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      Spain has published and brought into force an Extraordinary Regularisation Process (Regularización Extraordinaria) in 2026, aimed at certain individuals currently residing in Spain without regular immigration status, through Royal Decree 316/2026 of 14 April (published in the Spanish Official Gazette (BOE) on 15 April 2026).1

      The measure is expected to generate high application volumes, potentially placing significant strain on immigration authorities and related public services.

      WHY THIS MATTERS

      For employers, this development presents a relevant window to review workforce documentation, identify potential exposure, and prepare for operational delays affecting standard immigration processes. Although the process is individual-driven, the expected scale of applications is likely to have sector-wide consequences.

      Key anticipated impacts could include:

      • A surge in filings is expected from 16 April 2026 (start of the application window), with knock-on impacts on processing times.
      • In-person submissions are expected to be managed strictly by appointment: appointment booking is enabled from 16 April 2026, with in-person service commencing from 20 April 2026. Official communications indicate in-person submissions will be channelled through designated appointment-based service points (including selected Social Security offices and Correos locations), subject to local capacity.2
      • Official guidance includes an online requirements simulator to help applicants self-screen eligibility before filing (which may help reduce unnecessary submissions and appointment demand).3
      • Administrative saturation across immigration offices, police units, and/or related authorities. This includes authorities in the applicant’s country of origin, taking into consideration any consular processes or even specific document procurement, such as criminal background checks. 
      • Reduced appointment availability during and potentially after the application window, especially with the National Police for identity card (TIE) issuance.

      Background

      The stated objective is to provide legal certainty and access to rights for certain individuals already present in Spain prior to 1 January 2026, regularising a pre-existing situation rather than creating a new migration pathway. The Royal Decree entered into force on 16 April 2026, and the application window runs from 16 April 2026 through 30 June 2026.

      According to official guidance published by the Ministry of Inclusion, Social Security and Migration, the process is aimed at

      • certain applicants for international protection who applied before 1 January 2026 and
      • individuals in administrative irregularity who arrived before 1 January 2026, subject to meeting conditions including continuous presence (at least five months at the time of application) and other admissibility checks.

      The telematic channel is available continuously (24/7) throughout the window, while in-person submissions require a prior appointment; official guidance also stresses that in-person appointments are free of charge.

      KPMG INSIGHTS

      It is key to consider the time pressure now that the process has been formally opened. While detailed procedural guidance is still pending, even with the Royal Decree approved, organisations and employers may wish to urgently consider the following:

      • Conduct an internal immigration compliance review.
      • Map upcoming mobility or hiring needs against expected administrative delays.
      • Build longer timelines into 2026 immigration planning.
      • Coordinate with immigration advisors to monitor developments and assess workforce impact.
      • Identify individuals whose immigration status may be irregular or uncertain.
      • Assess whether such individuals could potentially benefit from the extraordinary regularisation process.
      • Consider risk exposure linked to undocumented work, including labour, social security, and reputational aspects.
      • Anticipate operational disruption to mobility plans and onboarding timelines in 2026.

      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).

      ENDNOTES:

      1  Agencia Estatal Boletín Oficial del Estado, “Real Decreto 316/2026, de 14 de abril, por el que se modifica el Real Decreto 1155/2024,” published on 15 April 2026.

      2  Ministerio de Inclusión, Seguridad Social y Migraciones, FAQ portal, “Regularización Extraordinaria para Personas Migrantes,” published on 19 April 2026.

      3  Ministerio de Inclusión, Seguridad Social y Migraciones, “Simulador de requisitos – Regularización extraordinaria 2026,” published on 19 April 2026.

      Contacts

      miguel-arias
      Miguel Arias

      Partner

      KPMG in Spain

      javier-de-robles
      Javier De Robles

      Director

      KPMG in Spain

      patricia-contreras-garcia
      Patricia Contreras Garcia

      Senior Manager, Immigration Lawyer

      KPMG in Spain

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      Disclaimer

      * 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.

      GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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