Spain has announced an Extraordinary Regularisation Process (Regularización Extraordinaria) to be implemented in 2026—pending final approval—aimed at individuals currently residing in Spain without regular immigration status.1
The measure is expected to generate a high volume of applications, potentially placing significant strain on immigration authorities and related public services.
For employers, this development presents a window of time to review workforce documentation, identify potential exposure, and prepare for operational delays affecting standard immigration processes. Although the process will be driven by individuals, the expected scale of applications is likely to have sector wide consequences.
Key anticipated impacts could include:
In January 2026, the Spanish Government published an official framework of an extraordinary, time-limited regularisation process, to be implemented via Royal Decree. The stated objective is to provide legal certainty and rights to individuals already present in Spain prior to December 31, 2025, regularising a pre-existing situation rather than creating a new migration pathway. According to official communications, the process is expected to open from April 2026 until June 30, 2026, subject to final approval of the Royal Decree with specific criteria and details.
Early identification allows employers to plan in advance, rather than reacting under time pressure once the process formally opens. While detailed procedural guidance is expected to follow once the Royal Decree is approved, organisations and employers may wish to consider the following:
If assignees and/or their programme managers have any questions or concerns about the scope of the update, its application and potential impacts, and appropriate next steps, they should consult with their qualified tax professional or a member of the GMS tax team with KPMG in Spain (see the Contacts section).
1 La Moncloa, “Preguntas y Respuestas – Tramitación de Regularización Extraordinaria 2026.”
* Please note the KPMG International member firm in the United States does not provide immigration or labour law 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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