Renewing a Spain Startup Visa or Digital Nomad Visa in 2026: Timelines, Documents, and What Changed

Both Spain’s Startup Visa and Digital Nomad Visa renew the same way: in two-year cycles under Article 76.3 of Ley 14/2013, processed by UGE-CE, as long as the conditions that granted the right are maintained. You file before your card expires, and the filing itself extends (prorroga) the prior authorisation until the procedure resolves. Miss the deadline and you still have a 90-day grace window after expiry, though a sanction proceeding may attach. UGE-CE decides in 20 working days, and if it stays silent, the renewal is approved by positive administrative silence. That much is shared. Where the two permits diverge is the means test, the social-security position at the two-year mark, and what each one has to prove about ongoing activity. This guide sets out the renewal rule that governs both visas and what the 2026 legal changes did and did not touch. It then walks through the document chains for each visa, the timing window, and the honest list of what gets renewals refused.

The renewal rule that governs both visas

Both visas renew under Article 76.3 of Ley 14/2013, in two-year cycles (“por periodos de dos años”), so long as the conditions that gave rise to the original authorisation are maintained. This is a régimen propio — its own self-contained regime, processed by UGE-CE, not the ordinary immigration track. Understanding that single article is the foundation of every renewal we file.

Three mechanics matter most. First, lodging the renewal extends the validity of your existing authorisation until the procedure is resolved, so you do not fall out of status while you wait. Second, the renewal is still valid if filed within 90 calendar days after expiry, though doing so may trigger a sanction proceeding. Third, UGE-CE must resolve within 20 working days, and if it does not, the renewal is granted by positive administrative silence under Article 76.1.

One point on timing that competitors routinely get wrong. For these Ley 14/2013 permits, the statute does not fix a minimum number of days before expiry by which you must file. You may file at any point while the card is valid. The widely repeated “60 days before” figure comes from the general immigration regime and from practice, not from Ley 14/2013. We treat the roughly 60 days before expiry as sensible practice, not a statutory deadline. The only hard statutory timing here is the 90-day post-expiry grace.

What changed for 2026 — and what didn’t

The most important fact about 2026 is what did not change: the new Reglamento de Extranjería, RD 1155/2024 (published 20 November 2024, in force 20 May 2025), does not govern Ley 14/2013 permits. Startup Visa, DNV, highly-qualified, and ICT authorisations keep their own regime; the general Reglamento applies only supplementarily.

This is the single most common error in competitor guidance. Many sources cite the general Reglamento’s renewal article — the 60-days-before, 90-days-after framework of ordinary residence permits — as if it were the legal basis for renewing a Startup Visa or DNV. It is not. The operative basis is Article 76.3 of Ley 14/2013. The practical effect on your file is small, since the timing windows look similar, but the legal citation matters when a case is contested.

Two real 2026 changes do touch these renewals. The minimum wage rose: RD 126/2026 (18 February 2026) set the SMI at €1,221/month over 14 payments — €17,094/year, up 3.1% on 2025. Because the DNV income floor is indexed to the SMI, that floor moved up with it. IPREM, by contrast, stayed frozen at €600/month — €7,200/year over 12 payments, where it has sat since 2023, which keeps the Startup Visa means test lower than the DNV’s.

The third change is judicial. In STSJ Madrid 741/2026 (Sentencia 26/2026, published 15 March 2026), the Madrid High Court of Justice upheld the extinction of an international-teleworker (DNV) authorisation because the holder had not registered with, and contributed to, Spanish Social Security from the start of validity. The significance is not the individual case but the principle it documents: social-security compliance is no longer just an initial-application checkbox. It is a live extinction risk that the administration can act on, and that a court will back, which reframes the entire renewal calculus for remote workers.

Common error (general Reglamento framing)	Correct basis for Ley 14/2013 permits
Renewals governed by RD 1155/2024	Renewals governed by Article 76.3 of Ley 14/2013
First-card validity then “ordinary” 5-year extensions	Two-year cycles (“por periodos de dos años”)
Statutory “60 days before expiry” filing deadline	No statutory pre-expiry minimum; 90-day post-expiry grace is the hard rule
Decision under general-regime timelines	20 working days at UGE-CE, positive administrative silence
Both visas use the same income test	Startup Visa = IPREM; DNV = 200% SMI (€2,849/month)

Renewing the Startup/Entrepreneur Visa

The Startup Visa starts on a three-year initial card, then renews in two-year cycles, building toward the five years of continuous residence that open long-term residence. The renewal test is continuity, not reinvention: you show that the entrepreneurial activity that justified the original grant is still running, and you meet the IPREM means test — not the higher minimum-wage figure that applies to the DNV.

The ENISA question is where precision earns its keep. We see applicants arrive convinced they must commission a fresh ENISA innovation report to renew, and that is not the rule. There is no requirement to procure a new applicant-led ENISA report at renewal. The test is maintenance of “the conditions that generated the right” — that the activity continues. What the statute does allow is that the Dirección General de Migraciones may (“podrá recabar”), at its discretion, request reports to confirm those conditions are maintained. That is a possible administrative step, not a burden that starts with you. The detail of the original innovation test sits in the Spain Startup Visa guide; at renewal, the centre of gravity shifts from innovative to still active.

Profitability is not a condition. The project may have pivoted, narrowed, or evolved away from its original plan; what it cannot be is abandoned. UGE-CE wants evidence the business is genuinely operating.

Documents for the Startup Visa renewal

The renewal file is built around proof of continuity:

• Evidence of ongoing activity — revenue, invoices, jobs created, investment raised, or other signs the company is operating.
• Social security up to date — autónomo RETA contributions current, or the company’s contributions for any employees.
• Tax affairs in order — registered with the Spanish tax census (Modelo 036), with the relevant IRPF, IVA, and (for a company) corporate-tax returns filed. Autónomos and companies that exceed €3,005.06 with any single Spanish counterparty in the year also file the annual Modelo 347; those under the SII regime, or below that threshold (for example billing only foreign clients), are exempt.
• Maintained health insurance — full-coverage, no copayments, from an insurer authorised in Spain (unless you sit in the public system via convenio especial).
• IPREM means proof — bank or investment statements showing sufficient funds.
• Valid passport, current TIE, and the renewal fee.

A fresh criminal-record certificate is generally not required at renewal, since you are already resident and vetted; treat its inclusion as case-specific rather than routine.

Renewing the Digital Nomad Visa

The DNV renews in two-year cycles after the initial card — one year if you entered through a consulate, three years if you filed in Spain through UGE-CE — and the income floor moves with the minimum wage. For 2026 that is 200% of SMI = €2,849/month, measured against the SMI in force at the moment you renew. The renewal tests the same structure as the original grant: genuine foreign employment or foreign clients, income above the floor, and now, pointedly, working social-security cover.

Family multipliers track the SMI too. Add 75% of SMI — €1,068/month for a first dependent, and 25% of SMI — €356/month for each additional one, so a family of three needs roughly €4,274/month at renewal. The 20% cap on Spanish-source income still applies: a freelancer can invoice Spanish clients, but that domestic work must stay at or below a fifth of total activity. Breach it and the renewal is exposed.

The social-security pivot is the part most renewals stumble on. The EU A1 posting certificate that exempted you from Spanish contributions typically covers about 24 months, which means it tends to lapse right around your first two-year renewal, exactly when scrutiny is highest. When it expires, the foreign employer must register with Spain’s Tesorería General de la Seguridad Social (TGSS) as a foreign employer (no Spanish establishment needed), or a self-employed holder moves onto RETA. After STSJ Madrid 741/2026, this is not housekeeping: a gap between A1 expiry and TGSS or RETA registration is precisely the kind of non-compliance a court has now upheld as grounds to extinguish the permit. The mechanics of running this through a foreign payroll are covered in Spain DNV with a Portuguese employer, and the underlying programme in the Spain Digital Nomad Visa guide.

Documents for the DNV renewal

• Continued foreign-employment or foreign-client proof — current contract or client agreements showing the relationship persists.
• Income proof — payslips or invoices plus bank statements showing the money actually arriving above €2,849/month.
• Social-security proof — a still-valid A1, or TGSS foreign-employer registration, or RETA registration.
• Maintained health insurance — no copayments, insurer authorised in Spain.
• Empadronamiento — current municipal registration.
• Valid passport, TIE, and fee.

As with the Startup Visa, a criminal-record certificate is generally not re-required at renewal.

If you renew as a self-employed (autónomo) DNV holder, the same tax-registration trail applies: census registration via Modelo 036, and the annual Modelo 347 only where your operations with a single Spanish counterparty pass €3,005.06 in the year — billing only foreign clients, or filing under the SII, keeps you outside it. DNV holders employed by a foreign company file neither form personally.

Timelines and the renewal window

There is no statutory minimum number of days before expiry by which you must file a Ley 14/2013 renewal, but the practical timeline is firm: prepare during the validity of your current card, and file in good time. We work to the roughly 60 days before expiry as good practice, which leaves room to assemble tax and social-security evidence without rushing. The filing itself extends your authorisation until UGE-CE resolves, so you are protected once it is in.

The hard statutory backstop is the 90-day grace after expiry. You can still file a valid renewal within those 90 calendar days, though a sanction proceeding may attach and the comfort of an unbroken card is gone. Past 90 days, the permit lapses, and you may have to begin again from scratch — a far costlier outcome than filing on time.

Processing is fast on paper. UGE-CE’s deadline is 20 working days, and positive administrative silence means a renewal is deemed granted if no decision arrives in time. In practice, a clean, complete file is what makes that timeline real; an incomplete one invites a requerimiento that stops the clock.

From renewal to long-term residence

Each renewal is a step toward long-term residence, available after five years of continuous legal residence. Continuity is not the same as constant physical presence: the rules allow absences of up to six consecutive months, capped at ten months in total across the five years, rising to eighteen months where the absence is for work reasons, per the Ministerio de Inclusión’s published criteria (Hoja 50).

It helps to translate those limits into a rough sense of how much time you actually need on the ground. In the non-work case, subtracting the ten permitted absence months from sixty leaves about fifty months — roughly four years and two months of physical presence over the five-year span. Treat that as an illustrative figure, not a legal term: the statute speaks in absence limits, not in a presence quota, and work-related absences push the math further. It is a planning aid, not a threshold to satisfy.

Citizenship sits further out. Naturalisation generally requires ten years of residence, dropping to two years for nationals of Ibero-American countries and a handful of others. If you are weighing the tax dimension across that horizon, the Beckham regime’s five-year look-back (cut from ten by Ley 28/2022) is mapped in the Startup Visa and Beckham Law transition guide, and the wider strategic picture in strategic immigration to Spain.

What gets renewals refused in 2026

Renewal refusals in 2026 cluster around compliance gaps that accumulated during the prior card, and social-security non-compliance now leads the list after STSJ Madrid 741/2026 made it an extinction risk rather than a paperwork nuisance. Most refusals are avoidable, but only if the issues are fixed during the two years, not discovered at filing.

The recurring patterns:

• Social-security gaps — no registration or contributions during the prior card; an A1 that lapsed without TGSS or RETA taking over.
• Income below threshold — months where deposits dipped under the floor, or money that does not trace cleanly to the named employer or clients.
• Non-compliant health insurance — any copay or deductible, or an insurer not authorised in Spain.
• DNV 20% breach — Spanish-source income creeping above one-fifth of total activity.
• Startup activity abandoned — no credible evidence the business is still operating.
• Filing past the 90-day grace — the permit lapses, and you may have to start over.

The pattern that turns a refusal into a deeper problem is filing late. For the specific profiles ENISA and UGE-CE turn down on the Startup side, the Spain Startup Visa rejection guide breaks them down further.

---

Renewals reward the work done quietly over the prior two years: social-security registration kept current, income that traces cleanly to the right source, insurance with no copays, and a file that cites Article 76.3 of Ley 14/2013 as its basis rather than the wrong Reglamento. Get those right and the 20-working-day, silence-approved timeline does its job. Relovisa files both renewals end to end, mapping the A1-to-TGSS pivot and the means test before the window opens. Start with the Spain Startup Visa engagement or the Spain Digital Nomad Visa page.

Sources

1. Ley 14/2013, de 27 de septiembre, de apoyo a los emprendedores y su internacionalización — Articles 62 and 76 (renewal, two-year cycles, 90-day grace, 20-day decision, positive administrative silence), consolidated text, Boletín Oficial del Estado / comercio.gob.es — verified June 2026
2. Ley 28/2022, de 21 de diciembre, de fomento del ecosistema de las empresas emergentes (Startup Act) — Digital Nomad Visa provisions and Beckham five-year look-back, Boletín Oficial del Estado — verified June 2026
3. Real Decreto 1155/2024, de 19 de noviembre — new Reglamento de Extranjería, in force 20 May 2025; supplementary application to Ley 14/2013 permits, Boletín Oficial del Estado — verified June 2026
4. Real Decreto 126/2026, de 18 de febrero — 2026 SMI set at €1,221/month (×14), €17,094/year, Boletín Oficial del Estado — verified June 2026
5. IPREM 2026 (Indicador Público de Renta de Efectos Múltiples) — €600/month, €7,200/year, frozen since 2023, Ley de Presupuestos Generales del Estado / official tables — verified June 2026
6. Secretaría de Estado de Migraciones / UGE-CE — autorización de residencia para emprendedores (entrepreneur renewal procedure), inclusion.gob.es — verified June 2026
7. Secretaría de Estado de Migraciones / UGE-CE — autorización para teletrabajadores de carácter internacional (international teleworker / DNV renewal procedure), inclusion.gob.es — verified June 2026
8. Ministerio de Inclusión, Seguridad Social y Migraciones — long-term residence criteria and absence limits, Hoja informativa 50, inclusion.gob.es — verified June 2026
9. Tribunal Superior de Justicia de Madrid — Sentencia 26/2026 (STSJ Madrid 741/2026), published 15 March 2026, extinction of an international-teleworker authorisation for Social Security non-compliance — verified June 2026
10. Reglamento (CE) n.º 883/2004 — EU social security coordination and the A1 posting certificate (~24 months) — verified June 2026
11. Agencia Tributaria — régimen especial de trabajadores desplazados (Beckham Law, artículo 93 LIRPF), agenciatributaria.gob.es — verified June 2026