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    GMS Flash Alert 2025-006

    Spain – Changes in Passport Renewal Policies for Venezuelan Nationals in Spain

    GMS Flash Alert 2025-006 | 8 January 2025

    Spain’s Directorate General of Migration Management (“DGMM”) and the General Commissary of Immigration and Borders (“GCIB”) have jointly issued a new Instruction, confirming that a valid Venezuelan passport is now a mandatory requirement for all immigration documentation processes in Spain.  This action effectively nullifies the previous Instruction1 from 15 March 2019, which had allowed Venezuelan nationals to submit expired passports for the processing of authorisations, permits, and the issuance of Foreign ID Cards (TIE).2

    This significant policy update was officially published by the Ministry of Inclusion, Social Security, and Migration on 16 December 20243, following the signing of the Instruction by the relevant authorities one month earlier.

    Effective 19 November 2024, the Spanish authorities have revoked the 2019 Instruction, citing confirmation that the Venezuelan Consulate in Madrid is now fully operational and equipped to renew passports.

    WHY THIS MATTERS

    The DGMM and GCIB have made it clear that a valid Venezuelan passport is now a mandatory requirement for all immigration documentation processes in Spain.  This update emphasises the need for Venezuelan nationals to make sure their passports are up-to-date to avoid any disruptions in their legal status and in the documentation processes in Spain.  The nullification of this 2019 Instruction could impact Venezuelan nationals should they not be in possession of a valid passport and need to complete an immigration process in Spain.

    For commercial entities and employers, this change necessitates heightened diligence in verifying the immigration documents of Venezuelan employees and applicants.  Fostering compliance with this new Instruction will be critical to help reduce the risk of legal complications and to support the continued legal residence and employment of Venezuelan nationals in Spain. 

    Background

    Previously, the 2019 Instruction was implemented due to the inability of Venezuelan nationals to access immigration procedures since they could not renew their passports through the Venezuelan consular services in Spain, which resulted in many of them assuming an “irregular stay” status.  Also, having an impact was the recommendation of the United Nations High Commissioner for Refugees (UNHCR) urging states to foster access by Venezuelan nationals to labour migration processes and systems so they would not be forced to return to Venezuela.  Following this, a joint directive was issued by Spain’s Director General of Migration and the Commissioner General of Foreign Affairs and Borders.

    This Instruction allowed the use of expired passports for the processing of authorisations and permits provided for in immigration regulations, as well as for the issuance and delivery of the TIEs, when requested by Venezuelan nationals.

    The validity of this aforementioned joint directive was determined solely by the duration of the extraordinary circumstances that prompted it.

    KPMG INSIGHTS

    The new Instruction affects not only initial applications but also renewals and modifications.  Employers may wish to consider reviewing their current foreign national workforce and plans in regards to Venezuelan nationals to help them formulate appropriate next steps so that their Venezuelan employees are not only aware of this change but also so that preparations can commence as soon as possible.  In light of the delays in obtaining documents, it is critical to prepare well in advance; once an immigration process is deemed necessary, there can be strict timeframes that do not align with the procurement estimates. 

    Affected parties should contact their usual immigration adviser or a member of the Immigration team with KPMG in Spain (see the Contacts section) for individualised support.

    KPMG strives to remain abreast of relevant developments and will endeavour to keep readers of GMS Flash Alert informed. 

    Footnotes:

    1  Instruction 2019 – Administración General del Estado, "Instrucción Conjunta del Director General de Migraciones y del Comisario General de Extranjeria y Fronteras por la Que Se Determina el Criterio a Tener en Cuenta Respecto a los Procedimientos de Extranjería Impulsados o Tramitados a Favor de Nacionales Venezolanos en España"  at: https://www.inclusion.gob.es/documents/410169/0/InstruccionVenezolanos.pdf/87336367-1259-5d91-3b81-6c594902d8f3?t=1686913287012.

    2  Instruction 2024 – “Instrucción Conjunta del Director General de Gestión Migratoria y del Comisario General de Extanjería y Fronteras” at: https://www.inclusion.gob.es/documents/d/migraciones/instruccion.

    3  La Asociación Progestión, publicado por Isabel Teruel, el 16 diciembre 2024, “Pasaportes venezolanos y procedimientos de extranjería” at: https://infoextranjeria.org/2024/12/16/pasaportes-venezolanos-y-procedimientos-extranjeria-19-noviembre-2024/ . Please note that by clicking on this link, you are leaving the KPMG website for an external site (non-KPMG, non-governmental) that KPMG is not affiliated with nor does KPMG endorse its content.  The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.

    Contacts

    miguel-arias
    Miguel Arias

    Partner

    KPMG in Spain

    patricia-contreras-garcia
    Patricia Contreras Garcia

    Senior Manager, Immigration Lawyer

    KPMG in Spain

    More information

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    Disclaimer

    * Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

    The information contained in this newsletter was submitted by the KPMG International member firm in Spain.

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