- The general rule: 10 days and a warning of desistimiento (article 68 Ley 39/2015). These are working days, excluding Saturdays, Sundays and public holidays, counted from the day after notification [1].
- The regulation sets special deadlines in places: 10 days for an initial employment permit and for children (articles 77, 159, 160), up to 15 days for the family of a Spanish citizen and for arraigo (articles 97 and 130); for visas, article 27 refers to the general article 68 Ley 39/2015, and gives no more than 15 days to appear in person [2].
- An extension of up to 5 days is possible if the documents are particularly hard to obtain, at your request or on the authority’s own initiative. You must ask before the deadline ends: an expired deadline cannot be extended (articles 68.2 and 32.3) [1].
- A late response may be accepted: an applicant’s action is admitted and valid if it is taken before the day on which the decision stating that the deadline has passed is served (article 73.3) [1]. Do not count on this.
- The response is filed through the channel stated in the notification. Mercurio also accepts additional documents for cases in progress [3].
What a requerimiento de subsanación is and how it arrives
Subsanación is the correction of defects in an application, and a requerimiento is the official request to make that correction. The basis is in general procedural law: article 68 Ley 39/2015. If the application lacks required information or the prescribed documents are missing, the administration asks the applicant to correct the defect or attach the documents within ten days and warns that otherwise the applicant will be deemed to have withdrawn the application, which is then confirmed by a decision under article 21 [1]. The immigration regulation sets its own deadlines in certain procedures [2].
The request arrives electronically or through the channel you chose when you applied. An electronic notification is deemed received when you or your representative open it; if the electronic form is mandatory or you chose it, and it is not accessed for 10 calendar days, it is deemed rejected (article 43) [1]. This is why a requerimiento can be “received” silently, without the message ever being opened. On notifications and checking: how to check your expediente; for the UGE: UGE application status.
How many days you have to respond: deadlines by procedure
| Procedure | Deadline to respond | Legal basis |
|---|---|---|
| General rule | 10 days, extension of up to 5 days | Ley 39/2015, article 68 [1] |
| Initial residence permit with employment | 10 days | RD 1155/2024, article 77.4 [2] |
| Residence permit for the family of a Spanish citizen | Deadline in the notification, no more than 15 days | Article 97.6 [2] |
| Arraigo and other circumstances | Deadline in the notification, no more than 15 days | Article 130.3 [2] |
| Children: articles 159 and 160 | 10 days from the day after notification | Articles 159.4 and 160.5 [2] |
| Visa at a consulate | General rule: 10 days, extension of up to 5 days. Appearing when summoned: no more than 15 days | Article 27.4 and 27.3 RD 1155/2024, referring to article 68 Ley 39/2015 [1][2] |
For UGE applications under Ley 14/2013 we did not find a separate deadline in the law: the general article 68 applies, and always read the number of days in the notification itself. How this works for the DNV is covered in UGE requerimiento for the DNV. If the notification states a deadline, it takes precedence over your own estimates.
How to count. Under the general rule the days are working days: Saturdays, Sundays and public holidays do not count (article 30.2); the period starts on the day after notification (30.3); if the last day is a non-working day, the deadline moves to the next working day (30.5). If a day is a working day where you live but a non-working day where the authority is based, or the other way round, it counts as a non-working day (30.6) [1]. Deadlines in calendar days and months are counted differently: deadline calendar.
Can you extend the deadline or reply later?
Extensions exist, but they are not automatic. Article 68.2: the deadline can be extended “prudencialmente” (with a margin) by up to five days, at your request or on the authority’s own initiative, when the documents are particularly hard to obtain. Condition: this does not apply to competitive and selection procedures [1]. Article 32 adds that the request for an extension and the decision on it must both happen before the deadline ends, and an expired deadline cannot be extended; a refusal to extend cannot be appealed separately [1]. If the system was down because of a technical failure, the administration may extend deadlines that have not yet expired and must publish this on the sede (article 32.4) [1].
A late response. Article 73.3: interested parties who did not take an action in time may be declared to have lost the right to that step, but an action taken before or on the day the decision stating that the deadline has passed is served is accepted and valid [1]. This is a lifeline for emergencies, not a strategy: the authority may issue its decision before you file your response.
If a document cannot be obtained in time (apostille, sworn translation, a certificate from another country), write to the authority before the deadline ends: describe which document is delayed and when it will be obtained, attach proof that you have ordered it and request an extension.
How to respond: the steps in order
- Open the notification and save it in full together with proof of the date. Write down the exact date of notification [1].
- Identify the authority and the case. Case number, procedure, who the response goes to. A message from an intermediary saying “bring in a certificate” does not replace the original request [1].
- Make a table. Each point of the request word for word, what has already been filed, what is being prepared, who is responsible, the deadline.
- Work out the type of objection. The document is missing altogether, the document exists but does not prove the requirement, the documents contradict each other, a translation or apostille is missing. Each type needs its own answer.
- If the deadline is tight, request an extension before it ends [1].
- Prepare a single response. A cover letter with the case number, numbered answers to each point of the request, attachments with clear names [1].
- File the response through the channel in the notification: via the sede, Mercurio or another channel named by the authority. Mercurio accepts electronic submission of additional documents for cases already in progress [3].
- Keep the proof of filing, the date and the list of attachments. If the response only went to an intermediary’s email, treat it as not filed.
If you or your representative are required to deal with the administration electronically and the response is brought in on paper, under article 68.4 the administration will require it to be filed electronically, and the filing date will be the day of the correction [1]. Translate and apostille foreign documents in advance: apostille and legalisation, sworn translation. Do not create or alter certificates: an error in a bank or government document is corrected through legitimate means (a new certificate, an explanation), not by editing the file.
How to write an explanatory letter
An escrito explicativo (explanatory letter) is needed when the documents do not match the request literally. It usually has five parts: the expediente number and the applicant’s details; the date and content of the request; a list of attachments by point of the request; an explanation of discrepancies (gross and net, currency conversion with the date and rate, payment via a platform, a change of surname due to transliteration); the signature of the applicant or representative with proof of authority. A representative must prove the representation: under article 5 Ley 39/2015 this is apud acta, an entry in the electronic register of representatives or another reliable method [1]. Insufficient proof of representation does not in itself prevent the action from being accepted, if you prove it within ten days (article 5.6) [1].
Requerimiento, desistimiento and refusal: how the consequences differ
A requerimiento is not a decision on the merits: the case remains in progress and you can supplement it. If you do not respond in time, the administration may issue a decision of desistimiento (withdrawal of the application), and for several procedures the regulation states: “se procederá al archivo del expediente” (the case will be closed), with a corresponding decision being issued [1][2]. The type of decision and the deadline for appeal are stated in the document itself. What desistimiento means and how it differs from caducidad: desistimiento and caducidad.
From notification until the request is complied with, the processing period for the application may be suspended (article 22.1.a), but this does not cancel the deadline to respond [1]. We have not confirmed how this works for UGE applications. If you receive a decision of desistimiento or a refusal, show it to a lawyer straight away: the deadline for appeal runs from the day of notification. On appeals: reposición, alzada and the courts. Filing a new application instead of responding is not advisable without analysing the consequences: it may affect deadlines, the validity of your previous permit and the fee, and there is no general answer here.
Common mistakes
- Not opening the notification: after ten calendar days it is deemed rejected, and the deadline to respond keeps running [1].
- Answering only some of the points: the rest become grounds for a new request or a refusal.
- Sending the same documents that were already filed instead of the ones requested: a repeat bank statement will not explain the origin of funds if that is exactly the question.
- Leaving it until the last day: a sede failure does not extend the deadline automatically [1].
- Sending the response to an agency by email or messenger instead of through the channel in the notification.
- Not requesting an extension before the deadline ends: once it has ended, it cannot be extended [1].
- Bringing documents that contradict those already filed (a different amount, date, job title).
- Editing certificates or scans.
When you need an individual review
A review is needed if the request concerns substance rather than paperwork (sufficiency of funds, type of relationship, whether a relationship is genuine), the deadlines differ for several points, a document cannot be obtained in time, the representative has no access to the sede, the notification arrived long ago and you do not know the exact date, or the request has already led to a refusal. The answer depends on the procedure and the facts.
How we can help
The ReloVictory team in Barcelona reads the requerimiento with you, calculates the deadline, works out which points are closed with documents and which with explanations, prepares the explanatory letter and supports you in filing the response. Corrections and refiling are included in the cost of support; an appeal is not. The legal side is handled by the team’s lawyer, the administrative side by a graduada social. Book: consultation. Service page: documents and appointments with the authorities.
Frequently asked questions
What is a requerimiento de subsanación?
How many days do you get to respond to a requerimiento from extranjería?
Can the deadline to respond to a requerimiento be extended?
What happens if you do not respond to a requerimiento?
Can you respond after the deadline?
Where do you file the response?
Is the processing period for the application suspended because of a requerimiento?
Official sources
- BOE · Ley 39/2015, articles 5, 21, 22, 30, 32, 43, 68 and 73 ↗
- BOE · Real Decreto 1155/2024, articles 27, 77, 97, 130, 159, 160 ↗
- Sede administracionespublicas.gob.es · Mercurio: solicitudes y aportación de documentación ↗
Sources reviewed on 02.10.2026. Consolidated texts and government reference pages are for information only: applying the law depends on official publications, amendments and the specific circumstances. Reviewed by lawyer Francisco Romero Jiménez (ICAB 33641) on 21.10.2026.
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ReloVictory · Sources reviewed 02.10.2026 · Not a substitute for individual legal advice.
