Health insurance for a Spanish residence permit: UGE rules and refusals

What insurance you need for a digital nomad residence: UGE requirements

The law requires “seguro público o seguro privado de enfermedad concertado con una Entidad aseguradora autorizada para operar en España”, that is, public insurance or private insurance taken out with an insurer entitled to operate in Spain (Article 62.3 e Ley 14/2013) [1]. The details are set by the UGE guidance and the consulates’ pages. Taken together, they give the following criteria.

The law lists only the first criterion. The rest are set out in the authorities’ guidance notes, which may be updated, so check the current pages of the UGE and of your consulate before you buy.

What copago, carencia and “reembolso” are and why they cause problems

Copago: the patient’s co-payment for each visit, procedure or medicine. Carencia: a waiting period after you buy the policy during which the insurance does not cover certain services. Reembolso: the policy pays you back after you have paid the doctor yourself, instead of paying for care directly.

The UGE lists these three features among those that make a policy unacceptable: “no se aceptan seguros de viaje, seguros basados únicamente en el reembolso de gastos médicos, seguros con copagos o períodos de carencia” [2]. The logic is clear: the SNS gives care immediately and with no co-payment, and the authority expects the same from a private substitute.

The UGE guidance says nothing about a franquicia (a fixed amount the policyholder pays before the insurer pays out). From public sources we do not know whether a policy with an excess is accepted: show such a policy to a lawyer before you apply.

Why policies are rejected: what the authorities explicitly exclude

We found no official statistics on why insurance policies are rejected. Below is what the UGE and the consulates explicitly call unacceptable, not how often each mistake occurs.

• A tourist or travel policy [2][3][5].
• A reimbursement policy that does not pay for care directly [2][3].
• A policy with copago or carencias [2][3].
• An insurer that is not authorised to operate in Spain or is not on the supervisory authority’s list [1][6].
• Cover narrower than the SNS [5][6].
• A policy shorter than the permit: the consulates in Moscow and Istanbul require it to be valid for the entire period [4][5].

If the policy terms do not fully match the requirement, the UGE advises attaching an explanatory letter [2]. It does not fix the mismatch, but it helps the case officer find the relevant clause in the terms.

How the UGE and consulate wording differs

Each authority uses its own wording, and they do not match word for word. If you apply through a consulate and then renew through the UGE, the same policy is read twice.

A safe rule: if the policy meets the strictest of these versions, any of the authorities will have fewer questions. We cannot say in advance which version your consulate or the UGE case officer will apply.

How to check a policy before buying it: step by step

1. Open the current UGE guidance on documents and your consulate’s page, and check the criteria as of the date you buy [2][4].
2. Check that the insurer is authorised to operate in Spain and is on the supervisory authority’s list (DGSFP) [1][6]. We could not open the register itself while preparing this article; look for it on the DGSFP website.
3. Ask the insurer for written confirmation that the policy has no copago and no carencias and that care is paid for directly, not reimbursed.
4. Check the duration. For the visa, the consulates in Moscow and Istanbul refer to the validity of the permit [4][5], and a permit obtained from within Spain, according to the consulate in Moscow, is issued for three years [4]: a one-year policy may fall short. Public materials do not say how the authority counts the period for a permit obtained from within Spain.
5. Make sure the certificate shows your first name and surname as in your passport, the period and the list of cover. If the document is not in Spanish, it must be translated: the UGE and the consulate in Moscow require translations of foreign documents [2][4].

When insurance is not needed and what about family members

The UGE guidance says that insurance documents are not needed if, after the permit is granted, you join the Spanish Seguridad Social (the general scheme for employees, RETA for the self-employed) [2]. The consulate in Bogotá says the same: insurance is not needed if cover by the public system is proven [6]. For a foreign company, this usually means that the employer is registered with the Spanish Seguridad Social and you are enrolled in it. More on social security: Digital Nomad and Seguridad Social.

If the applicant’s country has an international agreement with Spain that covers medical care, a certificate of entitlement to care from the competent authority of that country is submitted instead of a policy [2]. For citizens of Russia, Belarus, Kazakhstan and Ukraine we have not confirmed that such a certificate applies to the DNV, so do not count on it.

For family members, the UGE guidance for familiares requires their own policy unless they receive SNS care as beneficiaries through your activity [7]. The document we found is an older version, so check the conditions for family members with the authority.

Where insurance fits in the application and what to do about a requerimiento

In the UGE electronic form, insurance has its own line, “seguro público o privado de enfermedad”: the file is uploaded together with the passport, proof of income and the fee receipt [8]. The instructions for entrepreneurs describe the same interface; we have not double-checked the list of lines for remote work.

If the insurance raises a question, you will receive a requerimiento. In that case, do not send the same policy again: explain how it meets the criterion, or replace the policy. How to reply to a request: UGE requerimiento. The general list of documents for the application is in the residence permit document checklist.

How we can help

The ReloVictory team can check the terms of the policy you have chosen against the criteria of the UGE and your consulate, suggest which points to ask the insurer to confirm in writing, and prepare an explanatory letter for the application. The legal side is handled by the team’s lawyer. Book: consultation. Service page: Digital nomad residence permit. The whole route step by step is described in the DNV route card, and a general overview of the move is on the Residence permit in Barcelona page.

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