How we answered a document request that was about the client, not the applicant

A family of four obtained the digital nomad permit on a single filing. Along the way the authority sent a document request — not about the applicant but about the company he works for: it wanted proof that the client is genuinely trading. We answered on the fourth working day of ten and the decision came two days later. Before that the family had travelled across the country for a fingerprint appointment for nothing — rules at police offices change without notice.

37 days
from filing to approval
including the document request, which suspends the clock
4 people
on one filing
two adults and two children
10 working days
to answer the request
we answered on the fourth
€73.26
fee per person
plus €16.08 for the residence card, also per person

What they came with

They came to us in early September, six weeks before the move. Remote work under a contract between two sole traders; income evidenced by bank statements and the invoices behind the payments. Documents from the country of origin: a degree, criminal record certificates, marriage and birth certificates, and a register extract for the client company.

The distinctive thing about this route is that you are not only proving yourself. The law requires evidence that the company or sole trader you work for has been genuinely and continuously trading for at least a year. That is exactly where the request landed.

How the timeline ran

  1. 01
    Assessment and document list

    Early September. What was needed for the applicant, the family and the client, sequenced from the slowest document.

  2. 02
    Documents from the country of origin

    September–October. Criminal record certificates with apostilles, apostille on the degree, a paper register extract for the client with an apostille.

  3. 03
    Translations

    October. Sworn translations at around €30 a document. The bank statement needed no sworn translation.

  4. 04
    Arrival and entry declaration

    19–20 October. The head of the family had no entry stamp; the declaration was arranged separately.

  5. 05
    Filing

    21 October, all four on one filing. Some translations were uploaded to the file afterwards to avoid losing a day.

  6. 06
    Document request

    21 November. The authority asked for proof that the client is trading: invoices or evidence of tax payments.

  7. 07
    Answering the request

    25 November — the fourth working day of ten. Tax payments, issued invoices and a written explanation.

  8. 08
    Approval

    27 November, two days after the answer. Decisions for all four.

  9. 09
    Fingerprints

    29 December, in the province of the address on the application — after a wasted trip to another city.

What did not go to plan

Кейс прошёл не гладко. Ниже — то, что реально задержало или усложнило процесс, и что с этим делали.

No entry stamp at the border

Discovered at home going through the passports: three had the stamp, the head of the family did not — they had been handed over as a stack. Without it there is no way to evidence the entry date, and therefore no way to file.

You have three days to file an entry declaration, weekends included. The regulation allows any police station, but the nearest airport refused and sent them to the airport of arrival. It was done, and the filing slipped by a day.

The request was about the client, not the applicant

A month after filing the authority demanded proof that the client is genuinely trading: invoices or evidence of tax payments.

This is not nit-picking. The law expressly requires genuine and continuous activity by the client for at least a year — it is simply that at the outset a register extract is normally accepted, and here they decided to check. We gathered tax payments and issued invoices, added a written explanation and uploaded on the fourth working day of ten. The decision came two days later.

The trip for fingerprints was wasted

The family had no padrón yet, and in the two largest cities fingerprints are taken without one — that is how it went for another client of ours a month earlier. Four appointments were booked, the family travelled, and were refused: in the system the file is tied to the province of the address on the application, and an officer can only change that address against a local padrón.

Rules at police offices change without notice and are applied differently by different officers: what worked a month earlier did not work here. We covered the cost of the new appointments.

Appointments are taken by bots

Catching a free slot at the right office by hand is close to impossible. Some offices open booking only to holders of a digital certificate, and one certificate yields no more than three bookings — not enough for a family of four.

In the end the booking went through a contractor at €50 an appointment. Even then the right office did not come up at once: neighbouring towns were offered first.

What the costs were made of

ItemAmountPaid to
Our work €3,500 to us; fixed before the work starts
Application fee €73.26 to the state, per applicant; €293.04 for four
Sworn translations €447.70 to a third party, package for four; around €30 a document
Residence card fee €16.08 to the state, per person
Fingerprint appointment €50 to a third party, per person; slots are taken by bots
Courier for certificates by quote to a third party, where nobody can collect in person
Autónomo contribution, reduced rate €80/month to the state; this is the base — with the MEI surcharge the debit is around €88
Autónomo bookkeeping from €120 + IVA per quarter to us, under a separate contract

State fees and third-party services cost the same whoever you work with. Apostille and translation costs depend on how many people are on the application: here there were four.

What we did

  • Built the document list for the applicant, the family and the client, sequenced by lead time
  • Prepared the form of contract with the client to meet the authority’s requirements
  • Arranged the criminal record certificates with apostilles and their delivery
  • Explained the apostille route for the degree and the register extract
  • Aligned name spellings across all translations with the passports
  • Completed the forms, produced and paid the fee receipts
  • Filed for all four on a single application
  • Handled the document request: gathered evidence of the client’s activity and wrote the explanation
  • Booked the fingerprint appointments and prepared the police paperwork

What the service did not cover

Obtaining originals in the country of origin — apostilles on the degree and the register extract — is on the client: personal attendance or a power of attorney. We explain the procedure and arrange a courier where that is possible.

The padrón is registered at the town hall of your place of residence, and every municipality has its own rules: somewhere it is a walk-in, somewhere the next slot is two months away. We cannot always advise on a specific town — that is better checked locally.

Finding accommodation and opening a bank account were not part of the service. Autónomo bookkeeping is a separate contract.

A document request is not a sign of a bad file. It is a normal part of the procedure: the authority may ask for any document on the list of requirements, and most often it asks about the client rather than the applicant. Our job is to have the answer ready fast and complete.

Fingerprints carry a separate difficulty worth knowing about in advance. Rules at police offices change without notice and are applied differently by different officers: what worked a month earlier for another client did not work here, and the family travelled for nothing. That is why we present such options as a probability, not a guarantee. We covered the cost of rebooking in this file.

Questions we had to answer

What documents are needed about the client, rather than about you?

The law asks for two things: genuine and continuous activity by the client for at least a year, and a relationship with them existing for at least the three months before filing. Plus evidence that the work can be done remotely, and on what terms.

At the outset a register extract with an apostille and the contract will usually do. But if the authority has doubts it will ask for proof that the client actually trades — invoices they have issued, or evidence that they pay their taxes. Collect that before filing: hunting for it during a request costs days out of the ten you are given.

Is a degree compulsory?

No. The law allows two routes: a bachelor’s, master’s, vocational or business school qualification — or at least three years of professional experience.

If you go the degree route, one is enough, preferably the master’s. The apostille goes on the original itself and is bound to it; an extract from a register of qualifications will not do. If the degree is in the national register the apostille is quick, on the order of five working days. If it is not, you first have to ask the university to enter it, and that is the main source of delay in the whole package.

Transcripts do not need translating — only if you plan to study here later.

What is not required for this permit?

A tenancy agreement is not required — you can regularise while staying with relatives or in a hotel.

Private medical insurance is not compulsory if you register as autónomo: social security contributions cover healthcare for the whole family. You can still take private cover for convenience, and then it may be deducted as an autónomo expense — up to €500 per family member.

No pension fund certificate is needed. Originals need not be brought to Spain: filing is electronic and scans suffice.

What if you were not stamped in at the border?

File an entry declaration. You have three days from entry, and they are calendar days: weekends and holidays count.

Under the regulation in force it is accepted at any National Police station. In practice you are often sent to the airport of arrival even if another is closer, and officers frequently quote 72 hours — stricter than the rule, but arguing costs more than complying. Take your boarding pass: that is what evidences the date.

Without an entry record you cannot file: the authority has no way to verify that you were lawfully in the country on the filing date.

What happens when a document request arrives?

The review is suspended and you are given ten working days to answer. Missing that means refusal.

A request is not in itself a sign that something is wrong with your file: the authority simply wants to see one more document. Answer quickly and completely — here the answer went in on the fourth working day and the decision came two days after it.

Where can you give fingerprints?

The file is tied to the province of the address stated in the application. Giving fingerprints in another province without being registered there is luck, not a right: in the two largest cities it sometimes works, but the officer may require the padrón and turn you away.

The police’s official answer: either wait for the padrón and book afterwards, or process the card at the same address used for the application and then, once registered, request a duplicate card for the change of address — but the fee is payable again.

A separate difficulty is the booking itself. Free slots are taken by bots, some offices open booking only to holders of a digital certificate, and one certificate yields no more than three bookings. Hence the contractors who catch them.

When should you register as autónomo after approval?

As early as possible. Since late 2025 the authority has been opening revocation procedures against people who did not register after their decision — there are cases where the letter arrived forty days after approval, before fingerprints had even been given. The margin used to be far wider.

There is a counterweight: registering even for one day in a calendar year makes you liable for income tax for that whole year. So the date is a choice between two risks, and in December it is worth calculating separately.

You do not have to wait for your own bank account: an autónomo can be registered against someone else’s account with the owner’s written consent, and the collections moved to yours later.

Sources

Нормы и официальные материалы, на которые мы опирались. Ссылки ведут на первоисточники — проверяйте.

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