Business plan for the Spain startup visa: the ENISA questionnaire, criteria and reasons for refusal

A business plan for Spain’s startup visa is not a free-form document but an online questionnaire on ENISA’s website. From it, ENISA writes a mandatory report for the UGE on whether the project is innovative and of special economic interest to Spain, scoring innovation, scalability, finances and team. Without a favourable report, no entrepreneur permit is granted.

Below: who reads the plan and against which criteria, what to write in each section of the questionnaire, how to demonstrate innovation and money, why applications are refused, in what order to file and how long it takes. The route as a whole — timelines, family documents, cost — is covered on the Spain startup visa page. A step-by-step walkthrough of the form is in our guide how to prepare a business plan for ENISA (guide in Russian).

Who reads the business plan and what they decide

“Startup visa” is the everyday name for the entrepreneur residence permit under Article 69 of Law 14/2013. Since 23 December 2022, when the Startup Law 28/2022 came into force, the permit is issued for three years and then renewed for two; after five years you can apply for long-term residence. The application is filed only electronically and only with the UGE (Unidad de Grandes Empresas y Colectivos Estratégicos).

Two bodies read the file, and each has its own part. The UGE checks you: passport, criminal record certificate, health insurance, funds, fee. ENISA (Empresa Nacional de Innovación) assesses the project and answers the UGE with a “favorable” or “desfavorable” report. The report is mandatory: without a favourable conclusion from ENISA, the activity does not count as entrepreneurial in the legal sense, and the permit is refused.

The three things the law assesses

Article 70 names three subjects of assessment:

• The applicant’s profile and involvement in the project. Where there are several partners, the role of each is assessed — both those who need a residence permit and those who do not.
• The business plan: a description of the project, product or service, and its financing — how much needs to be invested and where the money will come from.
• Added value for the Spanish economy: innovation or investment opportunities.

The activity must be innovative and/or of special economic interest to Spain. The “and/or” matters: a project can qualify on scale and economic benefit even without breakthrough technology. And the UGE states plainly that there is no minimum investment and no minimum number of jobs. What is assessed is the quality of the project, not the size of the cheque.

The practical assessment rules are set out in two documents: Instruction DGM 1/2023 of the Ministry of Inclusion and ENISA’s guide to completing the questionnaire (Guía Visados 2026). Everything below about sections and criteria comes from them.

The business plan is an ENISA questionnaire, not a PDF

The most common misconception, repeated in founder chats for years: “I’ll write a 40-page plan and upload it.” There is nowhere to upload it. The plan is completed in your ENISA online account: section “Autorización de residencia para emprendedores” → “Rellenar formulario”. The questionnaire has three parts — registration, applicant details and the plan itself (Plan de negocio). Fields have length limits, some data goes into tables, and most sections allow a supporting file to be attached. A draft is saved with the “Guardar” button, so you can complete it over several sessions.

A template for your draft. It is easier to write the plan outside the portal first and then paste the finished text into the questionnaire. For that we publish our ENISA 2026 template (in Russian and Spanish) — every section of the questionnaire in its order, with a note on where a file can be attached and a list of the CNAE codes that most often fit startups. It comes with a spreadsheet that checks the character limits automatically, so text that will not fit a field shows up straight away. Make your own copies of both files and fill those in.

ENISA’s guide makes two warnings. First, the assessor does not know your project, so the clearer and more concise you are, the easier the assessment. Second, the information must be truthful and verifiable. This is the key to the whole questionnaire: every claim — about customers, technology, the team — needs something to back it up.

You do not need a company before applying

The applicant section offers two options: a company already exists in Spain (then its name, NIF, CNAE activity code and address) or there is only a project (name, CNAE code and the province where it will operate; NIF and address are optional). You do not have to set up an SL just to apply. But if you intend to renew the permit after three years, build the company and its incorporation timeline into the plan from the start.

Language of the plan

Instruction DGM 1/2023 allows project information to be submitted in English. A sworn translation can be requested only if the application cannot be assessed without it. Documents for the UGE — certificates and records — follow the general rules: apostilled and, if not in Spanish, with a sworn translation. In practice founders complete the questionnaire in English or Spanish; unedited machine translation shows and hurts the impression.

There is no interview

ENISA does not meet the applicant or ask for a pitch. The assessment is based on the questionnaire, the attachments and public sources: the guide says outright that LinkedIn may be used to check the team’s experience. If your experience is not visible from the questionnaire and your public profile, for the assessor it does not exist.

Innovation: how to demonstrate it

According to ENISA’s own guide, its report rests on two scores: the degree of innovation and the degree of scalability. Innovation can lie in the business model, the product or service, processes, proprietary technology or patents.

The short route: objective criteria

The section opens with an optional item. If the project has at least one of the following, that alone is enough for ENISA to recognise it as innovative:

• public funding or aid for research, development and innovation (I+D+i) in the last three years, not revoked for non-compliance;
• an award or recognition as an innovative company — winner or finalist, at least at regional level;
• a reasoned report from the Ministry of Science confirming a high degree of innovation (used for I+D+i tax deductions);
• social security rebates for hiring researchers;
• the Pyme Innovadora label, AENOR certificates for young and small innovative companies, or certification to the UNE 166.002 standard.

For a project that is only now moving to Spain, this is usually rare. But if your company abroad holds a grant, an award from a regional-level accelerator or a comparable certificate, attach it first.

The main route: five ways to describe what is new

• Patents. Filed patents count, granted ones even more so, whether owned by the company or available to it under a right of use. Trademarks and trade names do not count; software and know-how do. The patent must be connected to the project’s business.
• Proprietary technology. For an operating company ENISA looks at the share of research and development spending: at least 15% of total expenses over the past two years, or over the past year for a company younger than two years.
• New processes — a new or significantly improved method of production or delivery in the territory or the sector.
• New product or service — a new or substantially improved market offering: technical specifications, components, materials, software.
• New business model — what sets the product apart from competitors and gives a clear advantage in the market or sector.

The word “innovation” in the questionnaire proves nothing. You need to explain how the solution works, how it differs from what already exists in Spain, and attach evidence: a product diagram, a link to a working version, a technical description, a patent application. In practice, a mere mention of artificial intelligence is no longer enough: AI has become background, and assessors look for what else in the project is new.

There is also a limit on the other side. Under Instruction DGM 1/2023, ENISA may issue an unfavourable report if the model raises reasonable doubts because of reputational, regulatory, ethical or speculative risks. Projects on the edge of regulation — cryptocurrencies, gambling mechanics, questionable financial schemes — fare worse.

Scalability and market: eight blocks of the questionnaire

ENISA measures special economic interest for Spain through scalability. In the questionnaire this means eight blocks, and each receives its own score in the report.

Questionnaire block	What they want to see	How to back it up
Market attractiveness	Growing demand, barriers to entry, level of competition, growth without a proportional rise in costs	INE data, industry reports, an estimate of market size in Spain
Company stage	Whether the product is on the market, since when, how far it is from sales	Link to the product or MVP, launch date, interim results
Business model	How you make money, what you invest in and on what, jobs, timelines	Price list, revenue model, investment tables and a 4-year forecast
Competition	Direct competitors, their share, how you differ	A competitor table with point-by-point differences
Team	Industry and management experience, division of roles	CVs, LinkedIn, degrees, publications
Partners and shareholders	Partners’ experience, commitment, solvency, professional investors	Shareholdings, investor letters, letter of intent
Suppliers	Key contractors and how replaceable they are	Contracts, commercial quotes
Customers	Whether there are customers, their concentration, repeat business, acquisition cost	Contracts, letters of intent, last year’s revenue

Better not to leave blocks empty, but you must not invent anything either: if there are no customers yet, ENISA’s guide allows that table to be left blank. The strength of the project is then shown through the other blocks — market, product stage, team, partners. In practice, arrangements in Spain specifically make a visible difference: a Spanish customer, a partner, a pilot with a municipality, a letter from a local investor. Sales in another country show that the product works, but they do not prove benefit to the Spanish economy.

The financial plan and the founder’s own funds

The financial part of the plan and the money in your account are different things, checked by different bodies.

The financial plan for ENISA

In the business model block, ENISA’s guide requires:

• the purpose of the investment: what the money is needed for, what it costs, how it will be financed, how many jobs it will create and on what timeline;
• a breakdown of the investment: tangible and intangible assets, the share for working capital and other items;
• a quantified investment schedule for at least the next 18–24 months — the figures must match the breakdown;
• a financing schedule for the same 18–24 months: what partners contribute through capital increases and what comes from the company’s own cash flow;
• a forecast for each of the next four years and, if there is a closed financial year, its actual figures.

For a wealthy founder, the main temptation here is to show a large sum and a generous forecast. Assessors are persuaded not by size but by coherence. If the plan shows €400,000 of your own investment, it should be clear exactly where it goes over the first two years, when you will hire your first employees in Spain and why third-year revenue comes out at that figure. Unrealistic growth, salaries unconnected to the workload, expenses missing from the investment table — these are typical reasons for a low score on the business model. If funding will come from a business angel or a fund, say so in the partners block: ENISA asks separately about professional investors.

Living funds for the UGE

This is a separate requirement under Article 62 of Law 14/2013. Instruction DGM 1/2023 sets the benchmark:

• for the founder — 200% of the Spanish minimum wage (SMI) per month, currently €2,849 per month, or €34,188 per year;
• for a second family member — at least 75% of the SMI, i.e. €1,068 per month;
• for each additional family member — 25% of the SMI, i.e. €356 per month.

Funds can be proven by any means; the UGE looks at each case individually. You must show that the money belongs to you, was obtained lawfully and is available. The instruction does not say for how long the sum must be held. For a family with capital in several countries, it is worth preparing statements and an explanation of the source of funds in advance: the question of whether the money is lawful comes up more often than the question of the amount.

Besides funds, the application includes health insurance from a company operating in Spain (travel insurance does not qualify; more in health insurance for a Spanish residence permit) and a declaration that you will meet your social security obligations before starting the activity. The 790-038 fee for an initial application is €73.26 per applicant; how to pay it is explained in the guide paying fee 790-038 (guide in Russian).

Team and co-founders

Approval goes not to the project as such but to each founder, and each founder’s experience is checked against their role. In the team table, ENISA asks for position, function (technical, financial or business), years of experience in the industry and in management, and a link or document as proof. At a minimum, the founder’s own details.

• The role in the questionnaire, the CV and LinkedIn must match. The assessor will notice “CTO” in the plan versus “sales manager” in the profile.
• Experience must relate to the project’s niche. A finance professional launching a medical service strengthens the application with a doctor or technologist as partner.
• The team can include people who do not need a residence permit: the law expressly says that the involvement of all partners is assessed, not just the applicants.
• Each co-founder files their own application with the UGE. In practice each also completes their own ENISA questionnaire, and the project name must match letter for letter.

The founder’s family members — spouse, children — are not written into the plan and do not go through ENISA’s assessment: the UGE handles their applications itself. In practice the family gets a decision sooner than the founder precisely because no ENISA report is needed for them.

Tell us your situation — we reply within the hour

WhatsApp

or leave your contact and we will write first

Where should we reply?

We reply within an hour during working hours. We never call without warning.

I agree with privacy policy

Send question

Common mistakes and reasons for refusal

An ENISA refusal usually comes as a table: a score for each criterion, from “high” to “insufficient”, without a detailed explanation. In the refusal breakdowns founders have shared in the startup visa community from 2023 to 2026, the same reasons keep recurring:

1. The innovation is not visible. The most frequent wording is a low degree of innovation. In practice, if this criterion fails, the other scores drop as well.
2. No benefit to Spain is shown. Not to the world or the EU, but to the Spanish economy: what problem you solve, what jobs you create. Benefit to the economy and your company’s profit are different things.
3. Weak differentiation from competitors. “We have no competitors” reads as not knowing the market.
4. Claims without evidence. “We have partners”, “we have customers” without letters, contracts or links do not count.
5. The team does not fit the project, or the founder’s profile is empty.
6. No traction in Spain: no customers, partners or pilots here specifically.
7. An over-optimistic forecast and figures that do not reconcile between tables.
8. A project invented for the visa. An ordinary service business — an agency, a shop, a salon — without technological or business-model novelty does not pass, however well it performs.
9. An incomplete questionnaire. Empty innovation blocks or an unfilled team table are a reason for refusal in their own right, and an easy one to avoid.

How to apply: ENISA, the UGE and timelines

The sequence is described in the UGE instructions for entrepreneurs:

1. ENISA questionnaire. Register on enisa.es, open the entrepreneurs section, complete and submit. ENISA notifies the UGE that the questionnaire has been filed. Keep a screenshot showing the number of the submitted questionnaire: in practice the UGE may ask for it in a request for further information.
2. Documents for the UGE. A signed MI-T form (a filled-in sample is in the guide how to complete form MI-T, in Russian), the 790-038 fee receipt, a scan of every passport page, proof of funds, health insurance, and a criminal record certificate covering two years plus a declaration covering five (criminal record certificate for a residence permit).
3. Application on the UGE e-portal (sede). Log in with a digital certificate or Cl@ve (digital certificate in Spain), application type “Inicial”, files up to 24 MB, then sign and receive a receipt with the registration number.

ENISA does not start the assessment on its own: under Instruction DGM 1/2023, the UGE requests the report only after it has admitted the application for processing. Uploading the questionnaire and waiting for an answer without a UGE application achieves nothing. So the questionnaire and the application are filed within a day or two of each other, and the UGE documents are prepared in parallel with the plan: the criminal record certificate and apostille take weeks.

You can apply from within Spain — in which case your lawful stay is extended while the application is pending — or from abroad, where the permit and the visa are requested in a single application, and after approval you collect the visa at the consulate and enter Spain. After entry, or after approval in Spain, you obtain a TIE card.

How long it takes

By law, ENISA issues its report within 10 working days of the UGE’s request, and the UGE decides within 20 days; if it stays silent, the permit is deemed granted. But while the UGE waits for the mandatory report, its decision clock is paused — under Article 22 of Law 39/2015, for no more than three months. In practice the ENISA report arrives within one to three months, longer in summer. If you receive a request for further information, you have 10 working days to respond — how to answer is in the guide UGE requests for information (in Russian). When you can rely on administrative silence is covered in the article UGE silence.

If ENISA issues an unfavourable report

The ENISA report is not a decision in itself. The decision is made by the UGE, and that is what you appeal: an administrative appeal (recurso de alzada) is filed within one month of notification. In practice, appeals that dispute ENISA’s assessment on the merits do not succeed: the authority does not revisit its innovation score on the applicant’s arguments. What works is a fresh application with a reworked plan: strengthen the innovation section, add evidence, fix the team and the figures. The law does not limit repeat applications, but it is a new UGE application with a new fee.

Keep an eye on your permitted stay. If you are in Spain visa-free or on a Schengen visa, your lawful basis to remain may end after a refusal. What to do in that case and how to count appeal deadlines is covered in the article Spanish residence permit refusal.

After approval: the plan does not go away

The business plan is not just an entry ticket but also the yardstick three years later. At renewal, the UGE checks whether the conditions on which the permit was granted still hold, and under the UGE instructions the ENISA questionnaire is completed again — this time about how the project has developed. In practice an exact match with the original figures is not required, but the activity must be real. How renewal works and when switching to another permit is the better option is covered in the article Spain startup visa: renewal and switching to other permits and in the guide how to renew an entrepreneur permit (in Russian).

Three more things worth planning before you apply:

• Tax. Moving to Spain to carry out an activity that ENISA has recognised as entrepreneurial is one of the grounds for the Beckham Law regime (Article 93 of the IRPF Law). The election is made in the first months after registering with social security, so the decision needs to be taken in advance — especially with substantial capital held abroad.
• Startup certification. Empresa emergente status under Law 28/2022 is a separate, free ENISA procedure for an already incorporated company, with its own tax incentives. The residence permit report does not replace it, and vice versa.
• Funding. ENISA loans and grants are separate procedures with their own requirements: ENISA funding and business grants in Spain. If they are part of your financing plan, say so honestly — as a possible, not a guaranteed, source.

Key points on the startup visa business plan

• The plan is a questionnaire on the ENISA website, with fields, tables and attachments, not a free-form document.
• ENISA assesses innovation and scalability; the UGE assesses the applicant’s documents and funds.
• There is no minimum investment or job count; what persuades is verified facts and coherent figures, not large sums.
• Investment and financing are set out for 18–24 months, the forecast for four years.
• The questionnaire and the UGE application are filed together: without the application, ENISA will not start its assessment.
• After a refusal, what helps is a reworked plan and a fresh application, not arguing with the score.

If you want to know whether your project meets ENISA’s criteria before investing in the preparation, book a consultation.

Frequently asked questions about the startup visa business plan

What comes first, the ENISA questionnaire or the UGE application?

File them almost simultaneously. ENISA starts its assessment only at the UGE’s request, and the UGE requests the report after it has admitted your application for processing. The UGE instructions list the ENISA questionnaire as the first step, but if you complete it and wait, the project will sit untouched.

Can the business plan be written in English?

Yes. Instruction DGM 1/2023 allows project information to be submitted in English; a sworn translation may be requested only if it is needed for the assessment. Documents for the UGE — certificates and records — are submitted in Spanish or with a sworn translation.

Do I need to set up a company in Spain before applying?

No. The ENISA questionnaire has a “company not yet incorporated” option: you give the project name, the activity code and the province. The company will be needed later, so build its incorporation and timeline into the plan from the start.

Do I need patents, customers or investors for ENISA to approve the plan?

None of them is mandatory: the law requires neither patents nor a minimum investment. But each piece of evidence strengthens the score. In practice, projects without patents or investment have been approved — with a working product, customer letters and arrangements in Spain.

Does a non-IT project qualify for the startup visa?

Yes, if it has novelty in its product, process or business model and can grow beyond a single city. An ordinary service without such novelty — a café, an agency, a shop — does not pass ENISA’s criteria, even if it is profitable.

How long does ENISA take to review the business plan?

By law, 10 working days from the UGE’s request. During that time the UGE’s decision clock is paused, but for no more than three months. In practice the report arrives within one to three months, longer in summer.

Is there an interview or a pitch in front of ENISA?

No. ENISA assesses the questionnaire, the attachments and public sources, such as your LinkedIn profile. So everything that should convince the assessor has to be written and evidenced in the questionnaire itself.

How much money do I need in the bank for the startup visa?

Under Instruction DGM 1/2023, 200% of the SMI per month for the founder, currently €2,849, plus 75% of the SMI for a second family member and 25% of the SMI for each additional one. These are living funds for the UGE; investment in the project is described separately, in the financial plan for ENISA.

Does each co-founder need their own business plan?

Each co-founder files their own application with the UGE, and ENISA assesses each partner’s involvement. In practice each completes their own questionnaire for the same project, with an identical project name and their own role in the team.

Can I reapply after an unfavourable ENISA report?

Yes, the law does not prohibit reapplying. It is a new UGE application with a new fee and a new ENISA questionnaire. In practice, repeat applications with a reworked innovation section and evidence have been approved, whereas appeals against ENISA’s assessment itself have not.

Sources

• Law 14/2013 on support for entrepreneurs, Articles 62, 69, 70, 76 (BOE)
• Startup Law 28/2022 (BOE)
• Instruction DGM 1/2023 on entrepreneur applications (Ministry of Inclusion)
• ENISA: Guía Visados 2026 — guide to completing the questionnaire
• UGE: instructions for filing an entrepreneur application
• UGE: “Emprendedores” page
• Law 39/2015 on administrative procedure, Articles 22 and 122 (BOE)
• Law 35/2006 on IRPF (personal income tax), Article 93 (BOE)
• ENISA: empresas emergentes certification