Spanish authorities extended through 31 December 2021, the temporary restrictions placed on non-essential travel from third countries to the European Union (EU) and Schengen associated countries for public health reasons due to the evolving coronavirus health crisis.1  

Additionally, due to the new “omicron” variant of the virus, there are flight restrictions between certain southern African countries and Spanish airports effective 2 December through 15 December 2021,2 and a period lasting until 12 December 2021, during which quarantine rules must be respected for international travellers coming from high-risk countries.3

Lastly, there are changes to the documentation regarding the health measures to allow entrance into Spain depending on the country of departure. 4


The travel restrictions will affect employers and their globally-mobile employees – especially business travellers – doing business in Spain in terms of disruption, inconvenience, new procedures and requirements, and changes to travel plans.

Individuals travelling to Spain and employers sending employees into and out of Spain should stay abreast of the latest travel restrictions and should consider consulting with their travel agents and/or immigration counsel when planning their travel.  In light of the current, fluid situation, it may be prudent to delay non-essential travel. 

Restrictions on Non-essential Travel

The restrictions on non-essential trips will be in effect until 31 December 2021 (it is feasible that another extension will happen). However, there are two important exceptions.

  • The list of exemptions includes one -- exception letter “k” -- that allows fully vaccinated international travellers to continue to enter Spain.
  • The current list of countries, special administrative regions and other territorial entities and authorities whose residents are not affected by the temporary restriction of non-essential trips to the EU is as follows:




New Zealand

II. Special Administrative Regions of the People's Republic of China:

—    Hong Kong SAR

—    Macao SAR













Saudi Arabia

III. Entities and territorial authorities not recognised as states by at least one member state of the European Union:

—    Taiwan


South Korea


United Arab Emirates




People’s Republic of China

Source: KPMG in Spain 

Other Current Measures

Besides the travel restrictions on non-essential travellers, there are other measures to limit the spread of COVID-19 by international travellers from the following countries:

  • Limiting flights between certain southern African countries and Spanish airports:
    • Flights from any airport located in the Republic of Botswana, the Kingdom of Eswatini, the Kingdom of Lesotho, the Republic of Mozambique, the Republic of Namibia, the Republic of South Africa and the Republic of Zimbabwe to any airport located in the Kingdom of Spain, with or without intermediate stop-overs, may only be carried out in the case of aircraft carrying exclusively Spanish or Andorran nationals, or residents in Spain or Andorra, or passengers in international transit to a non-Schengen country with a stop-over of less than 24 hours without leaving the transit area of ​​the Spanish airport.
    • These limitations apply beginning 2 December 2021 through 15 December 2021.
  • Until 12 December 2021, there is a quarantine of 10 days for all international travellers arriving at any airport located in the Kingdom of Spain, with or without intermediate stop-overs, coming from any of the high-risk countries (Republic of Botswana, Kingdom of Eswatini, Kingdom of Lesotho, Republic of Mozambique, Republic of Namibia, Republic of South Africa and Republic of Zimbabwe). This quarantine will be in force for an initial period of 14 calendar days, which may be extended if the circumstances warrant.

Health measures continue to be valid and international travellers must submit the health declaration through the SpTH (Spain Travel Health app (however, the list of documents that accredit health requirements is updated).

The Resolution of 26 November 2021, of the General Directorate of Public Health,5 modifies rules around health controls to be carried out at the points of entry in Spain.  The Resolution provides for:

  • “Risk” and “high-risk” countries’ entry requirements.
  • Passengers from high-risk countries will be required, regardless of their vaccination status or having previously recovered from the disease, to present a diagnostic COVID-19 certificate with a negative result.

In this sense, as a general rule, the lists of countries or areas of risk and high risk will be reviewed every seven days; therefore, depending on the day of the trip you may or may not need a PCR test in addition to the vaccination certificate.


Any questions or concerns should be directed to your qualified professional adviser or a member of the GMS/People Services team with the KPMG International member firm in Spain (see the Contact section).


1  For the Spanish Order please see in the Boletín Oficial del Estado, Orden INT/1304/2021 de 26 de noviembre.

2  For the Spanish Order please see in the Boletín Oficial del Estado, Orden PCM/1324/2021 de 30 de noviembre

3  For the Spanish Order please see in the Boletín Oficial del Estado, Orden SND/1309/2021 de 26 de noviembre.

4  For the Spanish Order please see in the Boletín Oficial del Estado, Resolución de 26 de noviembre de 2021, de la Dirección General de Salud Pública.

5. Id. 

Please note that KPMG LLP (U.S.) does not provide any immigration services.  However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

The information contained in this newsletter was submitted by the KPMG International member firm in Spain.


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