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    GMS Flash Alert 2025-020

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

    GMS Flash Alert 2025-020 | 23 January 2025

    Spain’s Directorate General of Migration Management (“DGMM”) and the General Commissary of Immigration and Borders (“GCIB”) have jointly issued another new Instruction1.

    Due to ongoing issues with Venezuelan consular services in Spain, many Venezuelans were deemed still unable to renew their passports.  As a result, the Spanish authorities have decided to revert to the policy allowing the use of expired Venezuelan passports for immigration documentation processes, similar to the rules under the directive issued in March 20192.  This action effectively nullifies the previous Instruction3 from last year, which did not allow Venezuelan nationals to submit expired passports for the processing of authorisations, permits, and the issuance of Foreign ID Cards (TIE)4.

    This significant policy update was officially published by the Ministry of Inclusion, Social Security, and Migration on 16 January 2024, following the signing of the Instruction by the relevant authorities the previous day; it is effective as of 14 January 2025.5

    WHY THIS MATTERS

    Considering the brief duration of the previous policy before the decision to reinstate the policies and processes supporting Venezuelan nationals with expired passports, it would be prudent to recognise the potential for another swift policy change.  Being as prepared as possible is generally recommended “policy.”

    The DGMM and GCIB have clarified that a valid Venezuelan passport is no longer an essential requirement for all immigration documentation processes in Spain (whereas under the prior short-lived rule, it was mandatory).  Having said that, it is good practice for Venezuelan nationals to continue to strive to keep their passports up-to-date, given the current challenges they face, to help prevent any potential future disruptions to their legal status and documentation processes in Spain.

    For commercial entities and employers, this policy change necessitates increased diligence in verifying the immigration documents of Venezuelan employees and applicants.

    Background

    The 2019 Instruction mentioned earlier was implemented because Venezuelan nationals faced difficulties accessing immigration procedures due to their inability to renew passports through Venezuelan consular services in Spain, resulting in many assuming an "irregular stay" status.  Additionally, the United Nations High Commissioner for Refugees (UNHCR) recommended that states facilitate access to labour migration processes for Venezuelans to prevent forced returns to Venezuela.  Consequently, Spain's Director General of Migration and the Commissioner General of Foreign Affairs and Borders issued a joint directive.

    In November 2024, Spanish authorities revoked the 2019 Instruction, stating that the Venezuelan Consulate in Madrid was now fully operational and capable of renewing passports.6  The new directive mandated that a valid Venezuelan passport was required for all immigration documentation processes in Spain, thereby nullifying the Instruction of 15 March 2019, which had permitted Venezuelan nationals to use expired passports for processing authorisations, permits, and issuing Foreign ID Cards (TIE).

    KPMG INSIGHTS

    The new Instruction returns to a more “relaxed” approach to Venezuelan passports.

    Companies may wish to review their foreign national workforce plans concerning Venezuelan nationals to determine which employees have valid passports or are actively working on renewing expired ones.

    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 2025 – “Instrucción Conjunta del Director General de Gestión Migratoria y del Comisario General de Extranjeria y Fronteras” (in Spanish) at:  https://www.inclusion.gob.es/documents/d/migraciones/20250113-instruccion-conjunta-validez-pasaportes-venezolanos-caducados

    2  Instruction 2019 – Administración General del Estado, "Instrucción Conjunta del Director General de Migraciones y del Comisario General de Extranjería 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" (in Spanish) at: https://www.inclusion.gob.es/documents/410169/0/InstruccionVenezolanos.pdf/87336367-1259-5d91-3b81-6c594902d8f3?t=1686913287012.

    3  Instruction 2024 – “Instrucción Conjunta del Director General de Gestión Migratoria y del Comisario General de Extranjería y Fronteras” (in Spanish) at: https://www.inclusion.gob.es/documents/d/migraciones/instruccion.

    4  See GMS Flash Alert 2025-006, 8 January 2025.

    5  Ibid.

    6  Ibid.

    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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