Spain’s Digital Nomad Visa (DNV) has undergone significant updates following a leadership change inside the Digital Nomad & UGE office. These changes were confirmed during the Immigration Lawyer Congress in Córdoba last week and have caused a wave of concern—especially because the new criteria are being applied even to applications already in progress.

This article summarises the discussion inside the Spanish Digital Nomad Visa (DNV) Facebook group, where expert contributors, lawyers, and applicants shared firsthand insights.

1. What Has Changed?

A Quick Overview

According to long-time contributor Keith LM, the return of a previous director—one of the original architects of the DNV—has brought new interpretation criteria. Some requirements are now stricter; others are surprisingly more flexible.

But the biggest shock:

Even people who applied before the leadership change are being asked to meet the new requirements.

Here are the confirmed updates from the discussion.

2. Main Confirmed Changes

2.1 U.S. Certificate of Coverage (CoC) is no longer accepted

This is one of the most impactful updates.

• U.S. W-2 employees can no longer rely on the CoC for remote work in Spain.
• Only UK (A1), Russia, and Canada Certificates of Coverage are currently accepted.

Countries no longer covered for remote work under bilateral agreements include:
Colombia, China, and Chile.

2.2 Options for W-2 Employees (USA)

Even with the CoC restriction, Keith clarified that there are viable paths:

Option A: Switch to contractor (1099) status

• You apply as a freelancer instead of an employee.
• Important: You lose eligibility for Beckham’s Law.

Option B: Employer registers with Spanish Social Security

• Your company can register with Spanish SS and pay contributions in Spain.
• This has been done before, but requires administrative steps.

Option C: Apply via a consulate for the 1-year visa

• Some consulates are still accepting CoC for the initial application.
• But renewals won’t allow it.

Option D: A new alternative is being explored

• Lawyers expect clarification within 1–2 weeks.

2.3 Professionals (Doctors, Lawyers, Psychologists, Architects)

This part generated the most debate in the group. According to the new director’s interpretation:

Professionals must homologate their degree (validate it in Spain).

But several immigration professionals reported:

• Sworn statements confirming you will not practice in Spain are still being accepted as of a few days ago.
• The rules are shifting, and no one is fully certain whether homologation will become mandatory.

Important nuances from the discussion:

• No one has yet reported being required to homologate for remote-only work.
• Homologation takes 1–3 years and requires Spanish B2/C1.
• Psychologists may need to “rebrand” as “well-being consultants” if this change becomes strict.

2.4 Self-Employed (Autónomo) Applicants Must Register Immediately

This is a major procedural tightening:

• Anyone approved as autónomo must register with Spanish Social Security (SS) immediately.
• The director indicated it could even be backdated to the approval date, with a fine.

Why this matters:

• Backdating may affect eligibility for the first-year reduced Social Security rate.
• Registration delays are already causing problems for dependents being added to files.
• Renewals will check if autonomous registration was completed.

Important:
Group members confirmed you can register without your TIE as long as you have:

• a digital certificate
• a Spanish bank account
• NIE (as shown on the approval letter)

2.5 Apostilles & Translations

• Government-issued documents (except SS CoC/A1) must be apostilled + officially translated.
• Non-government documents (e.g., university degrees?) do not need an apostille, just a translation.
  • ⚠️ This point is still being clarified.

2.6 Renewals: Only One Month of Invoices Required

If renewing with the same company:

• Only one monthly invoice + proof of payment is required.

Some tax advisors in the comments, however, raised questions about how this works when switching from employee to autónomo mid-process.

2.7 Business Owners Can No Longer Apply Under Option C

Previously, digital nomads could apply as:

1. Employees
2. Self-employed
3. Self-employed business owners (Option C)

Option 3 is no longer possible, because:

• It creates a permanent establishment in Spain.
• That may invalidate DNV residency because DN visa holders cannot work for a Spanish entity.

However:

“It is still possible to apply as a business owner—just under a different structure.”

More guidance is expected soon.

3. Community Questions & Insights
Below are key concerns raised by group members and the answers given.

3.1 Should already-approved professionals (e.g., doctors) start homologation now?

• No one knows for certain.
• Current cases still show that sworn statements are accepted.
• Homologation is a long and difficult process; most lawyers advise waiting for official confirmation.

3.2 Can you register as autónomo without a TIE?

Yes.
Multiple commenters confirmed doing this successfully with:

• NIE + approval letter
• Bank account
• Digital certificate (some gestors can obtain this for you)

3.3 What if you registered for SS late (months after approval)?

This may cause renewal issues.

One commenter reported registering 6+ months late and is worried their renewal will be denied.

Keith’s advice:

• It may be possible to backdate with a fine.
• But this risks losing the reduced SS rate.
• More guidance is coming from tax/accounting teams.

3.4 Are nonprofits / NGOs / UN workers affected?

No specific guidance yet. Group members asked, but no definitive answer has been issued.

3.5 Is Employer of Record (EOR) still an option?

Not explicitly addressed, but historically:

• EOR has been used successfully for US employees.
• More clarity is expected with the new director’s rulebook.

4. Key Takeaways

• It is still possible to apply for the Digital Nomad Visa.
• W-2 applicants must adjust strategies.
• Professionals face possible degree homologation—but it’s not fully confirmed.
• Self-employed applicants must register with Social Security immediately.
• Renewals will be stricter, especially regarding autónomo registration.
• More updates are expected in the coming days as immigration lawyers meet with tax experts.

5. Conclusion

Spain’s Digital Nomad Visa continues to evolve rapidly. While the recent changes feel destabilising—especially for applicants already in the pipeline—immigration experts in the Facebook group agree on one thing:

Every issue has a solution. You may just need to adjust your strategy.

Experienced DNV specialists have already secured hundreds of approvals under shifting rules, and more clarifications are expected very soon.

If you’re applying soon or already approved, stay connected to reputable immigration professionals and community groups, as weekly updates are becoming the new norm.

This article is a summary of a public discussion from the Spanish Digital Nomad Visa (DNV) Facebook community and reflects the personal experiences, opinions, and interpretations shared by its members at the time of posting. It does not constitute legal advice, official immigration guidance, or a definitive interpretation of Spanish law. Digital Nomad Visa regulations may change frequently, and requirements can vary by consulate, region, and individual case. For personalised assistance, readers should consult a qualified Spanish immigration lawyer or legal expert.