Renewals & permits
Last updated: 06 Aug 2026

Startup Residency Permit Renewal in Spain (2026): How to Renew the Entrepreneur Permit with ENISA

If you arrived in Spain on the entrepreneur (startup) residence permit under Law 14/2013, your first card expires after three years and renewal runs through UGE with a fresh ENISA assessment. This guide lists every document required in 2026, explains the second ENISA application, shares real approval statistics from renewal files, and covers the alternatives — Digital Nomad residence or a modification to cuenta propia — if your project no longer supports a renewal.

Renewals & permits
14 min read

Renewal document checklist

The renewal file is filed online with UGE (Unidad de Grandes Empresas y Colectivos Estratégicos) using a digital certificate, either your own or your representative’s. The list below is what renewal files actually require in 2026 — noticeably shorter than the initial application, but heavier on company paperwork.

Note what is NOT on the list: a criminal record certificate and proof of savings are not requested at renewal. What is requested is evidence that a real company exists, files its taxes and has no debts.

  • Passport — full scan of every page (pasaporte completo o documento de viaje en vigor).
  • TIE — scan of both sides of your current residence card.
  • Fee Modelo 790 código 038 — the completed form plus proof of payment (justificante de abono de la tasa).
  • Application form MI-T, signed by the applicant (formulario de solicitud firmado por el solicitante).
  • Company annual accounts (cuentas anuales) filed with the Registro Mercantil — normally filed in August, ask your gestor for the confirmation.
  • Modelo 347 — the annual declaration of transactions with third parties above €3,005.06, filed in February.
  • Certificate from the Tesorería General de la Seguridad Social showing the COMPANY is up to date with social security obligations, dated recently.
  • Certificate from the Agencia Tributaria showing the COMPANY is up to date with its tax obligations, dated recently.

The social security certificate trap (and how to fix it)

If your SL has no employees, the Tesorería often refuses to issue the "al corriente" certificate simply because the company has no contribution account. The fix is to open a company contribution account code (CCC) at Social Security — once the account exists, the certificate generates without problems.

The procedure is called "Empresario Colectivo. Identificación de Empresa. Asignación de CCC inicial" and is completed online with a digital certificate. What applicants report in practice:

  • Enter the main CNAE activity code taken from your company deed (escritura de constitución).
  • For "Entidad de accidentes de trabajo", pick the mutua that handled your company after incorporation (many report ASEPEYO).
  • Use today’s date — the form rejects dates earlier than the current day, including the incorporation date.
  • Enter the company address manually even though the system appears to prefill it; the form will not continue otherwise.
  • On the collective agreement screen, code 60888888888888 (EMPRESA NO SUJETA A CONVENIO COLECTIVO) is the neutral option; the form does not let you continue with no code at all.
  • Confirm on the final screen, tick the box, submit and download the conforme confirming the account was opened.

The second ENISA application

Renewal requires a fresh favourable ENISA report, and that means a second ENISA application form — the same questionnaire as the initial filing, enriched with what actually happened over the last two to three years.

A practical detail that catches everyone: you cannot submit a second application from the same ENISA account. Create a new account, using an email alias such as youremail+renewal@gmail.com, and file the renewal application there.

Structure your answers as a plan–do–check–act narrative. Reviewers want to see continuity, not a brand-new pitch deck.

  • What you planned in the original, approved business plan.
  • What you actually executed, including pivots and why they happened.
  • What worked and what did not — traction, revenue, users, hires, partnerships, funding, concrete metrics.
  • Public recognition: press coverage, awards, accelerator programmes, grants, speaking slots, public sector clients.
  • Your plan for the next two years, with the resources you expect to need.

Approval statistics from real renewal files

June 2026 — around a dozen favourable decisions across very different company profiles. Total processing time was roughly 7–8 weeks; from the notice suspending the decision period to the ENISA report itself was about 5 weeks. Notably, modest turnover in the modelo 347 and annual accounts (€30–50k) was still approved. Where innovation or funding was thin, the public recognition section appeared to be decisive. A handful of refusals occurred and no single common trigger has been identified.

January 2026 — favourable. Around 60 days total, of which ENISA took roughly 45. Nothing exotic in the file: a company genuinely trading for 2.5 years, continuing development, pivots and slowly growing sales.

November 2024 — refused, purely on missing documents. No modelo 347: refusal. No cuentas anuales: refusal. No employees and therefore no certificado de estar al corriente with Social Security: refusal. Harsh, but it is how the file is assessed.

July 2024 (archive case, an exception to the rules) — two years of activity as autónomo, with an SL incorporated shortly before renewal. The originally approved plan focused on one project, but a different project became the real business, so the renewal was refocused on it and explained in detail to ENISA. Filed at the end of May, UGE requested the tax and social security certificates in early June, then approved after 42 days. All handled online with the company digital certificate.

If you still need an autónomo or an SL

For a renewal you need, as an absolute minimum, autónomo status: contributions to Social Security are a de facto condition of renewal, and most likely of a modification too. An SL on top makes the file considerably stronger, because the requested documents (cuentas anuales, modelo 347, company certificates) assume a company exists and is trading.

Readers report two routes to incorporate quickly without paying €3,000 or waiting a month:

  • Qonto + Finutive — roughly €250 for a year of banking plus SL incorporation plus autónomo-administrator registration, €150 notary, €40 registry fee, €23 for the FNMT certificate issued to the gestor.
  • Enley — around €350 all-in, with notary fees of roughly €250 covered and a nearby notary arranged; accounting afterwards around €140/month.

Renewal alternatives: Digital Nomad residence or cuenta propia

Renewing as an entrepreneur only makes sense if you are genuinely running the business — the ENISA report cannot be faked. If it is not, there are two realistic routes.

Digital Nomad residence in Spain: you lose the right to work with Spanish clients (remote work for foreign clients only), but the years still count towards long-term residence (larga duración) at five years. Upside: a legal decision period of 20 working days. Downside: you must maintain the income threshold and pay taxes, and Spanish clients are off limits. As of January 2026 there are nuances in the documents requested — company registry extracts from your country of origin and awkward questions about social security contributions over the last three years — so each case needs individual review.

Modification to cuenta propia (self-employment) under Law 4/2000, outside UGE and outside Law 14/2013: you live off your autónomo as you already do, and renewal simply requires keeping the autónomo. It did not work in 2019, it worked in 2021, and in 2025–2026 it works case by case depending on the province. Upside: you can serve any client, and even a dormant autónomo can be enough to renew. Downside: the modification took 6–8 months and requires a conventional business plan.

You can file for the entrepreneur renewal and the modification in parallel and then choose which outcome to keep.

  • If you hold the Beckham regime and switch to a permit type that is incompatible with it, you must file to have the regime revoked — the qualifying basis no longer exists.

Tactics and timing

The renewal window opens 60 days before your card expires, and you should use all of it. If your expiry falls in July or August, assume the 60 days will not be enough — Spanish administration slows to a crawl over the summer.

The pragmatic sequence: file the renewal as early as possible; in parallel prepare the Digital Nomad file so that a refusal costs you weeks, not months. If the renewal is approved, you simply drop the backup.

One serious warning: if you did essentially nothing for the permit period — no social security contributions, no SL, no autónomo — there is a real risk of the permit being revoked rather than merely refused. Explanations exist, but they depend heavily on whether you actually lived in Spain, and each case needs individual handling.

Key takeaways

  • Renewal is filed with UGE and requires a fresh favourable ENISA report.
  • Company documents drive the decision: cuentas anuales, modelo 347, and tax + social security "al corriente" certificates.
  • No criminal record certificate and no proof of savings are required at renewal.
  • No employees means no Social Security certificate — open a company CCC first, then request it.
  • The second ENISA application needs a new account (use an email alias) and a plan–do–check–act narrative.
  • Modest turnover (€30–50k) has been approved; public recognition matters when innovation or funding is thin.
  • Realistic processing in 2026: about 7–8 weeks total, ENISA taking roughly 5 of them.
  • File 60 days before expiry, and prepare the Digital Nomad residence file as a parallel backup.

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