
Spain’s ambitious plan to regularise undocumented migrants is facing new scrutiny after a confidential National Police analysis, leaked on 17 February 2026, concluded that as many as 1.35 million foreigners could receive residency and work permits—nearly triple the 500,000 applicants cited by the government. The programme, approved by royal decree in January, will open a three-month window (April–June) for anyone who can prove five months’ residence in Spain before 31 December 2025 and a clean criminal record.
The report, drafted by the National Centre for Immigration and Borders (CNIF), warns that generous eligibility rules and Spain’s position inside the passport-free Schengen Area could trigger secondary migration from other EU states as irregular workers reposition themselves to take advantage of the amnesty. Police analysts expect 200,000–250,000 such onward migrants on top of the 750,000–1,000,000 who are already in Spain. They also foresee increased document fraud and people-smuggling activity in the run-up to the April launch date.
For applicants who need help navigating Spain’s shifting visa and residency framework, VisaHQ offers a one-stop online concierge. Through its Spain portal (https://www.visahq.com/spain/) the service aggregates up-to-date requirements, automates form completion and provides live support—resources that can save both individuals and employers time as they prepare for the regularisation window and any subsequent work-permit filings.
For employers the stakes are high. Sectors such as agriculture, logistics, hospitality and domestic care rely heavily on informal labour; legalising that workforce would expand the contributory tax and social-security base but could also raise wage floors and compliance costs. HR teams planning to sponsor assignees under Spain’s Highly Qualified Professional, intra-company transfer or Digital-Nomad routes should anticipate processing bottlenecks: foreigners’ offices (Oficinas de Extranjería) already report six-week backlogs for routine renewals, and the civil-service union CSIF is demanding emergency staffing increases.
The political reaction has been polarised. Prime Minister Pedro Sánchez argues the measure will plug Spain’s demographic gap and fill 300,000 reported labour shortages, while the conservative Partido Popular says the plan will overstretch public services and act as a “pull factor” for illegal immigration. Brussels has signalled that regularisation is a national competence but reminded Spain of its duty to safeguard the Schengen area.
Companies should: (1) audit current employees who may become eligible to transition from irregular to legal status; (2) budget extra lead-time for any corporate immigration filings between April and December 2026; and (3) monitor regional authorities for supplementary guidance on labour-market integration, language training and social-security registration for newly regularised staff.
The report, drafted by the National Centre for Immigration and Borders (CNIF), warns that generous eligibility rules and Spain’s position inside the passport-free Schengen Area could trigger secondary migration from other EU states as irregular workers reposition themselves to take advantage of the amnesty. Police analysts expect 200,000–250,000 such onward migrants on top of the 750,000–1,000,000 who are already in Spain. They also foresee increased document fraud and people-smuggling activity in the run-up to the April launch date.
For applicants who need help navigating Spain’s shifting visa and residency framework, VisaHQ offers a one-stop online concierge. Through its Spain portal (https://www.visahq.com/spain/) the service aggregates up-to-date requirements, automates form completion and provides live support—resources that can save both individuals and employers time as they prepare for the regularisation window and any subsequent work-permit filings.
For employers the stakes are high. Sectors such as agriculture, logistics, hospitality and domestic care rely heavily on informal labour; legalising that workforce would expand the contributory tax and social-security base but could also raise wage floors and compliance costs. HR teams planning to sponsor assignees under Spain’s Highly Qualified Professional, intra-company transfer or Digital-Nomad routes should anticipate processing bottlenecks: foreigners’ offices (Oficinas de Extranjería) already report six-week backlogs for routine renewals, and the civil-service union CSIF is demanding emergency staffing increases.
The political reaction has been polarised. Prime Minister Pedro Sánchez argues the measure will plug Spain’s demographic gap and fill 300,000 reported labour shortages, while the conservative Partido Popular says the plan will overstretch public services and act as a “pull factor” for illegal immigration. Brussels has signalled that regularisation is a national competence but reminded Spain of its duty to safeguard the Schengen area.
Companies should: (1) audit current employees who may become eligible to transition from irregular to legal status; (2) budget extra lead-time for any corporate immigration filings between April and December 2026; and (3) monitor regional authorities for supplementary guidance on labour-market integration, language training and social-security registration for newly regularised staff.









