UGE requerimiento for digital nomads: what to add and how to respond

What a UGE requerimiento is and how it arrives

A requerimiento is an official request for missing or clarifying documents in your application. The legal basis is Article 68 Ley 39/2015 on subsanación y mejora de la solicitud (correcting and supplementing the application) [1]. A UGE reference document adds that additional documents may be requested at any time if those submitted do not prove the requirements of Ley 14/2013 [2].

The request arrives electronically. Applications under Ley 14/2013 and all related documentation (subsanaciones, ampliaciones de documentación, recursos, comunicaciones) are filed through the electronic sede of the Ministry of Inclusion [3]. A notification is considered received when you or your representative open it in the sede. If the electronic channel is mandatory or you chose it, and you do not open the notification for ten calendar days, it is deemed rejected [1]. That is why you need to check your email and the sede regularly: how to check the status of a UGE application.

How many days you have to reply and what happens to the 20-day deadline

Article 68 gives ten days to correct the shortcomings, with a warning: if you do not reply, you will be deemed to have withdrawn the application, and the decision on this is issued as a resolución [1]. Under the general counting rule these are working days, excluding Saturdays, Sundays and public holidays (Article 30.2) [1]. The period can be extended “prudencialmente” (with some margin) by no more than five days, at your request or on the authority’s own initiative, if the documents are particularly hard to gather [1]. If the requerimiento itself states a different period, go by that and keep the notification.

Effect on the decision deadline: Article 22.1(a) allows the overall period to be suspended from the notification until the request is complied with [1], and the UGE’s general period under Ley 14/2013 is twenty days [4]. We have found no confirmation that the UGE applies the suspension to DNV applications. More on the timeline: how long the UGE takes to process an application.

What the UGE most often asks you to add

We have not found official statistics on requests. The table below is based on the UGE document checklist: a request appears where the package differs from the checklist [2].

How to respond to a requerimiento: the steps

1. Open the notification in the sede, note the date and count the working days [1].
2. Write out the points of the request word for word and compare them with your package: what is missing, what is inaccurate, what needs explaining.
3. If you cannot gather everything in time (apostille, sworn translation), ask for an extension of up to five days before the period runs out [1].
4. Put the reply together as one package so that you do not get a second request on the same point. Prepare translations and apostilles according to UGE rules: apostille and legalisation, sworn translation.
5. Attach an escrito explicativo (explanatory letter): the UGE itself recommends this when the documents do not exactly match the checklist [2].
6. File the reply electronically through the sede and keep the filing confirmation [3].
7. Keep watching for notifications: your reply may lead to a new request.

An explanatory letter usually covers five things: the expediente number, the date and content of the request, a list of attachments point by point, an explanation of any discrepancies (gross and net, roubles and euros with the exchange rate and conversion date, payment through a platform) and the signature of the applicant or representative.

How a requerimiento differs from a refusal

A requerimiento is not a decision on the merits: the application is still being processed and you can supplement it [1]. Refusal and desistimiento are issued as a resolución. Decisions on permits under Ley 14/2013 must state reasons and can be appealed by recurso de alzada [4]. The period for alzada is one month where the decision is express (Article 122 Ley 39/2015) [1].

What happens if you do not respond

Under Article 68, the applicant is deemed to have withdrawn the application (desistimiento), and the decision is issued as a resolución [1]. Decisions on permits under Ley 14/2013 must state reasons and can be appealed by recurso de alzada [4]. Whether you have to pay the fee again when you reapply, and how your right to stay changes after the application is closed, depends on the case: for those who applied from Spain during a tourist stay, the period of legal stay runs in parallel. On this situation: applying from Spain on a tourist visa. On appeals: DNV refusal and recurso.

Common mistakes when responding

• Replying to only some of the points: the rest become grounds for a new request or a refusal.
• Attaching new documents instead of the ones requested.
• Sending the reply on the last day, with no margin for a technical failure of the sede.
• Not opening notifications: after ten calendar days, a notification is deemed rejected [1].
• Sending the reply by post or email instead of through the sede: the UGE accepts documentation under Ley 14/2013 electronically through the sede [3].
• Attaching documents that contradict those already submitted (a different amount, a different start date).
• Leaving the sworn translation until the last day.

When you need an individual review

If the request concerns substance rather than paperwork (the share of Spanish clients, the type of relationship, the company’s “genuine activity”, whether the work meets the condition of being done “exclusively by remote means”), the right answer depends on the facts of your case. The same applies to a request with several points and different deadlines. The 20% rule: explained.

How we can help

The ReloVictory team in Barcelona reads the requerimiento with you, works out which points are closed with documents and which with explanations, and prepares the explanatory letter. We prepare the reply; it is filed either by the team’s lawyer under a power of attorney or by you, as set out in the contract. Book a consultation.

Frequently asked questions

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ReloVictory · Sources reviewed 02.10.2026 · Not a substitute for individual legal advice.