The team arrived with a finished business plan and financial model — both written for investors. The first review showed they answered none of the three questions the authority actually assesses. The plan was rewritten from scratch: from the wording of the innovation to algorithm diagrams and a product demonstration. A month after filing the project was recognised as innovative.
- 2 months
- from first review to filing
- including reworking the concept and gathering project material
- 1 month
- to the decision
- filed at the end of May, recognised as innovative in June
- 4 founders
- on one project
- the lead founder files first, the others after his approval
- 10 working days
- the legal deadline for ENISA’s report
- the report is mandatory and the authority requests it itself
What they came with
They came to us in March. An IT project in cybersecurity: a security assessment service for mid-sized companies. The product was already working, the team assembled, the legal entity registered outside the EU — but dormant.
The team already had a business plan and financial model: written to talk to investors. That is a good document for its own purpose and the wrong one for this. The review took a day, and the conclusion was unambiguous: repackage.
How the timeline ran
-
01
Review of the existing plan
End of March. One day to conclude: the plan was written for investors and needs full repackaging.
-
02
Concept
A week. Analysis of comparable projects and of the pain points in the Spanish market, with sector reports and the national cybersecurity strategy as the base.
-
03
Gathering project material
April. Algorithm and service diagrams, interface screenshots, a video walkthrough, CVs, hiring plan.
-
04
First version of the plan
Mid-April. Then a cycle of edits from both sides.
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05
Refinement
May. Client and investor letters, evidence of investment, corrections to the financial model.
-
06
Filing
End of May. Application to UGE and the business plan to ENISA.
-
07
Decision
A month later. The project was recognised as innovative and the lead founder approved.
-
08
The other founders file
From August, as each was ready.
What did not go to plan
Кейс прошёл не гладко. Ниже — то, что реально задержало или усложнило процесс, и что с этим делали.
The finished plan answered the wrong question
The team arrived with a document they had already invested time in: a business plan, a P&L, a hiring plan. All of it made for a conversation with investors.
Telling someone their finished document has to be rewritten is an unpleasant part of the job, but there is nowhere to postpone it: a plan written against the wrong criteria does not become the right one through editing.
The innovation had to be formulated again
The first answer to «where is the innovation» was about accessibility and price. True of the business model, wrong for the assessment.
We took the product apart down to the technology: which algorithms sit inside, what the principle of each one is. Without a technical specialist on the team’s side this is impossible — a consultant cannot invent your innovation for you, only help you state it.
Client and consultant saw the project differently
To the draft concept the team replied bluntly: «you are describing a slightly different project, you are not in context yet». That was the right reaction — they proposed going through the text together and explaining what they actually do.
The concept ended up being assembled from both sides. It takes longer than silently accepting someone else’s text, but the result was both more accurate and more defensible.
The investor letter did not survive checking
A letter from an investment fund was attached to the plan. On checking, the fund’s own website turned out to state that it invests only in the medical sector.
«How could they possibly be interested in you» is a question to ask yourself before filing, not to hear in a document request. The letter was redone. The authority checks what you attach — what you attach has to stand up to checking.
What the costs were made of
| Item | Amount | Paid to |
|---|---|---|
| Concept stage | €200 | to us; a separate first step before the main work |
| Business plan preparation | by agreement | to us; fixed before the work starts |
| Application fee | €73.26 | to the state, per applicant |
| Residence card fee | €16.08 | to the state, per person |
| Sworn translations | by volume | to a third party; dearer for rare languages |
The concept is deliberately a separate paid step: it shows what the result will look like before both sides invest in a full plan. If it becomes clear at that point that there is no innovation, it is cheaper to stop there.
What we did
- Reviewed the existing business plan and explained why it does not meet the assessment criteria
- Studied the market, competitors and sector statistics for Spain and Latin America
- Formulated the project concept against the innovation requirement
- Gathered technical material from the team: algorithm diagrams, screenshots, a video walkthrough
- Wrote the business plan and agreed it with the team over several iterations
- Adjusted the financial model to a realistic growth curve
- Checked client, partner and investor letters for internal consistency
- Prepared the motivation letter
- Supported the remaining founders’ filings after the lead founder’s approval
What the service did not cover
Obtaining Schengen visas for entry is not our area: it is a separate procedure with separate providers.
Criminal record certificates and their legalisation in the countries of residence are obtained by the applicants themselves; we explain which ones are needed and for what period.
Tax questions are handled by us as well — that is Dmitrii Sheinkman, tax adviser. In this file the team asked about the 183-day rule and tax residence: questions of that kind are dealt with in a separate consultation rather than alongside work on a business plan, because the practice there is its own and the cost of a mistake is high.
Registering a company in Spain after approval is a separate service.
First and most important: innovation is an evaluative judgement. ENISA’s report is mandatory, but it gives nobody any guarantee. We say «this plan needs rewriting» before the work starts, not after a refusal, and if a project has no innovation in it we will say that too.
Second: a consultant does not invent the innovation for the client. In this file it existed — it had to be extracted and stated. If there is no technological novelty at all, no amount of packaging will create one, and it is more honest to look at other routes.
Third, about the case itself. This file is from 2024. The procedure has changed since: a new immigration regulation came into force in 2025, and since January 2026 ENISA and UGE again issue two separate decisions instead of one. Read this case as an analysis of what is assessed, not as a step-by-step guide to timelines.
Questions we had to answer
Why did a finished business plan not work?
Because the authority does not read it as an investor does. The law sets out exactly what is assessed: the applicant’s professional profile and involvement in the project — including partners who are not applying themselves; the plan itself, describing the project, the product or service and its financing, including the investment required and possible sources; and the elements that create added value for the Spanish economy — innovation or investment opportunity.
An investor deck answers a different question: how much we will earn and when. There is overlap, but not much of it.
What counts as innovation and what does not?
The team’s first formulation was this: our innovation is accessibility for the mid-market, simplicity of the result, and price. That describes a business model. It may be true and it may be strong, but it does not answer the question about innovation.
We had to take the product apart down to the technology: which algorithms run inside it, what their principle is, how that differs from how others do it. This is not rewording — it is different work, and it cannot be done without a technical specialist on the client’s side.
What goes with the plan besides the text?
In this file: schematic and technical diagrams of the service, block diagrams of the algorithms, screenshots of the client and admin interfaces, a video walkthrough (published unlisted), CVs of all founders, letters from clients confirming readiness to buy, letters from partners, an investor letter, evidence of investment already made, and the team’s certificates and diplomas.
There is no limit on quantity: the material goes into a folder and you give a link to it.
How do you evidence investment already made?
There is no prescribed form. Usually it is a table — cost item against amount, signed by a founder. Supporting documents such as contracts and payments are a plus but not a condition.
What matters more is that the figures agree with the financial model and do not contradict it.
What else is looked at besides documents?
What is visible from outside. A company page on a professional network with not a single post, a website with no Spanish version while the plan claims a focus on Spain, a legal entity registered in another country with no activity — all of this gets checked and raises questions.
Part of the work in this file was not in the documents at all: publishing project news, bringing the website into line with the market claimed, and explaining the status of the foreign entity in the plan itself.
How does a team of several founders file?
The lead founder files first. The others follow after his approval, with the same document package plus his application number.
In ENISA’s portal the remaining founders need only the business plan itself: CVs go as an annex to it, and a separate bank certificate is not required. After approval each person books a fingerprint appointment where they live — the padrón is not needed everywhere.
Which countries’ criminal record certificates are needed?
For the last five years, from every country where you lived for more than six months. It is counted from the stamps in your passport.
If documents were issued in a country with a rare language, check in advance with sworn translators whether they will take it on and at what price: sometimes there are few translators and the cost is a surprise.
Sources
Нормы и официальные материалы, на которые мы опирались. Ссылки ведут на первоисточники — проверяйте.
- Ley 14/2013, de 27 de septiembre, de apoyo a los emprendedores y su internacionalización Art. 70 — entrepreneurial activity as innovative or of special economic interest; the mandatory ENISA report within ten working days; the three assessment criteria: the profile and involvement of each partner, the business plan with its financing, and added value for the Spanish economy. Art. 76 — the review period and positive silence
- Real Decreto 1155/2024, de 19 de noviembre — Reglamento de la Ley Orgánica 4/2000 The immigration regulation now in force; adopted after this file and replacing RD 557/2011