and meet one of the anchors provided for the applicant (for example, work or an intention to work, vulnerability, or having minor children in their care).
     • If your mother or father lives with a minor daughter or son (for example, your younger sister or brother), they could use the minor-child anchor.
     • If they live only with adult children (with no minors and no disability or incapacity), this “family anchor” would not be enough on its own; they would need to rely on work or an intention to work, vulnerability, or another applicable case.

Important: living with your mother or father may help you fit within Transitional Provision 6; but for your ascendants to obtain authorization, each case is decided individually and must meet the draft’s requirements and anchors.

10) Menores: tramitación simultánea y orientación a estabilidad

The possibility remains of applying simultaneously for a minor’s authorization together with that of a parent or guardian, with relevant exemptions and a stronger focus on stability.

11) Procedimiento: modelo específico en sede y UTEX

A specific form, publication of information sheets and a more standardized channel are announced, with reference to UTEX for checks. UTEX is commonly used to refer to the Foreigners’ Case-Processing Unit, a technical support unit within the immigration administration responsible for verifying documents, carrying out checks and supporting case processing (for example, cross-checking databases, reviewing requirements and checking the consistency of the file).

12) Cambios “colaterales” del Reglamento

The draft also amends provisions on social-rootedness regularization, extensions and minors, affecting alternative strategies if a person does not qualify for extraordinary regularization. Examples include: (i) for social-rootedness regularization, strengthening the role of the integration report and referring to a threshold of 100% of IPREM for financial means, along with adjustments to their source; (ii) for extensions of certain regularization permits, making continuation conditional on active job-seeking or registration, with justified exceptions such as illness or disability; and (iii) for minors, setting a one-month decision period and providing for a negative administrative silence.

What changes for asylum and statelessness applicants (Transitional Provision 5)

1. Corte temporal: solicitud antes del 1/1/2026.
2. Five months of prior residence.
3. Valid identity documents.
4. Provisional work authorization from admission for processing.
5. Possible interruption or suspension of deadlines in the international-protection procedure while this route is processed.

What changes for people in an irregular administrative situation (Transitional Provision 6: “extraordinary regularization”)

Common requirements

• To be in Spain and to have been there before 1 January 2026.
• Five months of uninterrupted prior residence.
• Valid identity documents.
• No criminal record, with flexibility mechanisms.

In addition, meet at least one of these “anchors”.

1. Work or intention to work
   • Employed work: contract or contracts with a total duration of more than 90 days in one year.
   • Self-employed work: declaration of responsibility.
2. Cohabiting family unit
   • If the certificate does not arrive: after one month, the administration will request it; if it still does not arrive, a declaration of responsibility may be submitted, subject to possible subsequent review.
3. Vulnerabilidad
   • This can be demonstrated through social services and registered Third Sector organizations acting as collaborators.
   • The draft points to a presumption of vulnerability for people in an irregular administrative situation, pending practical implementation.

Impact on minors and families

• Simultaneous processing to avoid administrative gaps.
• Exemptions in certain cases (for example, birth, residence and financial means).
• A focus on stability for minors.

Regulatory changes that may affect alternative strategies

• Social-rootedness regularization: references to a 100% IPREM threshold and an integration report.
• Extensions: conditional on active job-seeking and registration, with justified exceptions.
• Minors: one-month decision period and negative administrative silence.

Practical recommendations

1. Valid identity documents: anticipate the risk and plan renewal or alternatives.
2. Proof of residence (five months): gather evidence from multiple sources.
3. Criminal records: document attempts if the country does not respond.
4. Intention to work: realistic and consistent contracts or activity plans.
5. Vulnerability: coordinate with social services and an accredited Third Sector organization.
6. Deadlines and administrative silence: monitor the three-month period and prepare appeals where appropriate.

FAQ

Until when could applications be submitted? Until 30 June 2026, according to the drafts.
Will it be possible to work while the application is processed? Yes, from admission for processing, either as an employee or on a self-employed basis.
Can an asylum applicant apply under Transitional Provision 6? No: Transitional Provision 6 requires that the person has not applied for protection; they would fall under Transitional Provision 5 if they meet its requirements.
What happens with minors? Simultaneous processing and exemptions to strengthen stability.

Conclusion

The second draft refines the design and provides greater predictability (separate routes, provisional work authorization and deadlines), but it also introduces requirements that may exclude people who cannot prove valid identity, five months of residence or an acceptable criminal-record situation. For SenValos, the focus should be on truthful information and strategic document support to prevent avoidable errors from causing missed opportunities.

You can download the PDF of the second draft by clicking this link.

The extraordinary regularization planned for 2026 could become one of the most significant measures in the field of immigration in Spain in recent years. For thousands of migrants in an irregular administrative situation, this process could open a real path to residence and work. For professionals working in social intervention, it could also become a key tool for providing better guidance, preventing mistakes and accompanying applications with greater confidence.

At SenValos, we have been sharing information in recent months about earlier drafts of this future regulation, precisely because we understood the enormous importance it could have for many people and families. In this article, we aim to bring together, clearly and systematically, the latest information currently available, based on the most recent draft that has emerged and the current institutional context. Everything suggests that the next step should be the approval and publication of the final text in the coming days, which will make it possible to know all the details of the new regulation accurately and publish them with the precision that such a sensitive issue deserves.

It is important to be clear from the outset: we are still talking about a planned process, not a regulation that has already been fully finalised and published with all its definitive effects. This requires us to act cautiously. But it also means being prepared, because if approval comes soon, there may be little time to respond properly.

What is the extraordinary regularization of 2026 and why is it so important?

The central idea behind this extraordinary regularization is to offer a legal solution to foreign nationals who already live in Spain and who, for different reasons, have not been able to access an ordinary residence permit. This is not simply a technical adjustment. If approved in terms close to the latest known draft, it could have a very significant impact on the daily lives of thousands of people.

The purpose seems clear: to reduce prolonged irregular situations, facilitate social and labour integration, and recognise a reality that already exists in neighbourhoods, schools, informal jobs and community networks throughout the country. In other words, this is not about attracting new migration, but about responding to people who are already here, who are already part of our society and who need a stable legal pathway.

The two main pathways provided for in the latest draft

According to the latest known draft, the future extraordinary regularization would be structured around two main pathways.

On the one hand, there would be a specific pathway for people who applied for international protection or asylum before 1 January 2026 and whose application or appeal has not yet been resolved. On the other, a new extraordinary roots-based residence pathway would be created for people who were already in Spain before 1 January 2026 and had not applied for asylum.

This distinction is very important. Until now, many people have been trapped in a kind of limbo: they could neither regularize their situation easily through the ordinary pathways nor find a clear solution after long periods of waiting. The new design seeks to respond precisely to this reality.

The most significant new feature: a provisional permit to reside and work

One of the most important aspects of the draft is that the mere admission for processing of an application could entail a provisional residence and work permit, both as an employee and on a self-employed basis, while the application is being decided.

This point could make an enormous difference. In practice, it would mean that people would not have to wait until the end of the procedure to begin leaving the informal economy or to access formal employment. For many families, this could translate into something as basic and decisive as stability, legal income, social-security contributions, safer access to rental housing and less exposure to labour abuse.

The draft also provides for a maximum decision period of three months. We will have to see whether this period remains in the final text and, above all, how it is applied in administrative practice. On paper, however, it is a significant provision.

Who could apply for extraordinary roots-based residence?

According to the draft, the new extraordinary roots-based residence pathway would be intended for foreign nationals who were in Spain before 1 January 2026, who do not hold a stay or residence permit and who are not processing another ordinary regularization pathway.

In addition, the person would have to prove certain basic requirements. These would presumably include documentary identity, no relevant criminal record and continuous residence in Spain for a specific period before the application.

Alongside these general requirements, the draft proposes that the applicant would have to demonstrate at least one of the following situations.

First, having worked in Spain or intending to work, whether through a job offer, an employment contract or a self-employed activity plan.

Second, living in Spain with their family unit, particularly where there are minor children, dependent descendants with disabilities or first-degree ascendants.

Third, being in a situation of vulnerability certified by competent organisations.

This last point could be especially important for social work and third-sector organisations. Not every application can be supported solely by contracts or employment evidence. Many people enter these procedures from situations of housing exclusion, severe hardship, violence, excessive family responsibilities or social vulnerability. The fact that vulnerability may carry independent weight in the future regulation is highly relevant.

What could happen to asylum applicants?

The second major pathway envisaged in the draft concerns people who applied for international protection before 1 January 2026. This is a particularly important group because, in recent years, many people have remained for long periods within the asylum system, without a definitive solution and unsure about which strategy to follow.

The draft appears to open a specific route to regularization for them, also with provisional authorisation to work from the moment the application is admitted for processing. It also provides that submitting this application may suspend certain deadlines within the international-protection procedure.

This calls for caution. Not all cases are the same. For some people this pathway may be appropriate, while for others it may not be the best option, depending on their file, pending appeals, family situation or possibilities through other immigration routes. That is precisely why technical and social support will remain essential.

The importance of the family unit and the protection of children

Another relevant element of the draft is that it appears to pay particular attention to the family unit. It envisages the possibility of processing linked permits for minor children, as well as certain flexibilities where minors or people with disabilities who need support are involved.

This is highly valuable. Regularization that resolves only the situation of one adult while leaving the rest of the family unit in uncertainty would be insufficient. If the new regulation consolidates this more family-centred and socially aware approach, it could prevent many unfair situations.

How could the application be submitted?

According to the information that has gradually become available, several submission channels could be enabled, including not only the usual administrative routes but also specific points at post offices or Social Security offices.

On this point, we should be very clear. More service counters do not mean that the procedure will be easy. On the contrary, an extraordinary regularization application may require evidence of residence, a criminal-record check, proof of identity, an assessment of vulnerability, family documentation and a strategic assessment of the case. Submitting an application incorrectly can lead to requests for additional documents, delays, closure of the file or even refusal.

Therefore, although the future regulation may have a more accessible approach, it will remain very important to have appropriate support, especially in the most complex cases.

What do we know and what do we still not know?

We know considerably more than we did a few months ago, but we still do not know everything. That is the reality. The latest draft allows us to anticipate the general structure of the process, the profiles that could benefit and several of its most relevant effects. However, until the final text is approved and published, it is impossible to state with complete certainty what the final wording will be, which exact documents will be required or how some key requirements will be interpreted.

For this reason, SenValos has sought to do something very specific: offer an understandable, serious and useful explanation of the latest information available, without selling false certainties or creating unrealistic expectations. That is also why we believe the decisive moment is now very close. If the final regulation is approved and published in the coming days, we will finally be able to analyse the definitive text, study its details article by article and explain precisely who can benefit, how to apply and which safeguards should be considered.

What should be done now?

For migrants who could benefit from this regularization, now is the time to begin organising the documents available: evidence of presence in Spain, a passport or identity document, proof of cohabitation, family documents, social reports, employment contracts or promises of employment and any other document that helps demonstrate roots, vulnerability or life history.

For professionals in social work, mediation, reception or community intervention, now is the time to identify potential profiles, review cases in good time and avoid improvisation when the regulation is published.

And for organisations such as SenValos, this process once again confirms something essential: clear, rigorous and understandable information can change lives. In immigration matters, bad information can undermine an application. Good guidance, by contrast, can open up a real opportunity.

As soon as we know the definitive text of the 2026 extraordinary regularization in Spain, we will publish an updated analysis with all the practical details of the new regulation.

Royal Decree 180/2026 of 11 March was published in the BOE on 12 March 2026 and entered into force on 13 March 2026. Its purpose is to regulate the procedure for recognising the right to health protection and healthcare financed through public funds for foreign nationals who are in Spain without legal residence, and also to extend coverage to certain Spanish nationals by origin who live abroad during temporary stays in Spain.

The news is important, but it needs to be explained properly. We are not looking at a magic formula that removes every administrative procedure overnight. This regulation does something different and highly relevant: it organises the procedure, reduces bureaucratic barriers and strengthens the consistency of this right throughout Spain, after years in which practical implementation varied depending on the territory. The BOE itself expressly acknowledges that, following the 2018 state reform, differences in implementation and additional administrative obstacles persisted for many migrants.

Put clearly: the new royal decree reinforces the idea that health protection must not be emptied of substance for administrative reasons, especially when a person lives in Spain, has no legal residence and also lacks any other mandatory public healthcare coverage or coverage that can be exported from another country. This is the core of the regulation and also why this change may have a very real impact on the daily lives of many people.

What exactly does Royal Decree 180/2026 regulate

Article 1 of the royal decree establishes that its purpose is to regulate the procedure for recognising the right to health protection and healthcare financed through public funds for foreign nationals who, while in Spain, do not have legal residence in Spanish territory, as well as the way of proving the requirements set out in Law 16/2003. In addition, the preamble makes clear that this regulatory development is approved without requiring a general minimum period of residence, precisely to strengthen the consistent effectiveness of this right.

This clarification matters greatly. For years, many migrants encountered different interpretations, changing documentary requirements or unclear procedures. With Royal Decree 180/2026, the State is trying to close part of this uncertainty and establish more uniform rules. It does not solve every problem, but it does provide a stronger basis for demanding that the right be applied in practice and not only in theory.

What changes in practice for foreign nationals without legal residence

The main operational change is the responsible declaration. The applicant must submit it to the competent administration of their autonomous community or to the National Institute of Health Management. In that declaration, among other matters, they state that they do not have other public healthcare coverage through a mandatory route, that they cannot export this right from another country, that there is no third party obliged to pay and that they do not hold a valid stay visa, registration in the Register of Union Citizens or foreign national identity card.

The second major new feature is that the regulation does not merely recognise the right at the end of the procedure; it also provides for a provisional document certifying it from the moment the application is submitted. This makes it possible to access healthcare provision financed through public funds on a provisional basis while the case is being decided. In practice, this measure may prevent a person from being left without protection for weeks or months because of administrative delays.

The third important issue is how habitual residence in Spain can be evidenced. The municipal register remains very useful, but it is not the only option. The royal decree accepts other forms of evidence, such as school enrolment certificates, documents issued by social services, certificates of visits by social-work professionals from public-interest NGOs, utility bills, consular registration, registration certificates or certificates from public migration centres. This is especially valuable for people who have greater difficulty registering with a municipality or maintaining stable administrative documentation.

The time limit is also important. The decision must be notified within a maximum of three months and, if the application was submitted by the person concerned and no response is issued within that period, positive administrative silence applies. In addition, once the right has been recognised, the supporting document does not expire and remains valid until the person can access healthcare through another route.

Which groups receive special protection

The royal decree expressly strengthens care for several vulnerable groups. These include minors, pregnant women, applicants for international protection or stateless-person status, people with temporary protection, victims of gender-based violence, victims of trafficking, victims of sexual violence and people affected by notifiable diseases. It also expressly provides for foreign women without legal residence to access voluntary termination of pregnancy in accordance with the legislation in force.

This point is particularly relevant in social and community work, because very often the greatest vulnerability lies not only in a lack of documentation but in the combination of factors that intensify exclusion: childhood, pregnancy, violence, exploitation or language and administrative barriers. The new regulation does not eliminate these risks, but it does strengthen the framework so that healthcare is not blocked by restrictive interpretations.

What was the situation in Galicia before this royal decree

In Galicia, this change is not starting from zero. Galicia’s Health Law 8/2008 already recognises that the right to health protection and healthcare financed through public funds, with universal coverage, is guaranteed to everyone residing in Galician municipalities. The law also adds that this protection is guaranteed to minors and pregnant women who are not included in this general residence regime.

However, this general wording coexisted for years with a more complex practice for foreign nationals in an irregular administrative situation. After the state restrictions introduced in 2012, Galicia published the Resolution of 31 August 2012, which circulated the instruction on providing healthcare to people without recognised insured or beneficiary status through the INSS or ISM. In that context, the Xunta promoted the Galician public-health social-protection programme, designed for those who fell outside ordinary state recognition and could not use other routes.

That Galician instruction already provided that foreign nationals who were not registered or authorised as residents in Spain, who were in Galicia, had no other public coverage and could not export it from their country of origin, could receive healthcare in several forms. These included emergency care for serious illness or accident, pregnancy, childbirth and postpartum care, care for minors under 18 and situations linked to international protection or trafficking.

Sergas’s previous practice: a system of its own with differentiated categories

The Sergas FAQ manual, updated in February 2024, explained that in Galicia health protection and healthcare for these people were processed through three routes or arrangements: the Galician public-health social-protection programme, the arrangement for foreign minors and the arrangement for pregnant foreign women. That document also stated that the Galician programme provided access to the basic, supplementary and ancillary common healthcare package, as well as to Galicia’s complementary package where applicable.

The same manual recalled that, following Galicia’s subsequent adaptation to Royal Decree-Law 7/2018, the minimum registration period required was reduced: registration in a Galician municipality and proof of residence in Spain for at least 90 days became sufficient; the income requirement was also removed, a 40% pharmaceutical contribution was set and the requirement to renew participation in the programme every two years was maintained. In other words, Galicia had already developed its own response, but it continued to operate through a specific autonomous-community scheme with separate requirements and administrative channels.

What changes now in Galicia with Royal Decree 180/2026

This is the key point of the article. The new state royal decree does not simply erase everything that came before, but it does introduce a more protective common framework that Galicia must apply. This new state framework is based on a different logic from some of the filters that had operated in regional practice: it does not require a general minimum period of residence, allows habitual residence to be evidenced through more flexible routes, requires a provisional document to be provided from the time of application and establishes positive administrative silence if no decision is issued within the time limit.

For that reason, in Galicia, the entry into force of Royal Decree 180/2026 should be understood as strengthening the right and as a call to review previous practice wherever it is more restrictive than the new state regulation. Put simply: if the Galician system had been operating through special programmes or arrangements with specific filters, those channels must now be interpreted in line with a more protective state standard. If a more restrictive practice conflicts with the new state rule, it is reasonable to demand application of the more protective regime established by the royal decree.

In addition, Sergas’s official documentation that remains accessible to the public still reflects this previous model of arrangements and the Galician programme, based on the 2024 update. This suggests that Galicia may need operational and communications adjustments so that the system’s actual functioning is fully aligned with the new state regulation.

What should be explained clearly to migrants in Galicia

The useful, clear and responsible message would be this: yes, the new royal decree significantly improves access to public healthcare for foreign nationals without legal residence, including in Galicia, but it remains important to submit the application correctly and keep the documentation filed. It is not enough to repeat that “there is already universal healthcare” if the person then does not know what to request, which documents to bring or what to do if obstacles are placed in their way.

In Galicia, it is important to act carefully. First, gather the identity documentation available and any proof of habitual residence in Spain or Galicia. Second, if there is difficulty registering with a municipality, remember that the royal decree allows other forms of evidence. Third, from the moment the application is submitted, request the provisional supporting document, because it is essential for accessing healthcare provision provisionally while the case is decided. Fourth, if there is no response within three months, administrative silence is positive when the application was submitted by the person concerned.

It is also important to bear in mind that some people from certain countries may need to prove that they cannot export healthcare rights from their country of origin or provenance. This detail may be decisive in some cases and therefore deserves appropriate support to avoid mistakes that could later delay effective access to the system.

What this reform means at its core

Beyond the procedure, Royal Decree 180/2026 has clear political and social significance. It recognises that public health cannot be based on a model of healthcare exclusion for people who already live in our country and form part of the community, even when their administrative situation has not been regularised. It also recognises that territorial inequality and bureaucratic barriers ultimately affect not only migrants but also the coherence of the public health system itself.

In a territory such as Galicia, where prior regional tools already existed, the challenge now is not to start from scratch but to adapt practice so that the right can be exercised with greater clarity, less arbitrariness and fewer obstacles. This will be the real test of the reform: not only what the BOE says, but how people are treated at the health centre, how applications are processed and how officials respond when someone needs care and does not fit easily into traditional administrative channels.

Conclusions

At ONGD SenValos, we welcome any regulatory progress that helps make the right to health effective for migrants and other vulnerable groups. The publication of Royal Decree 180/2026 moves in that direction: it provides greater legal certainty, reduces barriers and may help ensure that access to public healthcare depends less on the territory, the discretion of each office or each person’s individual ability to face complex procedures alone.

At the same time, we must be rigorous. The regulatory change is important, but its real effectiveness will depend on how it is applied in each autonomous community and, in Galicia’s case, on how Sergas’s previous practice is adapted to the new state framework. It will therefore be essential to follow closely the administrative instructions, criteria and updates published over the coming weeks or months.

If you are a migrant and have questions about how to apply for this right in Galicia, or if you are part of a social organisation, community service or professional team supporting migrants, seeking guidance in good time can prevent many obstacles. Understanding the required documentation, knowing what to do if the municipal register is not up to date or identifying when the provisional document must be issued can make the difference between having a right recognised only on paper and being able to exercise it in practice.

In recent days, a very significant change has become known for many Venezuelan people in Spain: the Government will stop systematically granting residence permits on humanitarian grounds which, since 2018, had served as a common route for people who applied for asylum and were denied. According to the published information, this change will start to apply from June 2026.

However, it is important to state this precisely. We are not looking at the disappearance of Article 37.b of the Asylum Law or the repeal of the humanitarian-grounds regime in the Immigration Regulations. The regulations currently in force still provide for temporary residence authorisation on humanitarian grounds for people whom the Interior Ministry authorises to remain in Spain under Articles 37.b) and 46.3 of Law 12/2009, and the Ministry’s official website continues to describe this authorisation as temporary residence renewable for one-year periods. What has been announced is, for now, a change in administrative criteria and general practice, not a formal suppression of that legal basis published in the BOE.

That is why the question is not only what will change for those who arrive from now on, but also what may happen to Venezuelan people who are already in Spain, who have already applied for asylum, who already have humanitarian grounds or who are trying to find another route to regularisation. And we must speak plainly here: not all situations are the same.

1. Venezuelan people whose asylum application is still being processed

If a Venezuelan person’s asylum application is still awaiting a decision, they remain an applicant for international protection for the time being. This matters greatly because the Immigration Regulations state that a person cannot apply for arraigo while they remain an applicant for international protection, nor, as a general rule, is the time spent in Spain during the processing of that application counted until a final decision has been issued through the administrative process and, where applicable, the courts.

This means it is not correct to say that anyone with an asylum application pending will automatically have a route through arraigo if they are later refused. It will depend on the procedural stage, the date of the final decision and the specific requirements of each route.

That said, there is an important nuance here. In January, the Government announced an extraordinary regularisation scheme for foreign nationals already living in Spain. According to official information released by La Moncloa, those who can prove at least five months of residence before 31 December 2025 and have no criminal record will be able to benefit from it; people who had submitted their application for international protection before that same date will also be eligible. The Executive also explained that admission for processing would allow people to work provisionally and that minor children in Spain could be regularised at the same time.

Therefore, for some Venezuelan people with an asylum application pending, the extraordinary regularisation could become the most important route out in 2026, provided it is ultimately approved and its final terms published. As of 5 April 2026, the Government itself continues to describe the process as pending final approval, although it maintains that its timetable is still moving forward.

2. Venezuelan people whose asylum application has already been refused

Here too, it is important to be very precise. The regulations currently in force include a fifth transitional provision allowing certain people who became irregular after a final decision refusing or dismissing their application for international protection to apply for residence authorisation through arraigo, but under the transitional regime currently in force this route applies only to those who had entered that situation before 20 May 2025. In addition, that provision is not valid for everyone or immediately: it requires the person to have remained in Spain in an irregular situation for at least six months before submitting the application.

However, alongside this transitional provision in the regulations currently in force, the drafts of the 2026 extraordinary regularisation scheme are considering another, separate fifth transitional provision specifically intended for applicants for international protection. According to the publicly available information on this process, this future route could benefit those who had submitted their asylum application before 1 January 2026, even if they did not fit within the fifth transitional provision currently in force. For many Venezuelan people this would be especially relevant, because it would open an extraordinary regularisation route linked to their status as asylum applicants, without initially requiring them to meet the same criteria that the current transitional provision requires for final refusals issued before 20 May 2025. Put simply: if that draft is approved on similar terms, it could offer an important route out for many Venezuelan asylum applicants who would currently fall outside the fifth transitional provision of the regulations in force.

3. People who have already been granted humanitarian grounds

This is one of the most sensitive points. People who already hold a residence authorisation on humanitarian grounds are still currently covered by a valid authorisation, with permission to reside and work, and the Ministry’s official information indicates that these authorisations and their extensions are valid for one year.

The problem arises when considering the move to a more stable ordinary authorisation. Here we need to correct an idea that is being repeated frequently: the regulations currently in force do not allow an application to modify under Article 191 from residence authorisations for exceptional circumstances under Article 128.1, which precisely include residence authorisations on humanitarian grounds linked to the Asylum Law. Article 191.7 of the Regulations expressly excludes it.

Put simply: having humanitarian grounds does not mean that there is currently a clear, open route to automatically “modify” it into ordinary residence and work authorisation through this pathway. This is precisely one of the major legal problems at present.

4. The group facing the greatest uncertainty: people with humanitarian grounds who are not working and depend on annual renewals

This is probably the most exposed group. Many Venezuelan people have been in Spain for some time, have been chaining together annual extensions of their humanitarian authorisation and have not been able to secure a more stable situation. In some cases they do not have a contract; in others they work in precarious conditions; in others, they simply do not fit the ordinary routes provided for by the regulations.

At present, the transition applicable to all these people is not expressly defined with the degree of detail that would be desirable, making it premature to say that they will all end up in an irregular situation. The most accurate statement is that there is a real risk of legal uncertainty for those who depended on a cycle of renewals and do not have easy access to other routes.

Nor does the second-chance arraigo appear, in principle, to resolve this problem in most cases, because this form of arraigo requires having held a residence authorisation that was not granted on the basis of exceptional circumstances. And humanitarian grounds are precisely an authorisation based on exceptional circumstances.

5. Venezuelan people arriving from now on

For those arriving in Spain from now on, the situation will be more difficult. If the practice that had generally allowed humanitarian grounds to be granted after an asylum refusal stops being applied, there will no longer be that almost automatic expectation that operated in practice for many Venezuelan people for years. This will mean looking at other regularisation routes, which tend to be slower, more demanding and more uncertain.

In addition, ordinary arraigo routes generally require two years of continuous residence and, for those who have applied for international protection, the time taken to process the asylum application is not counted until a final decision has been issued. This can greatly extend the actual time needed to access a residence authorisation through arraigo.

What this situation reveals

It is important not to lose sight of the human context. UNHCR continues to describe the situation in Venezuela as a displacement crisis of enormous scale and reports that around 7.9 million people have left the country in search of protection and a better life. This context helps explain why Spain opened a humanitarian pathway in 2018 that has benefited hundreds of thousands of Venezuelan people.

For that reason, the debate should not be limited to whether or not a procedure changes. The underlying question is different: if a route that had worked in practice as a mass response to a prolonged crisis is reduced, the alternatives must be clear, accessible and offer genuine legal certainty. When that does not happen, the risk is not only administrative. The risk is pushing many people and families into another period of uncertainty.

What should be done now

The most important thing at this point is not to act on rumours. Each case requires an individual review: date of entry into Spain, status of the asylum case, validity of the current authorisation, criminal record, registration with the municipality, family ties, work and whether or not the person may fit within the extraordinary regularisation scheme if it is ultimately approved.

It is also advisable to gather as soon as possible all documentation that may prove useful: municipal registration, passport, asylum decisions, cards, employment history, contracts, criminal record certificates, social services reports, medical or school documentation for minors and any evidence of residence in Spain. In 2026, the difference between being able to pursue a regularisation route and being left out may literally lie in how each date and circumstance is evidenced.

A final thought

As of 5 April 2026, the most honest thing to say is this: yes, the situation is becoming tougher for many Venezuelan people, but not everything is closed and not everything is lost. Some situations have a way forward, others involve considerable uncertainty and others depend on the extraordinary regularisation scheme ultimately being approved on the terms announced.

At a time like this, legal prudence is not alarmism. It is responsibility.

The 2026 extraordinary regularisation does not only affect migrants and asylum seekers. It also affects, and significantly so, companies, self-employed employers and organisations that already have or want to have foreign staff on their workforce.
https://www.inclusion.gob.es/regularizacion

For a company, this process can solve a very specific problem: how to provide legal continuity to the work of people who are already integrated into the organisation, but whose administrative situation was fragile, uncertain or directly irregular. This is especially relevant in cases involving asylum seekers whose application or appeal has not yet been resolved, and people who were already working or could work but whose continuity raised operational and compliance concerns. The royal decree follows this logic: integrating people who are already in Spain, reducing the informal economy, strengthening contributions and providing stability to the labour market.

Why this regularisation matters to companies

The regulation explains the measure’s economic and labour approach quite clearly. The Government justifies the reform because the full incorporation of foreign nationals into the administrative and economic system strengthens Social Security, improves tax collection, reduces the shadow economy and promotes a more transparent and efficient labour market. It also links the measure to the need to fill vacancies in sectors facing recruitment difficulties.

In business terms, this means three things:

1. It helps stabilise the workforce

If a person is already working or is a genuine candidate for joining the company, this route can turn a precarious or uncertain situation into an employment relationship with greater legal certainty.

2. It reduces operational risk

When the authorisation to work depends on a lengthy asylum procedure, a renewal or a pending appeal, the company operates under uncertainty. This regularisation creates a specific route for bringing that situation into order.

3. It makes it easier to retain trained talent

Many companies have invested time in training people who already know the job, the workplace language and the internal dynamics. This process can prevent that investment from being lost.

Who may be interested in this procedure from a business perspective

The extraordinary regularisation is aimed at two broad groups:

1. People seeking international protection

Those who submitted their application for international protection before 1 January 2026 may apply. The royal decree itself adds something crucial for companies: this route also covers people whose application or appeal has not yet been resolved.

This is precisely the situation in many workforces where the company has a person who:

• applied for asylum some time ago,
• may have worked with asylum documentation,
• lodged an appeal,
• and remains in administrative limbo.

For these cases, the new 20th Additional Provision creates a specific route based on arraigo.

2. People in an irregular administrative situation

The 21st Additional Provision is intended for people who were in Spain before 1 January 2026 and who can also prove one of the following three elements:

• having worked or intending to work,
• living with their family unit,
• or being in a situation of vulnerability.

For companies, the first case is particularly relevant: having worked or submitting a work commitment. The EX-32 form expressly states that this route may be evidenced with a copy of the contract, documentation of work already carried out or a job offer that must be formalised during the provisional permit recognised while the application is being processed.
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf

The key point for employers: when can the person work?

This is the key fact.

The regulation establishes that, both under the route for applicants for international protection and under the extraordinary arraigo route, from the notification that processing of the application has begun, the person is provisionally authorised to reside and work as an employee or self-employed person until the procedure is resolved. The maximum resolution period is three months.

In addition, the royal decree specifies that:

• the provisional authorisation to work must appear in the notification that processing has begun;
• if the application is refused, the provisional authorisation automatically loses its validity;
• and if the person was working as an employee under that provisional authorisation, they must immediately inform the company of the outcome of the decision.

What this means in practice

For a company, the decisive document is not a future promise or a simple draft. It is the notification that processing has begun and that records the provisional authorisation to work.

That distinction is fundamental:

• It is not enough for the person to say that they have already submitted the application.
• The prepared form is not enough.
• What allows the person to work is the administrative notification that recognises that provisional authorisation.

How a company benefits when the person was already working with asylum documentation or an appeal pending

This is probably the most useful scenario to explain to employers.

Typical case

A company has an employee who applied for asylum some time ago. Their international protection documents allowed them to work. A refusal or a complex situation then arose, and there is now an appeal, delays or uncertainty.

The new regulation responds precisely to this gap. The royal decree states that the new DA20 allows applicants for international protection whose application or appeal has not been resolved to access a temporary residence authorisation based on arraigo.

What it solves for the company

Above all, it solves four problems:

1. It provides an alternative route to stability

The company no longer depends solely on the uncertain progress of the asylum case.

2. It reduces the risk of losing someone who is already integrated

If the person knows the job and the organisation wants to retain them, this regularisation can help ensure continuity.

3. It prevents unnecessary interruptions

From the notification that processing has begun, the person is provisionally authorised to work.

4. It turns a provisional situation into clearer work authorisation

The authorisation granted is valid for one year and allows the person to reside and work as an employee or self-employed person, anywhere in Spanish territory, in any occupation or sector.

A note of caution

This needs to be very clear: it does not mean that the company can relax its document checks. Quite the opposite. The company must check at all times which document authorises the person to work:

• the asylum document, if it is still valid;
• or, where applicable, the notification that regularisation processing has begun and includes provisional authorisation;
• and subsequently, the authorisation granted and the corresponding TIE.

What the company should and should not do

What the company can do

Provide documentary support

If the person uses the extraordinary arraigo route on a work-related basis, the company can provide:

• a contract,
• a job offer or work commitment,
• or employment documentation that helps prove previous activity.

Prepare the employment so it can be formalised during the provisional permit

The EX-32 form specifically reflects this approach: there must be an offer that is formalised during the provisional processing period.
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf

Register the person with Social Security when appropriate

In subsequent modification procedures, the effectiveness of the authorisation is conditional on registration with Social Security within one month of notification.

Submit the subsequent modification

When the time comes to modify the temporary authorisation into residence and work authorisation, the procedure may be submitted by the foreign national or the employer.

What the company should not do

Do not replace the applicant

The initial application for this regularisation must be made by the foreign national, personally or through a representative. The information sheets identify the foreign national or their representative as the person entitled to submit it.

Do not hire based solely on expectations

Until there is a valid document authorising work, the company must not act as though authorisation already existed.

Do not confuse “submission” with “authorisation”

Submitting the application does not automatically amount to permission to work. What matters is the notification that processing has begun and expressly recognises that provisional authorisation.

Which companies can benefit most?

This procedure will be especially useful for:

Hospitality and catering

Sectors with high staff turnover and difficulties filling positions where people are already integrated into the workforce.

Care and home support

Cases in which continuity and trust are decisive.

Agriculture, logistics, cleaning and ancillary services

Sectors where the company often already knows the person and wants to regularise their incorporation on a stable basis.

SMEs and self-employed employers

Especially when they already have someone with genuine roots in Spain and want to formalise or maintain the employment relationship with less uncertainty.

What happens after the initial authorisation?

The authorisation granted is valid for one year and allows the person to work anywhere in Spain, in any occupation or sector.

During the two months before it expires, the person may apply for a modification under Article 191 of the Regulation. They may also submit it within the following three months, although there is a risk of a penalty for filing late. Submission extends the validity of the previous authorisation until a decision is made.

For companies, this is important because the extraordinary regularisation is not just a short-term patch. If managed properly, it can become the gateway to a more stable residence and work situation.

At this modification stage, the employer becomes fully involved

The modification information sheet states:

• the person entitled to submit the application may be the foreign national or the employer;
• the employer pays fee 790-062 for the initial employee work authorisation;
  https://sede.administracionespublicas.gob.es/pagina/index/directorio/tasa062
• the worker pays fee 790-052;
  https://sede.administracionespublicas.gob.es/pagina/index/directorio/tasa052
• the resulting authorisation is valid for one year and is considered an initial residence and work authorisation;
• its effectiveness is conditional on registration with Social Security within one month.

Practical recommendations for companies

1. Review each case individually

Not every foreign national fits this regularisation. It is necessary to distinguish between:

• asylum seekers with a pending case or appeal,
• people in an irregular situation with a work-based route,
• and other profiles that may have a better route available.

2. Always request a copy of the authorising documentation

In particular:

• current asylum document, if it remains the basis,
• notification that processing has begun with provisional authorisation,
• favourable decision,
• TIE when it is issued.

3. Document the job offer or work commitment properly

In DA21 cases based on employment, the offer should be genuine, clear and consistent with the position.

4. Prepare the subsequent modification in good time

The company may take part later in the modification to residence and work authorisation. It is not advisable to wait until the last minute.

5. Coordinate immigration, employment and compliance matters

This regularisation has implications for hiring, Social Security, risk prevention and the internal filing of documents. It should not be viewed solely as an immigration procedure.

FAQ for companies and employers

Can the company submit the extraordinary regularisation application directly?

Not as a general rule for the initial application. Standing to apply belongs to the foreign national personally or to their representative.

Can the company help?

Yes. It can support the process with a job offer or work commitment, employment documentation and assistance during the subsequent modification stage.

Can an asylum seeker with a pending appeal apply?

Yes. The royal decree expressly states that this route covers people whose application or appeal has not been resolved.

Can the person continue working while the application is being decided?

Yes, but only from the notification that processing has begun and that recognises the provisional authorisation to work.

Does simply submitting the application already allow the company to hire?

It should not be considered valid on that basis alone. The decisive document is the administrative notification stating the provisional authorisation to work.

Does the final authorisation limit the sector, occupation or territory?

No. The authorisation granted allows the person to work as an employee or self-employed person anywhere in Spanish territory, in any occupation or sector of activity.

How long does the authorisation granted last?

One year. It is considered a temporary residence authorisation for exceptional circumstances on the basis of arraigo.

What happens if the application is refused?

The provisional authorisation to work automatically loses its validity. If the person was working as an employee, they must immediately inform the company of the outcome of the decision.

Does the company pay any fee?

At the subsequent stage of modifying the authorisation to residence and employment, yes. Fee 790-062 is paid by the employer, while fee 790-052 is paid by the foreign worker.
https://sede.administracionespublicas.gob.es/pagina/index/directorio/tasa062
https://sede.administracionespublicas.gob.es/pagina/index/directorio/tasa052

When must the person be registered with Social Security?

During the subsequent modification, within one month of notification that the authorisation has been granted, because its effectiveness is conditional on that registration.

Can this regularisation help retain staff?

Yes, and this is one of its clearest effects. It is a route for consolidating existing or imminent employment relationships with people who are already in Spain and already have genuine roots there. This is a reasonable conclusion based on the stated purpose of the regulation and the provisional authorisation to work during processing.

Conclusion

For companies, the 2026 extraordinary regularisation is not an unrelated matter. It is a practical tool for putting real employment situations that already exist in the daily life of many organisations in order.

Its value is particularly high in three scenarios:

• when the company already has an asylum seeker with a pending application or appeal;
• when it wants to turn a fragile relationship into employment backed by legal certainty;
• and when it needs to retain staff who already know the job and fit into the organisation.

The central idea is simple: this regularisation can turn uncertainty into continuity. But only if it is managed with rigorous documentation and without confusing expectations with effective authorisations.

The 2026 extraordinary regularisation process is already under way, and town halls will have an important role to play. Not because they decide on applications—that falls under the responsibility of the State Administration—but because many people will first go to their town hall for information, to register as residents, to prove cohabitation, to provide evidence of their daughters’ and sons’ schooling, or to seek social support.

For municipal staff, this means something very specific: they will need to provide clear information, identify correctly who may qualify for the process, give guidance on the basic documentation, and prevent mistakes that could delay or complicate the application. The Royal Decree was published on 15 April 2026. The online route opened on 16 April. The in-person route begins on 20 April, although appointments also open from 16 April. The general application deadline is 30 June.

What town hall staff need to know first

This regularisation is intended for two very specific groups:

1. People seeking international protection who submitted their application before 1 January 2026.
2. People in an irregular administrative situation who arrived in Spain before 1 January 2026.

In addition, there are two general requirements for both routes:

• To be in Spain before 1 January 2026 and to prove continuous residence of at least five months at the time of application.
• To have no criminal record and not pose a threat to public order, public security or public health.

Municipal services should convey a clear message here: this is not a process open to every foreign national, but rather to people who fall within these specific cases. In fact, the official information states that it is not intended for people who already hold a valid authorisation or are renewing one, for people covered by temporary protection because of Ukraine, or for stateless people, who have their own procedures.

What role do town halls play in this process?

The town hall does not grant the authorisation, but it can be decisive in ensuring that people arrive at the procedure well prepared. In practice, its role can be focused on six functions:

1. Provide correct initial guidance

Many people will not know whether they should use the asylum route or the irregular-status route. This is where the first municipal screening is essential.

2. Help identify evidence of residence

The person will need to show that they were in Spain before 1 January 2026 and have remained here for at least five consecutive months before submitting the application. The official information accepts any legally valid evidence that makes it possible to identify the person.

At this point, town halls are often key because useful municipal documents may exist, such as registration certificates, reports or administrative records, depending on the case.

3. Provide documentation on cohabitation or schooling

For the extraordinary regularisation route based on family unity, the family relationship and cohabitation will need to be proved. Where there are minors, evidence of their schooling may also be required.

4. Activate social services when there is vulnerability

In cases involving vulnerability, the information sheet requires a certificate from the competent authority or a collaborating organisation proving that situation. The EX-32 form itself states that this certificate may come from the competent bodies responsible for social assistance or from Third Sector organisations registered in the Electronic Register of Immigration Collaborators.

This means that municipal social services may have an important role, provided that they are the competent body in that territory.

5. Explain the submission channels clearly

Many people will go to the town hall simply to ask “where do I submit it?”. It is worth having a very clear answer to that question.

6. Refer cases when they are complex

If there are identity problems, criminal-record issues in the country of origin, a complex family situation or doubts about other, more suitable regularisation routes, referring the person to specialist advice or collaborating organisations will be the most prudent option.

Requirements for people seeking asylum

People seeking international protection may qualify if their application was submitted before 1 January 2026. For this group, the basic documentation includes:

• Official EX-31 form.
• A complete copy of the passport, even if expired, or a registration certificate or travel document recognised in Spain.
• A criminal-record certificate from the country or countries where the person lived during the five years before entering Spain.
• A document proving that the application for international protection was submitted before 1 January 2026.
• A document proving residence in Spain for at least five consecutive months before the application.
• Proof of payment of the fee.

For municipal staff, the most important point is this: if the person had already applied for asylum before that date, they do not also have to prove employment, family ties or vulnerability. That additional requirement applies to the irregular-status route, not to the specific route for applicants for international protection. This makes initial guidance much easier.

Requirements for people in an irregular administrative situation

People in an irregular situation follow the route under Additional Provision 21, using form EX-32. In addition to the general requirements, they must prove at least one of the following three situations:

• To have worked as an employee or self-employed person during their residence in Spain, or to prove an intention to work through a job offer or a declaration of responsibility for self-employed activity.
• To remain in Spain with their family unit, consisting of minor daughters and sons, adult daughters and sons with disabilities, or first-degree ascendants who live with them.
• To be in a vulnerable situation, certified by the competent authority responsible for social assistance.

This point is very important for municipal services: being in an irregular situation is not enough on its own. The person must also fall within one of those three situations.

Documentation for each situation

A) Si acredita actividad laboral

They must provide:

• EX-32 form.
• Passport, registration certificate or travel document.
• Criminal-record certificate.
• Documentation of the work carried out or of the job offer.
  The form itself adds that a declaration of responsibility may also be provided if the intention is to work as a self-employed person.

B) If a family unit is proved

They must provide:

• Passport, registration certificate or travel document.
• Criminal-record certificate.
• Documentation proving the family relationship.
• Documentation proving cohabitation with the family unit.
• Proof of payment of the fee.

The form adds that the schooling of minors or of adults with disabilities with whom the person lives must be documented.

C) If vulnerability is proved

They must provide:

• Passport, registration certificate or travel document.
• Criminal-record certificate.
• Documentation proving residence in Spain.
• A vulnerability certificate from the competent authority or collaborating organisation.
• Proof of payment of the fee.

How daughters and sons can also be regularised

This is one of the most relevant points for town halls, because many enquiries will focus on minors.

The official documentation provides that, when the applicant has minor daughters or sons, or adult daughters or sons with disabilities who require support, they may simultaneously apply for a residence authorisation for them under Articles 159 and 160 of the Immigration Regulations. Both applications will be decided together.

If the minor was born in Spain

Article 159 applies. The general rule states that authorisation may be requested for minors born in Spain who are children of foreign parents with residence, and that it lasts for five years. Normally, it must be requested within six months of the birth or from the time the parent obtains residence. Under this extraordinary regularisation, that requirement is relaxed: the six-month limit does not apply.

If the minor was not born in Spain

Article 160 applies. During this extraordinary process, important requirements are relaxed: the prior two-year residence requirement is not imposed, nor is proof of the financial means and adequate housing normally required for family reunification.

What municipal staff need to know

In simple terms:
if the mother, father or guardian applies for extraordinary regularisation, they can also process the residence of their minor daughters and sons at the same time. The requirements have been eased in this process precisely to provide better protection for children. The Royal Decree itself stresses that these authorisations for minors may be granted for five years, guided by the best interests of the child.

Channels for submitting the application

The application can be submitted through two routes: online and in person.

Online (telematic):

It has been open since 16 April and operates 24 hours a day through the MERCURIO platform. It can be done:

1. With the person’s own electronic certificate.
2. Through a registered power of attorney.
3. Through authorised professionals.
4. Through organisations registered in the Register of Immigration Collaborators.

In-person route
In person

It begins on 20 April, always with a prior appointment, which can be requested from 16 April. In-person submission can be made at authorised offices of:

• Immigration offices.
• Social Security offices.
• Post offices.

The official information adds that Correos has been authorised to provide support and management through assisted online submission, precisely to facilitate territorial access to the procedure.

How to request an appointment

According to the questions-and-answers guide, the appointment can be requested:

• On the regularisation portal using Cl@ve.
• On the portal using the web form.
• By calling 060.

What town halls should say to prevent mistakes

There are several messages that municipal staff should repeat clearly:

First: proof of submission is not the same as the communication that proceedings have begun. The authorisation to work takes effect with that communication from UTEX, not with the simple submission receipt.

Second: the initial authorisation lasts one year and allows residence and work only in Spain, not in the rest of the European Union.

Third: after a favourable decision, the TIE must be requested from the Policía Nacional within one month.

Fourth: if the person cannot obtain the criminal-record certificate from their country of origin in time, there is an exceptional route to request that it be obtained through diplomatic channels, but this does not automatically replace the certificate. They must prove that they requested it and submit a declaration of responsibility and specific authorisation.

FAQ for town hall staff

1. Can the town hall process or decide on the regularisation?

No. The decision belongs to the General State Administration. The town hall can provide guidance, facilitate municipal documentation and, where appropriate, involve social services if it is the competent body to certify vulnerability.

2. Who can qualify for the process?

People seeking asylum whose application was submitted before 1 January 2026 and people in an irregular situation who arrived before that date, always with at least five months of residence and no relevant criminal record.

3. Should a person with a valid residence card apply for this regularisation?

No. The official information states that this process is not intended for people with a valid authorisation or one undergoing renewal or extension.

4. Do people seeking asylum have to prove employment, family ties or vulnerability?

Not through this specific route. They must prove that they were applicants for international protection before 1 January 2026, their residence in Spain and the general documentation.

5. Can people in an irregular situation apply even if they do not have a job?

Yes, but only if they fall within one of the other situations: family unit or vulnerability. If they cannot prove any of the three situations, they would not meet the requirements.

6. Can the whole family submit their applications at the same time?

Yes. The official guide states that, in a single in-person appointment, applications from people in the same household can be handled together. In addition, minor children can be processed at the same time.

7. How is a minor daughter or son regularised?

Together with the application of the mother, father or guardian, applying Articles 159 or 160 of the Regulations, depending on whether the child was born in Spain. This process includes important relaxations to protect children.

8. Which municipal documents may be useful?

Especially those that help prove residence, cohabitation, schooling or social circumstances. Residence can be proved through any legally valid evidence.

9. Where can a person without a digital certificate submit the application?

In person with a prior appointment, or online through a representative, authorised professional or collaborating organisation.

10. Can the application also be submitted through Correos?

Yes. The in-person route includes authorised post offices, and the Royal Decree also provides for Correos’ participation in supporting and managing the procedure.

11. When can the person start working?

Not from the simple submission receipt. They may do so once they receive the communication that the administrative procedure has begun.

12. Where can updated official information be found?

On the Ministry’s dedicated regularisation website, where the online route, prior appointments and information about collaborating organisations are brought together.

Conclusion

For town halls, the key is not to become an immigration office, but to be a reliable gateway. Good municipal support can prevent common mistakes: confusing the asylum route with the irregular-status route, forgetting proof of residence, failing to process daughters and sons at the same time, not activating social services in cases of vulnerability, or assuming that the submission receipt already authorises someone to work.

Put simply: the town hall does not decide, but it can make the difference between a well-prepared application and one that gets off to a bad start.

The 2026 extraordinary regularisation allows migrants who were already in Spain before 1 January 2026 to apply for a residence and work permit. The application period opened online on 16 April, in-person assistance began on 20 April, and the general deadline is 30 June. The application can be submitted online, including through entities registered in the Register of Foreigners’ Collaborators.

The most important point: not everyone needs this report

The vulnerability report or certificate is not a general document for the entire regularisation process. It is only needed in one very specific case: when the person is in an irregular administrative situation and wants to apply for extraordinary roots on the basis of vulnerability using form EX-32. The official materials state that, for this route, the applicant must prove at least one of three situations: having worked or having a job offer or commitment, living with their family unit, or being in a situation of vulnerability. The certificate is required in this third situation.
https://www.inclusion.gob.es/documents/20121/7817425/Modelo%20de%20certificado%20de%20vulnerabilidad.pdf/a50a2832-48e2-1b30-4040-f072c9c2c582?version=1.0&download=true
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf

In addition, the Ministry has expressly clarified that people who have applied for international protection, those who can qualify through the work route, and those who can prove that they live with their family unit do not have to submit this certificate. In other words, if your application follows one of those other routes, you will not be asked for this report.

For which applications is it actually required?

You should only consider this document if the following situation applies:

Person in an irregular situation + application using EX-32 + the option “Being in a situation of vulnerability” selected.
Form EX-32 includes this option expressly, and its instructions state that, in this situation, the applicant must provide the corresponding certificate.
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf

Which entities can issue it?

According to the model published by the Ministry, the certificate may be issued by:

• the public administration competent in social assistance, or
• a Third Sector entity registered in the Register of Foreigners’ Collaborators; the Ministry’s broader information package also refers to registered trade-union organisations.
  https://www.inclusion.gob.es/documents/d/guest/entidades-colaboradoras?download=false

For practical purposes, this means two very clear things:

1. You can go to public social services if they are authorised to do so in your area.
2. You can also go to a social entity registered in the official register of collaborators. The Ministry created this register so that social organisations and trade unions can provide free support with the regularisation process.

What the report must include

Annex II of the official form requires the entity to complete, at a minimum, the following sections:

1. Details of the certifying entity
Name, tax identification number, type of entity, registration number if applicable, address, telephone number and email address.

2. Details of the person concerned
Name and surname, NIE or passport if available, date of birth, nationality, address, mobile phone number, town or city, postcode and province.

3. Circumstances of vulnerability
The official form allows one or more of the following situations to be selected:

• social isolation or lack of a support network
• homelessness or insecure housing
• discrimination or social exclusion
• insufficient income
• poverty or risk of economic exclusion
• difficulty accessing employment
• dependants
• vulnerable family unit
• single parenthood in a context of hardship
• psychosocial risks
• exposure to exploitation or abuse
• other circumstances, if the entity specifies them.

How the entity should complete it

It is important to be very clear here: this report is not a free-form letter. It has an official format and must be completed using that model.

The entity must:

• state whether it is acting as a public administration or as an entity registered in the register;
• provide its full details;
• properly identify the applicant;
• select the applicable circumstances of vulnerability;
• record that the person is in an irregular administrative situation and that those circumstances negatively affect their living conditions or effective access to rights;
• sign and stamp the document.

The central wording of the model is very important because the entity is not merely describing a social situation: it certifies that the person is in a situation of vulnerability “solely for the purposes provided for” in that provision. That is why any informal statement is not sufficient.

What documents does a person usually need to request it?

Although each entity may organise the social interview differently, in practice it is advisable to bring:

• available passport or identity document;
• proof of residence in Spain;
• registration certificate, if available;
• documents concerning insecure housing or lack of accommodation;
• documents proving lack of income;
• documents relating to dependants;
• social, health, educational or specialist-care reports, if available;
• any evidence of discrimination, exploitation, lack of protection or exclusion.

This does not replace the official form, but it helps the entity better substantiate the real situation and complete the certificate on the basis of documentary evidence. The official information sheet also requires, for this EX-32 route, a passport or equivalent document, a criminal-record certificate, proof of continuous residence for five months before 1 January 2026, the vulnerability certificate and payment of the fee.
https://www.inclusion.gob.es/documents/20121/7817425/28%20Ter.%20Autorizaci%C3%B3n%20residencia%20temporal%20por%20circunstancias%20excepcionales.%20Arraigo%20extraordinario%20%28DA21%C2%BA%29%20%281%29.pdf/31869954-4f70-ffdb-efab-b9675df61aac?version=1.0&download=true
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf
https://sede.administracionespublicas.gob.es/pagina/index/directorio/tasa052

Where to find free help

The Ministry has said that entities in the Register of Foreigners’ Collaborators offer free support and may also act as representatives when submitting the application online.
https://www.inclusion.gob.es/documents/d/guest/entidades-colaboradoras?download=false

Some of the contacts for collaborating entities are as follows:

Frequently asked questions

1. I am an asylum applicant and they are asking me for this certificate. What should I do?

In principle, you do not need it. The Ministry has said that this certificate is not intended for people who enter through the international-protection route.

2. If I have children and live with my family, do I also need the report?

Not necessarily. If you can apply through the family-unit route and prove it properly, you should not have to submit the vulnerability certificate.

3. Can any association prepare it for me?

No. It must be issued by a public administration competent in social assistance or by an entity registered in the Register of Foreigners’ Collaborators, using the official form.

4. Is a free-form social report prepared by an NGO, without the official form, sufficient?

The recommended approach is not to do so. The safest option is to use the official Annex II, signed and stamped.
https://www.inclusion.gob.es/documents/20121/7817425/Modelo%20de%20certificado%20de%20vulnerabilidad.pdf/a50a2832-48e2-1b30-4040-f072c9c2c582?version=1.0&download=true

5. Does the certificate automatically grant me residence?

No. The certificate helps prove that you qualify through the vulnerability route, but the final decision is made by the immigration authorities.

6. Can the entity also help me submit the application?

Yes. Registered entities can provide free support and may also act as representatives when the application is submitted online.

7. What happens if I have neither a job nor a provable family unit?

This is precisely where the report can be decisive, provided that a competent entity assesses and certifies your situation of vulnerability.

8. Where can I consult the official list of collaborating entities?

In the Ministry’s official list of collaborating entities.
https://www.inclusion.gob.es/documents/d/guest/entidades-colaboradoras?download=false

Conclusion

If you are in Spain in an irregular situation and cannot enter the extraordinary regularisation through work or family unity, the social vulnerability report may be the key to submitting your application through the correct route. You do not need it in every case, but if your situation involves exclusion, lack of income, insecure housing, isolation or family responsibilities, you should make an appointment with social services or with a registered collaborating entity and ask them to assess your case using the official Annex II model for EX-32. Always use free channels and check that the entity appears on the Ministry’s official list.
https://www.inclusion.gob.es/documents/20121/7817425/Modelo%20de%20certificado%20de%20vulnerabilidad.pdf/a50a2832-48e2-1b30-4040-f072c9c2c582?version=1.0&download=true
https://www.inclusion.gob.es/documents/d/migraciones/ex32-formulario-autorizacion-de-residencia-por-circunstancias-excepcionales-por-razon-de-arraigo-extraordinario-da21-.pdf

The Ministry has published interpretative criteria explaining how Royal Decree 316/2026 should be applied in the extraordinary regularisation. Put simply, this document helps the Administration process cases more consistently and clarifies important questions about who can apply, which documents are needed and what happens with older cases or applicants with minor children.

This post summarises those criteria in plain language, without losing detail, so that anyone can understand how they really affect the processing of their case.

1. First criterion: people who applied for asylum before 1 January 2026 can qualify, even if their situation has changed

This is one of the most important clarifications. The criterion states that people who applied for international protection before 1 January 2026 may request this authorisation, even if they no longer have asylum-applicant status at that time.

This includes, for example, people whose asylum application:

• is still being processed,
• was withdrawn,
• was refused,
• was refused and appealed,
• or is still subject to an ongoing appeal.

How does this affect the processing of the case?

It matters greatly because it prevents the office from rejecting an application simply because the person no longer has valid asylum papers. What matters here is having submitted the international-protection application before the deadline, not still being formally an applicant at that time. In practice, this criterion increases legal certainty and reduces the risk of restrictive interpretations.

2. Second criterion: a vulnerability certificate is not required in every case

The criterion also clarifies an important point about the extraordinary-roots route under the twenty-first additional provision: there are three different ways to qualify for this route:

1. having worked or being able to demonstrate an intention to work,
2. remaining in Spain with the family unit,
3. being in a situation of vulnerability.

The key point is this: the vulnerability certificate or report is required only in the third case, that is, when the application is submitted through the vulnerability route. If the person applies through work or family unity, that certificate should not be requested.

How does this affect processing?

It prevents unnecessary requests for documents. Many people might think that they always need a social report or vulnerability certificate, but the criterion clearly says they do not. This can save time, avoid requests to correct the file and make the case simpler when the application is based on work or family.

3. Third criterion: who can issue the vulnerability certificate and how it must be prepared

When vulnerability does need to be proven, the criterion explains who can issue the certificate and what formal requirements it must meet. It may be issued by:

• the public administrations competent in social assistance,
• and also Third Sector entities or trade-union organisations registered with RECEX.

The criterion also clarifies several practical points:

• only Third Sector entities or trade unions actually registered with RECEX may issue it;
• if their territorial scope is limited, they may issue it only within that territory;
• they are not obliged to issue certificates merely because they are registered;
• it may be signed by anyone who is part of the entity;
• it must bear the official stamp of the issuing entity and the RECEX case-file number; the criterion does not require a specific stamp format, so it may be electronic or on paper, provided that it clearly identifies the entity;
• and its issuance must be free of charge.

How does this affect the processing of the application?

It matters because it brings order. This criterion helps clarify when a certificate is valid and when it is not. It can also prevent very common problems: certificates signed by entities that are not registered, documents without a stamp, or reports issued outside the relevant territorial scope. In short, it is not enough to have a report; it must also have been issued correctly.

4. Fourth criterion: it is not advisable to withdraw other applications or waive authorisations that have already been granted

The document expressly recommends that people who have already submitted an application for a stay or residence permit, or who already hold a valid authorisation, do not withdraw it or waive it.

How does this affect the processing of the application?

It matters because the extraordinary regularisation is not intended to leave someone with “nothing” while they wait. If someone waives an authorisation or withdraws an application that could be successful, they may end up in a worse situation. The practical message of the criterion is clear: before abandoning one route, it is important to assess carefully whether it really makes sense.

5. Fifth criterion: minor children and some people with disabilities must be processed at the same time as the main application

The first transitional provision, as explained by the criterion, says that when a person covered by the extraordinary regularisation has:

• minor children,
• adult children with a disability requiring support or who cannot meet their own needs because of their health,
• or is their guardian, the application for the minor or dependent person must be submitted at the same time as the parent’s or guardian’s main application.

The criterion also introduces several flexibilities:

• for Article 159, the requirement to submit the application within six months of the birth is waived;
• for Article 160, the two-year prior residence requirement is waived, as are the financial means and accommodation requirements for family reunification;
• but in the latter case, it is still necessary to prove that the minor has been in Spain for five consecutive months before the application.

How does this affect the processing of the application?

It matters because it makes regularising children and dependent people much easier. In these cases, the Administration will not require all the ordinary conditions that would normally be required under Articles 159 and 160. This makes the family application more accessible and quicker to resolve jointly.

6. Sixth criterion: in certain family applications, the decision must be issued at the same time

The criterion also says that, in these cases involving minors or dependent people processed together with the main application, the checks will be carried out by the Foreigners’ Applications Processing Unit and the decision must be issued simultaneously. In these cases, competence lies with the head of the Directorate-General for Migration Management.

It also adds another important point: this provision also applies to authorisations that are being processed and to those submitted up to 30 June 2026. Even if the minor’s authorisation was not requested at the same time at the start, it can still be requested by that date so that both decisions are issued simultaneously.

How does this affect the processing of the application?

It matters because it creates a second opportunity to regularise children or dependent people correctly if this was not done jointly at the start. It also helps prevent applications from being split in two, with one part resolved and the other left unresolved.

7. Seventh criterion: people who already had earlier applications submitted also benefit

The first transitional provision does not only concern new applications linked to this regularisation. It also applies to applications already submitted under Articles 159 and 160 by parents or guardians with a temporary residence permit, provided they were submitted before the maximum date set for applying for the authorisations under Additional Provisions 20 and 21. In those cases, the competent foreigners’ office will decide, and the Government Delegation or Subdelegation must notify the applicant within one month of receiving the application.

How does this affect the processing of the application?

It matters because it does not exclude families that had already begun the process through the ordinary route. The criterion allows these favourable special rules to be applied to those earlier applications as well.

8. Eighth criterion: applications from earlier years that are still being processed are not excluded

The second transitional provision is another of the most important parts of the document. It says that two major groups of applications in progress benefit from this new regime:

• applications submitted under the fifth transitional provision of Royal Decree 1155/2024 before the new royal decree came into force;
• and applications for temporary residence on exceptional grounds under Title VII, except for the application under Article 128.1, which were in progress and were submitted between 20 May 2025 and 15 April 2026, inclusive. This also applies to administrative and contentious-administrative appeals that are pending against those decisions.

How does this affect the processing of the application?

It matters because it prevents many older applications from having to start from scratch. If they were already being processed on those dates, the Administration must review them under the new transitional rules, rather than acting as if nothing had changed.

9. Ninth criterion: depending on the type of older application, the requirements reviewed by the Administration change

The criterion clearly distinguishes between two scenarios:

• in the first section of the second transitional provision, only compliance with the requirements of Additional Provision Twenty will be required;
• in the second section, the requirements in the first paragraph of Additional Provision Twenty-One must be met.

In addition, in the first scenario, the royal decree states that it will be sufficient to prove that the person has no criminal record and does not pose a threat to public order, public security or public health, assessed on the basis of the relevant police report.

How does this affect the processing of the application?

It matters because the office must not mix the requirements of one route with those of another. Each application must be reviewed against the correct list of requirements. This may sound technical, but it is actually very important: using the wrong set of requirements can lead to unfair refusals or incorrect requests for additional documents.

10. Tenth criterion: people with a favourable decision on an older application will receive the permit they applied for, not a different one

The criterion states that people with applications under Title VII still being processed, submitted between 20 May 2025 and 15 April 2026, will receive the authorisation they applied for, and that its validity will begin from the date it is granted.

It also sets out three practical rules:

• if someone applied for socio-educational roots and receives a favourable decision, they will have that authorisation with its own characteristics, including the possibility of working for an employer for up to 30 hours per week;
• if they applied for socio-occupational roots, the effectiveness of the authorisation will not depend on prior registration with Social Security;
• if they applied for residence based on cooperation against organised networks, that cooperation with the authorities must still exist.

How does this affect the processing of the application?

It matters because it provides certainty about the final outcome of the application. An application is not automatically converted into a different type of permit. Each case retains its nature, with its specific effects. This is particularly important for socio-educational roots, socio-occupational roots and cooperation with the authorities.

The most important points, explained very simply

If we had to summarise the entire criterion in very simple sentences, it would be as follows:

One: if you applied for asylum before 1 January 2026, you can qualify even if your situation is different now.

Dos: el informe de vulnerabilidad solo se pide si vas por la vía de vulnerabilidad.

Three: vulnerability certificates must come from the appropriate body and be properly signed.

Four: it is not a good idea to withdraw other applications or waive permits without considering it very carefully.

Five: applications for minors and dependent people are intended to be decided together with the main application and under more flexible rules.

Six: many older applications still being processed also benefit from the new framework and do not have to start from scratch.

Conclusion

The interpretative criteria for the 2026 extraordinary regularisation are not simply a technical text. In practice, they clarify questions that can completely change the outcome of an application. Thanks to these criteria, it is clearer that many asylum applicants can still qualify for the process, that a vulnerability certificate is not required in every case, that minors and dependent people receive more flexible treatment, and that many older applications still being processed should not be excluded from the new framework.

The main idea is simple: the extraordinary regularisation must be applied consistently, more clearly and more fairly. For that reason, before submitting an application, responding to a request for additional documents or giving up another residence route, it is advisable to check carefully which situation each case falls under and which specific criterion applies. Understanding these rules can prevent mistakes, save time and increase the chances that the application will be processed correctly from the outset.

In a process as important as this one, knowing the criteria well is not a minor detail: it can make the difference between an application that is poorly structured and one that is properly prepared.

FAQ: frequently asked questions about the interpretative criteria for the 2026 extraordinary regularisation

Does this criterion apply to people whose asylum application was refused?

Yes. The criterion says that people whose application for international protection was refused, withdrawn or appealed may also qualify, provided that the asylum application was submitted before 1 January 2026.

Is a vulnerability report always required?

No. It is only required when the application is submitted through the vulnerability route. If it is submitted on the basis of work or family unity, that report should not be required.

Can an NGO issue the vulnerability certificate?

Yes, but not just any NGO. It must be a Third Sector entity or trade union organisation registered with RECEX, and it must act within its territorial scope.

Can the entity charge for this certificate?

No. The criterion states that these entities must issue the vulnerability certificate or report free of charge.

Who can sign the vulnerability certificate?

It can be signed by anyone who belongs to the issuing entity or the competent administration, without prejudice to its internal organisational rules.

What must this certificate contain to be valid?

It must include the official stamp of the issuing entity and, if it is issued by an entity registered with RECEX, the file number recorded in that register as well. The criterion does not require a specific stamp design: it does not set a size, shape, colour or minimum wording. What matters is that it clearly identifies the entity, and it may be electronic or physical.

What happens with minor children?

They must be processed at the same time as the parent’s or guardian’s application, and in some cases requirements that would normally be more demanding are made more flexible.

Can a minor be regularised if their application was not submitted at the same time at the start?

Yes. In certain cases, the criterion allows it to be submitted until 30 June 2026 so that both decisions are issued simultaneously.

Can applications submitted before this royal decree benefit from it?

Yes. The criterion states that certain applications in progress submitted between 20 May 2025 and 15 April 2026, and even some appeals that are still pending, will be reviewed under these transitional rules.

If I already have another application in progress, should I withdraw it to apply for this regularisation?

The criterion recommends not automatically withdrawing or waiving other applications or authorisations that are in force. Each case must be examined before taking that step.

What happens if my older application was for socio-educational roots?

If the decision is favourable, you will receive that same authorisation, with its own characteristics, including permission to work for an employer for a maximum of 30 hours per week.

What if my older application was for socio-occupational roots?

The criterion clarifies that the effectiveness of that application will not be subject to prior registration with Social Security.

The 2026 extraordinary regularisation allows migrants who were already in Spain before 1 January 2026 and meet the procedural requirements to submit an application for temporary residence on exceptional grounds. The application period began on 16 April and will remain open until 30 June 2026. Applications may be submitted online or in person, but in-person submission always requires a prior appointment.

Quick answer

If you want to submit the application in person in Galicia, you must book an appointment first. An appointment can be requested in three ways through this link to the Regularisation Platform: https://www.inclusion.gob.es/regularizacion

1. Online with Cl@ve or a digital certificate, choosing the office, day and time.
2. Using a web form, without Cl@ve, but you cannot choose the office or day: the system assigns you a nearby appointment.
3. By calling 060, with assistance in Spanish.

In Galicia, documents submitted in person must be delivered at authorised Correos and Social Security offices. Galicia’s Foreigners’ Offices are not authorised to receive documents in person for this procedure. The only Foreigners’ Offices authorised for this procedure are in Madrid, Alicante, Valencia, Almería and Murcia.

1. What is the prior appointment for?

The prior appointment is used to visit an authorised office and submit the extraordinary regularisation application there. It is not an appointment to request general information or to review your entire case from scratch. For this reason, it is advisable to prepare the documents before going.

The in-person route works only by prior appointment. By contrast, the online route is available 24 hours a day throughout the application period.

2. First option: book an appointment with Cl@ve or a digital certificate

This is the most convenient option if you, a trusted person or an organisation helping you have digital identification.

How does it work?

You enter the official regularisation portal and access the appointment service with Cl@ve or a digital certificate. With this option, you can choose the office, date and time. If you do not have Cl@ve, someone who does can book the appointment for you by entering your details.

Simple steps

Go to the Ministry of Inclusion, Social Security and Migration’s official regularisation website. Look for the prior-appointment section. Log in with Cl@ve or a digital certificate. Enter the details of the person who will submit the application. Choose the province, office, available day and time. Confirm the appointment and save the receipt.

This receipt is important: take it with you on the day of the appointment, either on paper or on your phone.

When is this option useful?

It is useful when you need to choose a specific office, want to control the day and time, or when a social organisation, lawyer, professional adviser, employment relations graduate or trusted person is helping you book the appointment.

3. Second option: book an appointment using the web form, without Cl@ve

This option is for people who do not have Cl@ve or a digital certificate.

How does it work?

The web form lets you request an appointment without digital identification, but there is an important difference: you cannot choose the office or date. The system assigns the appointment closest to the information you provide.

What information does the form request?

The official public information states that, so that you can be contacted and notifications can be delivered correctly, personal and contact details must be completed very carefully, especially your telephone number, email and postal address.

Before starting the form, have these details ready:

• First name and surname.
• Passport number, NIE if you have one, registration certificate or identity document you use.
• Date of birth and nationality.
• Address where you live in Spain.
• Postcode, town or city and province.
• Mobile phone number.
• Email address.
• Details of the people in your family unit if you are going to submit several applications together.
• Province or area where you need the appointment.

Important advice

Enter your telephone number and email address correctly. If the email is incorrect or the telephone number does not work, you may miss the appointment notice.

4. Third option: book an appointment by calling 060

You can also book an appointment by calling 060. Assistance is provided in Spanish. The official hours stated for this procedure are Monday to Friday, from 09:30 to 14:00 and from 16:30 to 19:30.

Prepare this before calling

Have your passport or identity document, full address, telephone number, email address and the details of any family members who want to submit the application with you in front of you.

Speak slowly and write down the appointment details: office, day, time and any code or reference you are given.

5. How do we book an appointment if we are a family?

A single appointment may be used to submit the applications of people in the same household simultaneously. This is very important for families, because it avoids booking a separate appointment for each member when they submit their applications together.

Simple example

A mother, a father and two minor children live together and are going to apply for regularisation. They can book one appointment for the family unit and bring a complete application for each person who is going to be regularised.

What to bring when applying as a family

Each person must have their own form and documents. It is not enough to put all the documents in the father’s or mother’s folder. Each case file must be clear and separate.

For minors, it is important to bring documents proving the family relationship: a birth certificate, family record book or another valid document, normally legalised or apostilled and translated where applicable.

6. Authorised offices in Galicia

According to the official list of regularisation offices, Galicia has 15 authorised offices between Social Security and Correos. The official list itself organises the offices by autonomous community and province.

Province of A Coruña

Province of Lugo

Province of Ourense

Province of Pontevedra

Social Security offices handle this procedure from 16:00 to 19:00 and Correos offices from 08:30 to 17:30, Monday to Friday.

7. Important: Galicia’s Foreigners’ Offices do not accept these applications

Although regularisation is an immigration procedure, in Galicia you should not go to a Foreigners’ Office to submit the application in person for this procedure. In Galicia, the authorised points are the Correos and Social Security offices shown in the official list. The Foreigners’ Offices authorised for in-person assistance under this procedure are only those in Madrid, Alicante, Valencia, Almería and Murcia.

This does not mean that the Foreigners’ Office will not be involved later. It means that, to submit the documents in person in Galicia, you must go to an authorised Correos or Social Security office with a prior appointment.

8. What to check before going to the appointment

Bring the saved appointment confirmation, the relevant official form, your complete passport or travel document, copies of the documents, evidence that you were in Spain before 1 January 2026, evidence of having remained in Spain for at least five months, and a criminal-record certificate where applicable. The official information reminds applicants that all supporting documents must be in the applicant’s name and dated.

If you are submitting applications as a family unit, bring a separate folder for each person.

FAQ: frequently asked questions about appointments for the 2026 extraordinary regularisation

Can I go without an appointment?

No. A prior appointment is mandatory for the in-person route. Without an appointment, they should not see you to submit the application.

Is the appointment for submitting the application or only for requesting information?

It is for submitting the application in person. It is advisable to attend with the case file prepared.

Can I choose the office?

Yes, if you book the appointment with Cl@ve or a digital certificate. If you use the web form without Cl@ve, you cannot choose the office or date: the system assigns the appointment closest to the information you provide.

Can I book the appointment by phone?

Yes. You can call 060, with assistance in Spanish, Monday to Friday from 09:30 to 14:00 and from 16:30 to 19:30.

Can someone else book the appointment for me?

Yes. The official information states that, if you do not have Cl@ve, you can ask someone who does to request the appointment by entering your details.

Does a family need one appointment for each person?

Not necessarily. The applications of members of the same household can be managed through a single appointment.

Can I submit my children’s documents as part of my case file?

That is not recommended. Each person should have their own application and documents. For minors, add the family documents proving the relationship.

What happens if I enter my telephone number or email incorrectly?

You may miss important notices. The Administration states that subsequent communications will preferably be sent through the channel used when the application was started, and asks applicants to enter their telephone number, email and postal address carefully.

Can I submit the application at any Correos office?

No. Only at Correos offices authorised for this procedure and with a prior appointment.

Can I submit it at any Social Security office?

No. Only at offices authorised for this procedure and with a prior appointment.

Do Galicia’s Foreigners’ Offices accept applications?

They are not listed as authorised points in Galicia for this procedure. In Galicia, you must use the authorised Correos or Social Security offices.

Until when can I submit the application?

Until 30 June 2026.

Does having a prior appointment mean that I already have residence?

No. The appointment only allows you to submit the application. The Administration must then admit it for processing and decide it.

Does the submission receipt allow me to work?

The submission receipt is not the same as the notice that processing has begun. According to the official information, the notice that processing has begun is the document that allows provisional work while the case is being processed.

Conclusion

A prior appointment is the gateway to submitting the 2026 extraordinary regularisation application in person. In Galicia, in-person applications are submitted at authorised Correos and Social Security offices, not at Galicia’s Foreigners’ Offices. The easiest way to avoid mistakes is to prepare all the documents beforehand, book the appointment through an official channel and bring a separate folder for each family member.

The 2026 Extraordinary Regularisation is generating a particularly important notification for many migrants and also for companies that need to recruit: the notice of admission for processing or notice that processing has begun.

This document is not yet the final decision granting residence. However, it has a highly significant practical effect: it provisionally authorises the applicant to reside and work in Spain while their case is being decided.

For the applicant, it means being able to join the labour market with greater legal certainty. For the company, it makes it possible to formalise employment without necessarily waiting for the final decision, provided that the person has this administrative notice and that labour and Social Security obligations are met.

What is admission for processing under the 2026 Extraordinary Regularisation?

Admission for processing is the notice through which the Administration informs the applicant that the application has been received by the competent authority and that processing has begun.

Within the framework of the 2026 Extraordinary Regularisation, it may mainly refer to two routes:

Twentieth additional provision — DA20. Intended for people who applied for international protection in Spain before 1 January 2026. The interpretative criteria of the Directorate-General for Migration Management indicate that anyone who applied for international protection before that date may qualify, regardless of whether they still have applicant status when the application is submitted.

Twenty-first additional provision — DA21. Intended for people in an irregular administrative situation who were in Spain before 1 January 2026 and meet one of the cases provided for: having worked or being able to demonstrate an intention to work, remaining in Spain with their family unit, or being in a documented situation of vulnerability.

Royal Decree 316/2026 provides that these permits may be applied for until 30 June 2026 and that, from the notice that processing has begun, the applicant is provisionally authorised to reside and work, as an employee or self-employed, until the procedure is decided, with a maximum decision period of three months.

What usually appears in the admission-for-processing notice?

Although the format may vary, these notices usually include:

Case file number. This is the administrative identifier for the procedure.

Applicant’s details. Name, NIE if available, and other basic details linked to the case file.

Date the application was received. This is relevant because it identifies when certain administrative periods begin to run.

Type of authorisation requested. For example, temporary residence on exceptional grounds under DA20, or temporary residence on exceptional grounds based on extraordinary roots under DA21.

Maximum decision period. The notice usually states that the Administration has three months to decide and notify the outcome.

Provisional authorisation to reside and work. This is the most important part: the person is provisionally authorised to reside and, if of working age, to work as an employee or self-employed anywhere in Spain and in any occupation or sector of activity.

Warning in the event of refusal. If the application is ultimately refused, the provisional authorisation automatically ceases to be valid, without any additional decision being required to withdraw it.

When is admission for processing notified?

The notice of admission for processing should generally be issued within the ten working days following receipt of the application by the authority competent to process it.

This means that Saturdays, Sundays and public holidays do not count. Therefore, ten working days do not necessarily equal ten calendar days: if a weekend or national, regional or local public holidays fall within the period, the actual calendar period may be longer. Law 39/2015 provides that, when periods are expressed in days, they are understood to be working days unless a law or European Union law establishes a different calculation, excluding Saturdays, Sundays and public holidays.

This notice is important because it informs the applicant that processing has begun, states the maximum period for a decision and explains the effects of administrative silence. In the case of the Extraordinary Regularisation, it is also the document recognising provisional authorisation to reside and work while the case is being decided.

This initial notice period must be distinguished from the period for the final decision: the Administration has a maximum of three months to decide and notify whether the authorisation is granted or refused.

The provisional authorisation to work should not be understood as taking effect solely because the application has been submitted. It takes effect when the person receives the notice of admission for processing or notice that processing has begun, expressly stating that provisional authorisation.

Practical development: Social Security number and healthcare

One of the most relevant developments in admission-for-processing notices is the reference to the Social Security number.

The notice states that, in the days that follow, the applicant will receive at the address given in the application —without having to go to a Social Security office— a decision recognising the right to healthcare. That decision will include the Social Security number assigned to the applicant and, where applicable, to their family members.

This point is especially important for recruitment. The document itself states that the Social Security number must be provided when the person starts work. In addition, with that decision they can go to the health centre corresponding to their address to request a health card.

A common misunderstanding should be avoided: this notice is not equivalent to registration as an employee with Social Security. The company must complete the registration, as in any ordinary employment, before work begins. What this notice makes possible is for the person to have an assigned Social Security number and provide it when formalising their employment relationship.

For companies, this is a practical advantage: hiring people whose applications have been admitted for processing and who have provisional authorisation to work can be handled more quickly, provided that the contract, registration and all other labour obligations are properly completed.

What does this mean for the applicant?

For the migrant, admission for processing represents a significant practical change while the case is being processed.

From that moment, they can:

• reside provisionally in Spain while the procedure is being processed;
• work as an employee;
• work on a self-employed basis;
• access formal employment;
• be registered with Social Security;
• prove to a company that they have provisional authorisation to work.

Provisional authorisation should not be confused with residence that has already been granted. It is a temporary authorisation linked to the ongoing procedure. It remains valid until the Administration decides the case. If the decision is favourable, the person will have temporary residence authorisation. If it is refused, the provisional authorisation will cease to have effect.

Royal Decree 316/2026 expressly provides that the notice that processing has begun must state that the applicant is provisionally authorised to work, and that refusal will automatically cause that provisional authorisation to cease to be valid.

Why is this important for companies?

For many companies, especially in sectors facing recruitment difficulties, admission for processing creates an immediate opportunity.

The company does not necessarily have to wait for the final residence decision. If the person has a notice of admission for processing recognising provisional authorisation to work, the company can move forward with the recruitment.

This may be especially useful in sectors such as:

• care and support for people;
• hospitality;
• cleaning;
• construcción;
• logistics;
• agriculture;
• retail;
• local services;
• the social economy;
• third-sector organisations.

Regularisation benefits more than just the applicant. It also provides security for companies that need staff and want to recruit within the legal framework.

What should a company check before hiring?

Before formalising the employment, the company should check several basic elements.

1. That the person has the notice of admission for processing. Submitting the application is not enough. The company must have the administrative notice stating that the application has been admitted or that processing has begun.

2. That the document recognises provisional authorisation to work. It must state that the person is provisionally authorised to work as an employee and/or on a self-employed basis.

3. That the provisional authorisation is still valid. The provisional authorisation remains valid while the case is being processed. If the decision is refused, it automatically ceases to have effect.

4. That the person has a Social Security number or that it is being correctly processed. The notice states that the Social Security number will be assigned and sent to the address provided. That number must be provided when the person starts work.

5. That registration with Social Security is completed before work begins. The employment must be formalised like any other employment relationship: contract, registration, salary in accordance with the applicable collective agreement, occupational risk prevention and compliance with all employer obligations.

6. That a copy of the documents is kept. The company should retain a copy of the notice of admission for processing, the identification documents and the employment registration completed.

¿Qué implica para la Seguridad Social?

Provisional authorisation allows the person to be hired and registered with Social Security. This is essential because it turns a situation of vulnerability or informality into an ordinary employment relationship with rights and obligations.

For the company, this means:

• the possibility of regular employment;
• Social Security contributions;
• compliance with employment regulations;
• reduced risks arising from informal employment;
• bringing in people who are immediately available to work.

For the worker, this means:

• access to formal employment;
• social protection;
• contributions;
• verifiable work experience;
• greater stability while their case is being processed.

What happens if the application is granted?

If the Administration grants the authorisation, the person will obtain temporary residence on exceptional grounds.

From that moment, they must follow the steps stated in the decision, including applying for the Foreigner Identity Card where applicable. The provisional authorisation is no longer the main legal title because a definitive authorisation has been granted.

What if the application is refused?

If the case is refused, the provisional authorisation to work automatically ceases to be valid, without any additional administrative decision being required.

This has two practical consequences:

• the worker must immediately inform the company of the outcome of the decision;
• the company must review whether the employment relationship can continue, because the person would no longer be authorised to work.

For this reason, it is advisable to monitor the case and keep all notices.

An opportunity to recruit with legal certainty

Admission for processing under the 2026 Extraordinary Regularisation is much more than a simple acknowledgement of receipt. It is the document that activates provisional residence and work authorisation while the Administration decides the case.

For migrants, it provides a real route into the labour market. For companies, it represents an opportunity to meet staffing needs with legal certainty and social responsibility.

In addition, assigning a Social Security number and recognising the right to healthcare facilitate the transition to a more orderly administrative and employment situation, although they do not replace the employer’s obligations to hire and register the worker.

At SenValos, we recommend that companies wishing to hire people in the process of regularisation carefully review the documents, properly formalise the employment relationship and seek advice if they have any doubts.

Well-managed regularisation benefits everyone: it protects rights, reduces the shadow economy, improves employment stability and allows many people who are already part of our society to contribute fully through formal employment.

Frequently asked questions about admission for processing under the 2026 Regularisation

Is admission for processing the same as residence being granted?

No. Admission for processing is not the final decision. It is a notice that processing has begun and, in these procedures, may provisionally authorise the person to reside and work until the case is decided.

When should admission for processing be notified?

Generally, within the ten working days following receipt of the application by the authority competent to process it. Working days exclude Saturdays, Sundays and public holidays.

Can people work once their application has been admitted for processing?

Yes, provided that the notice expressly states that the person is provisionally authorised to work.

Can a company hire someone with this provisional authorisation?

Yes. The company can hire the person if they have a notice of admission for processing with provisional authorisation to work and the contract and Social Security registration are completed correctly.

Does the Administration automatically assign a Social Security number?

The notice states that the person will receive at the address provided a decision recognising the right to healthcare, which will include the assigned Social Security number. That number must be provided when the person starts work.

Does that Social Security number amount to registration as an employee?

No. A Social Security number is not equivalent to registration as an employee. The company must complete the registration before work begins.

How long does the final decision take?

The maximum decision period indicated for these procedures is three months.

What happens if the regularisation is ultimately refused?

The provisional authorisation automatically ceases to be valid. If the person was working, they must immediately inform the company.