IMPACT – HIGH

The Spanish government has amended the criteria for non-essential travel restrictions as a result of COVID-19. The updated list of countries exempted from entry ban includes countries added and removed as health conditions worsen/improve in each country.

Key Points:

  • Citizens from the following countries can travel to Spain: Algeria (subject to reciprocity), Australia, Canada, China (subject to reciprocity), Georgia, Japan, Morocco (subject to reciprocity), New Zealand, Rwanda, South Korea, Thailand, Tunisia and Uruguay.
  • The list may be subject to modification at the discretion of the Ministry of the Interior.
  • The following groups are also exempt from the entry ban:
    • Residents of the EU, Schengen-associated states, Andorra, Monaco, the Vatican or San Marino who provide documentary evidence.
    • Holders of a long-term visa issued by a Member State or Schengen-associated state.
    • Working healthcare/elderly care professionals and health researchers.
    • Sea and flight crews and other personnel required to carry out air transport activities and transport of goods.
    • Members of diplomatic missions, consular posts, international and military entities, civil protection, and humanitarian organizations for the performance of their official duties.
    • Students undertaking studies in Member States or Schengen-associated states, provided they are traveling to the country where they study and entry is undertaken during the academic year or 15 days prior its start.
    • Highly qualified employees whose activity is mandatory, cannot be postponed or undertaken remotely, including participants in upscale sports competitions taking place in Spain.
    • People traveling for imperative family reasons.
    • People who provide evidence of unforeseen circumstances, necessity, or whose entry is permitted on humanitarian grounds.

Analysis & Comments: The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

As of July 6, U.K. citizens residing in Spain can apply for a new residence identity card.

Key Points:

  • Procedures for obtaining the residence ID card differ depending on whether or not the applicant has an EU certificate in Spain.
  • Those with an EU certificate:
    • K. citizens currently living or working in Spain who are in possession of an EU certificate may change their current document for a residence ID card that states that they benefit from the rights and conditions established by the exit agreement between the EU and the U.K.
    • Must make an appointment to apply for the ID card in person at a police station.
    • Citizens that currently have a temporary EU certificate and do not have five years of legal residence in Spain will receive a residence card valid for five years.
    • Citizens that currently have a temporary EU certificate and have five years of legal residence in Spain can apply for permanent residence and obtain a residence card valid for 10 years.
    • Citizens that currently have a permanent EU certificate will receive a residence card valid for 10 years.
  • Those without an EU certificate:
    • Can apply online or make an appointment to apply for the new work and residency permit for U.K. nationals in person before the immigration authorities and must prove their residence in Spain.
    • After applying for the certificate, they can then apply for the residence ID card.
    • Citizens that currently do not have five years of legal residence in Spain will receive a residence card valid for a period of five years.
    • Citizens that currently have five years of legal residence in Spain can apply for permanent residence and obtain a residence card valid for 10 years.
  • Third-country national family members of EU citizens with a valid residence permit in Spain:
    • Must make an appointment to apply for the ID card in person at a police station.
    • If they have less than five years of legal residence in Spain, they will receive a residence card valid for five years.
    • If they currently have five years of legal residence in Spain, they can apply for permanent residence and obtain a residence card valid for 10 years.
    • If they currently have a permanent residence permit for family members of EU nationals, they should change the status to a permanent residence card with a validity of 10 years.
  • Third-country national family members of EU citizens that do not have a valid residence permit in Spain:
    • Can apply online or make an appointment to apply for the new permit for family members of U.K. nationals in person before the immigration authorities and must prove their residence in Spain.
    • After applying for the certificate, they can then apply for the residence ID card.
    • If they currently do not have five years of legal residence in Spain, they will receive a residence card valid for a period of five years.
    • If they currently have five years of legal residence in Spain, they can apply for permanent residence and obtain a residence card valid for 10 years.

Additional information: Deloitte will provide additional updates as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

 

 

IMPACT – HIGH

Spain recently lifted its state of alarm and many of its pandemic-related restrictions.

Key Points:

  • The nationwide state of alarm has been lifted.
  • People are now allowed to move freely within Spain.
  • Travelers entering the country from abroad are no longer subject to 14-day quarantine.
  • Non-essential travel from third countries remains restricted until June 30.
  • While most borders in the European Union are now open, Spain’s border with Portugal remains restricted until June 30.

Analysis & Comments: Though some restrictions remain in place, the lifting of the state of alarm and pandemic-related restrictions is good news for employers with employees who will be entering the country or who are already there. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

Spain recently announced automatic extensions for permits, visas, foreigner identification cards, renewals and long-term stays, to provide relief during the COVID-19 pandemic.

Key Points:

  • All work and residence permits, as well as foreigner ID cards, that expire during the state of emergency will be extended automatically the day after they expire. The automatic extension will be valid for six months after the state of emergency has ended.
  • The automatic extension also applies to renewal processes that are underway until there is a resolution.
  • Long-term stays and visas will likewise be extended for three months after the state of emergency has ended.
  • Residents of Spain or holders of long-term visas who are not inside the national territory, with permits or visas that expired during the state of emergency, and who are unable to return because of border closures, can enter the country using an expired permit or visa and a travel document once the restrictions have ended.

Analysis & Comments: The automatic extension of stay is good news because it provides some relief to foreign nationals stranded in Spain. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

The Egyptian government has announced travel and immigration restrictions to mitigate the spread of COVID-19.

Key points:

  • Inbound and outbound passenger flights have been suspended by the Egyptian government. Inbound and outbound commercial passenger flights shall not begin operating again until further notice. Only special flights, arranged by the government, to return Egyptian nationals who have contacted Egyptian embassies in advance, to Egypt.
  • The majority of the government bodies have suspended its services until April 23. Services provided by free zone, labor and immigration authorities are included in the suspension.
  • Pending immigration applications are now on hold and expired work and residence permits extensions are not possible currently.
  • Individuals outside Egypt who have work and residence permits that have expired could be required to secure a new entry visa to come back to the country following the expiration of their permits.

Analysis & Comments: The new travel and immigration restrictions will impact the movement of people into Egypt. Employers should account for affected travelers and rearrange travel schedules accordingly. Significant delays may occur for consular and in-country processing. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

Spanish authorities have extended the country’s COVID-19 state of alarm until April 12, limiting business activity and travel within Spain. Authorities also continue to enforce strict international travel restrictions.

Key Points:

  • State of alarm. Business activities and travel are limited, including movement on public roads, with some exceptions, such as to get food or medical treatment or going to work in businesses considered essential. In-person immigration services in Spain are suspended because of the lockdown. Immigration officials are working from home to process online immigration services in order to try to avoid excessive delays. Work permit resolutions are being received.
  • International travel. Spain has halted most international travel as part of the European Union’s suspension of non-essential travel to the EU. For the 30-day period beginning March 22, non-EU/Schengen Area nationals will be denied entry unless they are (1) residents of another EU/Schengen Area member state traveling directly to that member state, (2) holders of long-term visas issued by an EU/Schengen Area member state who are traveling directly to that member state, (3) cross-border workers, (4) healthcare or eldercare professionals traveling for their work, (5) individuals who are transporting goods or who are part of flight crews, (6) consular office personnel, diplomatic mission members or military or international organization personnel who are traveling for their work, (7) individuals traveling on duly accredited imperative family reasons, or (8) individuals who have documentation of a need or an unforeseen circumstance or who should be let in for humanitarian purposes. EU/Schengen Area nationals will only be let into Spain if they meet one of the exceptions listed above, are registered residents of Spain or are going directly to their place of residence in another EU/Schengen Area country.
  • Land borders. Land border remain closed, with exceptions for Spanish residents, cross-border workers, individual with cases of force majeure or those transporting needed supplies. Spanish entry and exit points in Ceuta and Melilla are also temporarily closed.

Analysis & Comments: The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

IMPACT – HIGH

The Spanish government recently announced stronger travel restrictions to mitigate the spread of COVID-19.

 Effective from March 23 at midnight, third-country nationals and EU nationals and their dependents, are no longer allowed to enter the country, with a number of exceptions, including:

  • Spanish residents or residents in transit to their homes in other Schengen Area or EU member states.
  • Long-term visa holders who have visas from Schengen Area or EU member states who are traveling to those places.
  • Professionals engaging in healthcare and elder care who are traveling for work.
  • Transportation personnel who are working to ship goods and flight crew who are working while engaging in commercial aviation tasks.
  • Consular office personnel, diplomatic mission members, and military and international organization personnel who are performing professional work.
  • Individuals with very important family reasons for traveling.
  • Individuals who have documentation of a need or an unforeseen circumstance.
  • Individuals whose movement is allowed because of humanitarian reasons.
  • The suspension also does not apply to these two areas: the inland border with Andorra and at a checkpoint for the Gibraltar territory.
  • Additionally, the inland borders with Ceuta and Melilla are temporarily closed for entering and exiting the country.

Analysis & Comments: The new travel restrictions will impact the mobility of third-country, and EU nationals and their dependents into Spain. It is likely the current state of alert will be extended. Employers should account for affected travelers and rearrange travel schedules accordingly. Significant delays may occur for consular and in-country processing.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Applicants for residence permits for highly skilled professionals are experiencing delays when booking appointments to have fingerprints taken at police stations in Barcelona.

What does the change mean? While applicants can usually begin working before fingerprinting is completed, the delays have caused problems for visa-required nationals who need to travel abroad before their fingerprints are taken and their permits finalized.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Residence permits, including residence permits for highly skilled professionals.
  • Who is affected: Employers and non-EU/EEA nationals applying for residence permits.
  • Business impact: Visa-required nationals may need to postpone international travel or obtain a visa if they need to leave Spain before they obtain their permits.

Additional information: The delays for highly skilled professionals are occurring in Barcelona, not other parts of Spain. Applicants for other types of residence permits, however, are seeing delays elsewhere in the country. In Madrid, for example, family members who are applying to join an EU national family member are experiencing significant delays when making appointments. Exact wait times will depend on the type of permit and the location in Spain.

Analysis & Comments: Employers are encouraged to work closely with Deloitte to determine the best options for employees who are experiencing processing delays or delays in making an appointment. Visa-required nationals who have urgent travel needs but do not yet have their residence permit should contact Deloitte immediately.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What does the change mean? Internal report requests (i.e., police records, social security status of company), which are required during the residence permit process, are taking longer than normal. Foreign nationals should anticipate that processing of residence permits will take longer than the 20 business days required by statute and should adjust their business schedules accordingly.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Residence permits for highly skilled professionals, ICT permits.
  • Who is affected: Employers and non-EU nationals applying for the residence permits listed above.
  • Impact on processing times: Processing times are longer than the standard 20 business days. Current processing times may range from 30 to 35 working days.

Background: Under the Entrepreneurs Act, the statutory processing time for residence permit applications is 20 days. However, the authorities may extend this processing time without prior notice. 

Analysis & Comments: Foreign nationals submitting visa applications should book an appointment at the consulate immediately after beginning the residence permit process. Since supporting documents for visa applications must be submitted 90 days after their issuance, and appointments are being scheduled up to three months in advance, applicants should confirm that submitted documents will be accepted once the appointment is assigned.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.  Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Immigration authorities have announced specific amendments to the Mobility Section of the Entrepreneurs’ Act that set out specific criteria for entrepreneurs, investors, researchers, and ICT permit applicants applying for work permits in Spain.

The specifics:

  • Financial qualifications.
    • Entrepreneurs. Monthly amount equivalent to at least 100% of the IPREM (Multiplier of the Public Income Index).
    • Investors. Monthly amount equivalent to at least 100% of the IPREM.
    • Dependents of entrepreneurs. Dependents, highly qualified specialists, researchers and third country nationals must earn a monthly amount equivalent to 150% of the IPREM for the first or primary dependent, and 50% of the IPREM for each additional dependent.
  • Document requirements. Documents provided with the initial and renewal application must be submitted in Spanish and must be apostilled by the Diplomatic Avenue. Educational documents must be recognized by the Spanish Education Ministry to be considered valid.
    • Investors. Equity investors are eligible for the Global Mobility permit if they have invested at least €500,000 (free of liens and encumbrances).
    • Entrepreneurs. Entrepreneurs must be able to prove three years of experience in the related job title.
    • Researchers. The Global Mobility permit for researchers is valid for two years or the length of the contract.
    • ICT permits.Those applying for an ICT permit must hold an applicable social security agreement, as long as it is in place between Spain and the home country. The remuneration must comply with Spanish employment law minimums, excluding bonus/variable payments and with maximum 30% of salary in kind.
    • Highly-qualified professionals: The remuneration threshold amounts to €54,142 for directors and managers; €40,077 EUR for technicians, excluding bonus/variable payments and with maximum 30% of salary in kind. A reduction coefficient of 0.75% is applicable for companies that belong to a strategic sector and when the individual is less than 30 years old.
    • Dismissals for highly qualified professionals: As long as the dismissal is notified and the individual is entitled to access to the unemployment benefit, his work permit can be renewed under Act 4/2000, General Immigration Law (generic work permit as employed person).
    • Medical coverage. Current permit holders must hold a valid health insurance policy to obtain a renewal permit.
    • Change of employer. Foreign nationals who change their employing entity must notify the authorities and request a new permit unless the change is covered under Section 44 of the Worker’s Statute.

Background: The Entrepreneurs’ Act entered into force on Sept. 30, 2013 and aims to boost the economy by attracting high-skilled foreign talent.

Analysis & Comments: Investors, entrepreneurs and researchers should account for the financial qualifications required to apply for a work permit as well as the new document requirements. Additionally, the above-mentioned applicants should be sure to obtain a valid health insurance policy prior to applying for a renewal permit. Failure to do so will lead to the rejection of the application.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.