Spain’s extraordinary regularisation process is placing pressure on immigration appointment systems, particularly for fingerprint registration and the issuance of residence cards. While these delays do not affect the validity of an approved residence and work authorisation, they may create practical difficulties where physical proof of status is required. Employers and applicants should expect longer lead times and review immigration status evidence and travel risks while physical cards remain pending.
Background on the current delays
Following the approval by the Spanish Government on 16 April 2026 of the extraordinary regularisation process for undocumented migrants, immigration authorities are experiencing a significant increase in workload and operational pressure.
Under this extraordinary regularisation scheme, foreign nationals who can evidence residence in Spain prior to 1 January 2026 and meet the applicable requirements may apply for a temporary residence permit and work authorisation.
According to official estimates, the Spanish administration has already received close to 550,000 applications. As a result, immigration authorities, particularly Police Stations, are currently facing substantial delays in the management of appointments related to fingerprint registration and the issuance of residence cards, known as the TIE card.
Appointment delays and TIE issuance
In recent weeks, we have observed:
The Spanish immigration process usually consists of two separate stages.
While the extraordinary regularisation scheme allows applications to be submitted electronically, including through legal representatives, it also allows individuals to schedule in person appointments at Police Stations. A large number of individuals, including applicants with limited access to digital tools are opting for in-person appointments.
This exceptional measure has significantly increased operational pressure on Police Stations nationwide and we expect this situation to intensify further in the coming weeks and months. As favourable decisions begin to be issued, individuals will start booking appointments for fingerprint registration and TIE issuance. This is likely to generate a second wave of demand on already saturated Police Station systems.
Immigration status pending TIE issuance
Despite the delays affecting fingerprint appointments and TIE issuance, an individual’s immigration status is not negatively affected solely by the absence of the physical residence card. Once the residence and work permit has been approved through a favourable administrative resolution:
While the favourable resolution confirms the individual’s legal immigration status in Spain, the resolution itself is generally not considered a valid travel document for re-entry purposes in Spain.
Individuals who need to travel before obtaining their physical residence card may face difficulties when returning to Spain, depending on their nationality, travel route, destination country and specific immigration circumstances. For this reason, each case should be carefully assessed individually in order to determine the most appropriate and legally viable alternatives before travelling.
In addition, employers employing affected individuals should retain the favourable resolution and any TIE appointment confirmation as part of the individual’s immigration file while the physical card remains pending.
We are currently assisting affected individuals and employers in managing the practical consequences arising from these appointment delays.
Our support includes:
Where travel is unavoidable, we can review and assess the available legal and practical alternatives on a case-by-case basis to minimise business disruption and immigration risk.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Elena Pérez Martin
Director
Elena Román Rodríguez
Senior Associate
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