EX-31 Form Spain 2026: Arraigo for International Protection Applicants

EX-31 is Spain’s special form for the 2026 residence-by-arraigo procedure created for certain people who had applied for international protection in Spain before 1 January 2026. The initial application window closed on 30 June 2026, so new applicants can no longer start this special EX-31 route.

However, EX-31 remains highly relevant for people who:

• submitted an EX-31 application before the deadline and are waiting for a decision;
• received provisional residence and work rights while their application is pending;
• have been approved and need to obtain their TIE;
• need to understand what happens to a pending asylum application after approval;
• received the one-year EX-31 residence authorization and need to plan the next immigration step;
• may qualify for an exceptional EX-31 extension;
• have qualifying family members or children whose applications were linked to the 2026 procedure.

The special route was introduced in April 2026 through Royal Decree 316/2026, which added the Twentieth Additional Provision to Spain’s Immigration Regulation.

EX-31 should not be confused with standard arraigo under EX-10, Spain’s 2026 extraordinary regularization route, or Hoja Informativa 31.

To compare all Spanish immigration forms, see our Spain Immigration Forms: EX-00 to EX-32 guide.

What Is EX-31?

The official EX-31 form is titled:

Solicitud de aplicación de la Disposición adicional vigésima del Reglamento de la Ley Orgánica 4/2000

It concerns:

Autorizaciones de residencia por circunstancias excepcionales por razón de arraigo para personas solicitantes de protección internacional

In practical terms, Spain created a temporary special residence opportunity for certain people who had entered the international-protection system before 2026 but were living in Spain without another residence or stay authorization.

The procedure was deliberately time-limited.

New initial applications could be submitted only until:

30 June 2026

That deadline has now passed.

EX-31 at a Glance

Question	Answer
Form	EX-31
Main purpose	Special arraigo for certain international-protection applicants
Legal basis	Twentieth Additional Provision of RD 1155/2024
Created by	RD 316/2026
International-protection cutoff	Application initiated before 1 January 2026
Initial EX-31 filing deadline	30 June 2026
Can a new initial application be filed now?	No
Minimum continuous presence required for initial applicants	5 months before application
Applicant had to be in Spain	Yes
Applicant had to be an adult	Yes
Temporary Protection holders eligible	No
Provisional work rights while pending	Yes
Employee work	Yes
Self-employment	Yes
Geographic restriction	No
Sector restriction	No
Official decision period	3 months
Administrative silence	Negative
Initial authorization validity	1 year
TIE after approval	Yes
Normal next step	Modification under Article 191
Exceptional extension possible	Yes

The EX-31 Filing Window Is Closed

This point should now appear near the beginning of every accurate EX-31 guide.

The special authorization could be requested only until:

30 June 2026.

Therefore, a person who did not file the initial special application before that deadline cannot now begin a new EX-31 application merely because they:

• previously applied for asylum;
• currently have an asylum case;
• received an asylum refusal;
• have lived in Spain for several months;
• have become undocumented;
• want to obtain arraigo.

The expiry of the filing period does not make EX-31 irrelevant.

Thousands of people can still have:

• pending applications;
• recently approved authorizations;
• provisional work rights;
• future modification or extension questions.

The page should therefore now focus heavily on what happens after an EX-31 application was filed.

Who Could Apply for EX-31?

The initial route was available to qualifying foreign nationals who, before 1 January 2026, had taken one of the recognized steps to enter Spain’s international-protection procedure.

This included people who had:

• requested access to the international-protection procedure;
• registered an international-protection request;
• formally submitted an international-protection application in Spain.

The timing of the international-protection application was essential.

A person who first applied for international protection on or after 1 January 2026 did not fall within this specific EX-31 measure.

Did the Asylum Case Need to Still Be Pending?

No.

This was an important feature of the special EX-31 procedure.

A qualifying person could potentially use the route even if they had already lost the formal status of international-protection applicant.

This could include situations where:

• asylum had been refused;
• the person had withdrawn the international-protection application;
• an appeal had been withdrawn;
• another event had ended their status as an international-protection applicant.

The critical question was whether the person had entered the Spanish international-protection procedure before 1 January 2026 and satisfied the remaining EX-31 conditions.

What If the Asylum Application Was Still Pending?

A pending international-protection application did not automatically prevent EX-31.

This was a major difference between EX-31 and ordinary current arraigo.

A qualifying applicant could submit EX-31 while an international-protection procedure or appeal was still pending.

However, if EX-31 was approved, an additional step became necessary.

The person had to withdraw:

• the pending international-protection application; or
• the pending appeal, where applicable.

Proof that the withdrawal had been requested was then needed for the TIE stage.

EX-31 vs Standard Arraigo for Asylum Applicants

EX-31 was a special temporary exception.

Under Spain’s ordinary current arraigo rules, a person generally cannot be an international-protection applicant when submitting or processing a standard arraigo application.

Time spent while holding international-protection applicant status also has special treatment when calculating the ordinary continuous-presence requirement.

EX-31 was specifically created to avoid applying those ordinary restrictions to the limited group covered by the 2026 measure.

For Spain’s standard current arraigo categories, see our EX-10 Arraigo guide.

Main EX-31 Requirements

The initial applicant had to satisfy all of the applicable statutory conditions.

Applicant Had to Be an Adult

The principal EX-31 applicant had to be:

18 years old or older.

Children were dealt with through related family and minor-residence provisions rather than simply being treated as adult EX-31 applicants.

Applicant Had to Be in Spain

The applicant had to be physically present in Spain when the EX-31 application was submitted.

This was not a Spanish consular residence application.

It was an in-country exceptional-circumstances procedure.

No Existing Residence or Stay Authorization

At the time of applying, the foreign national could not already be the holder of another Spanish:

• residence authorization; or
• stay authorization.

EX-31 was intended to regularize a particular population rather than duplicate an immigration status the person already held.

No Other Pending Residence or Stay Procedure

The applicant also could not be an interested party in another pending procedure involving:

• grant of a residence or stay authorization;
• extension;
• renewal;
• modification.

This prevented people from simultaneously pursuing multiple incompatible immigration regularization procedures.

Temporary Protection Was an Exclusion

A person could not use the special EX-31 route if they were or had previously been the holder of residence granted under the EU Temporary Protection framework activated following the displacement from Ukraine.

This is important because temporary protection and EX-31 were separate legal systems.

Someone protected under Spain’s Ukraine Temporary Protection regime should not have been advised to abandon that status simply to pursue EX-31.

Five Months of Continuous Presence in Spain

The applicant had to demonstrate:

five months of uninterrupted presence in Spain immediately before submitting EX-31.

Spain allowed this presence to be proven through any evidence legally capable of demonstrating it, provided the documentation contained sufficient personal information to identify the applicant.

What Could Prove Five Months in Spain?

Potential evidence could include:

• padrón certificates;
• healthcare records;
• asylum documentation;
• social-services records;
• bank records;
• rental documentation;
• official appointments;
• administrative applications;
• educational records;
• employment-related evidence;
• transport records;
• public-authority documents;
• other reliable dated evidence.

The strongest evidence normally creates a timeline covering the complete required period rather than relying on one document from five months earlier.

Evidence From Previous Immigration Procedures

Spanish authorities specifically encouraged applicants to provide previous records showing presence in Spain.

These could include even unfavorable immigration records such as:

• previous immigration applications;
• previous asylum documentation;
• return decisions;
• records from temporary holding facilities;
• invitation letters;
• earlier asylum refusals;
• expulsion proceedings related to irregular stay.

A negative immigration document can still be useful evidence of physical presence in Spain.

Criminal Record Requirement

EX-31 applicants had to satisfy Spain’s criminal-record rules.

The applicant was generally required to provide a criminal-record certificate from the country or countries where they had lived during the:

five years before entering Spain.

Spain also checks its own criminal and police databases.

Criminal records that are legally eligible for cancellation in Spain receive specific treatment under the current framework.

What If You Requested the Foreign Criminal Record but Never Received It?

The special EX-31 procedure included an unusual mechanism for this problem.

If the applicant could prove that:

1. they requested the required foreign criminal-record certificate; and
2. one month passed without receiving it,

Spain could initiate a diplomatic request for the document.

The EX-31 package includes special annexes for this process.

The applicant needs to provide documentation including:

• evidence that the foreign certificate was requested;
• the required responsible declaration;
• authorization allowing Spanish authorities to request the criminal record from the foreign country.

The authorization may need to be presented both:

• in Spanish; and
• in the language required by the foreign country.

Can the EX-31 Procedure Be Suspended While Spain Requests Criminal Records?

Yes.

When Spanish authorities use the diplomatic criminal-record mechanism, the immigration procedure can be suspended for up to:

three months.

Importantly, the applicant’s provisional residence and work authorization continues during the applicable suspension.

If the criminal-record document still cannot be obtained through that process, the applicant can ultimately be required to provide it within the period set by the administration.

Ignoring that request can result in the application being treated as withdrawn.

Public Order and Security

The applicant could not represent a threat to:

• public order;
• public security;
• public health.

Spanish authorities obtain:

• Central Criminal Records information;
• relevant European database information;
• a police report.

An adverse item in a police report is not necessarily an automatic refusal.

The authorities must assess the circumstances of the individual case.

Entry Restrictions

The applicant could not be listed as inadmissible in the territory of countries with which Spain has the relevant arrangement.

Applicable immigration restrictions therefore had to be checked.

Voluntary Return Commitment

Where the applicant had previously accepted a Spanish voluntary-return programme containing a no-return commitment, they could not still be within that prohibited-return period.

EX-31 Documents

A typical initial EX-31 file included:

• completed and signed EX-31;
• complete copy of passport, even if expired;
• or qualifying Cédula de Inscripción;
• or recognized travel document;
• evidence of the international-protection application before 1 January 2026;
• evidence of the required continuous presence in Spain;
• criminal-record certificate;
• fee documentation;
• family documentation where applicable;
• representation documentation where applicable;
• required criminal-record annexes where the exceptional diplomatic procedure was used.

The government also recommended including previous Spanish documentation capable of establishing the applicant’s presence.

Could an Expired Passport Be Used?

Yes.

The special EX-31 framework expressly allowed a complete copy of certain identity or travel documents even where they had expired.

This could include:

• passport;
• Cédula de Inscripción;
• recognized travel document.

That flexibility was particularly important for people who had spent a long period in the asylum system or could not easily obtain renewed national documentation.

This does not mean a valid passport is unimportant for later:

• travel;
• TIE procedures;
• consular matters;
• other immigration procedures.

EX-31 Fee

The residence-processing fee uses:

Modelo 790 Código 052

under the category for:

temporary residence due to exceptional circumstances — arraigo.

The fee became due when the EX-31 application was admitted for processing.

It generally had to be paid within:

10 working days.

What If the Applicant Did Not Have an NIE?

Applicants without an NIE were specifically instructed not to pay the Modelo 790 Código 052 fee in advance.

Instead, they should wait until the admission-for-processing communication requests payment.

This avoided problems generating or associating the fee before the administration had assigned the necessary identifying information.

How Could EX-31 Be Submitted?

During the filing period, the special procedure allowed several presentation methods.

Applications could be submitted:

• electronically through Mercurio;
• personally through authorized public offices;
• through a representative;
• through designated immigration offices;
• through certain Correos offices;
• through certain Social Security offices;
• through other public offices specifically enabled for the programme.

Electronic filing began in April 2026, followed by the designated physical filing system.

The initial filing programme closed on 30 June 2026.

Can You Submit a New EX-31 Through Mercurio Now?

The fact that EX-31 remains visible in government systems does not mean the initial application window remains open.

The statutory deadline was:

30 June 2026.

After that date, a new applicant cannot normally revive the special initial residence route merely by uploading the form electronically.

EX-31 remains relevant for existing applications and later procedures expressly provided for holders of the special authorization.

Who Decides EX-31?

The decision-making authority for the special procedure is the:

Dirección General de Gestión Migratoria

The government created a specialized processing structure to handle these applications.

This was not simply an ordinary local arraigo process decided independently under different legal criteria by each province.

The substantive requirements were national.

How Long Does EX-31 Take?

The statutory maximum decision period is:

three months

from the day after the application entered the register of the competent authority.

The period can be suspended in legally permitted circumstances, including certain criminal-record verification procedures.

Is Administrative Silence Positive?

No.

If the statutory period expires without notification of a decision, the application can be considered:

refused through negative administrative silence.

Do not assume that three months without a decision means residence has automatically been approved.

Can a Requerimiento Extend the Process?

Yes.

If the application is incomplete, the authorities can issue a requerimiento requesting correction or additional documentation.

Under the special framework, the correction period specified by the administration cannot exceed:

15 days.

Failure to respond can result in:

• the applicant being treated as having withdrawn the request;
• closure of the expediente.

Monitor notifications closely.

EX-31 Provisional Residence Rights

One of the most important features of the special procedure was that applicants did not necessarily need to wait for final approval before acquiring a documented temporary right to remain.

From the official communication confirming the start of processing, the applicant received provisional authorization to:

reside in Spain while EX-31 was pending.

This provisional protection remained until the application was decided, subject to the rules governing the procedure.

Can You Work While EX-31 Is Pending?

Yes.

From the communication initiating the administrative processing, a qualifying EX-31 applicant was provisionally authorized to work:

• as an employee;
• as self-employed;
• anywhere in Spain;
• in any occupation;
• in any economic sector.

This was a much broader provisional work right than many ordinary immigration procedures provide.

The communication initiating the procedure should expressly indicate that the applicant is provisionally authorized to work.

Can an Employer Legally Hire a Pending EX-31 Applicant?

Where the applicant has received the official communication establishing provisional work authorization, the EX-31 framework permits employment while the case remains pending.

Employers should retain appropriate evidence of:

• the applicant’s identity;
• provisional authorization;
• Social Security registration;
• employment documentation.

The work right is tied to the provisional immigration authorization.

Can a Pending EX-31 Applicant Become Autónomo?

The provisional authorization also allows qualifying applicants to work:

por cuenta propia

or as self-employed.

The person must still comply with ordinary Spanish requirements for operating a self-employed activity, including relevant:

• tax registration;
• Social Security registration;
• professional or business rules.

Immigration permission to work does not eliminate normal Spanish business obligations.

What Happens to Provisional Work Rights After Approval?

Where the application is approved, the holder receives the definitive one-year exceptional-circumstances residence authorization with broad work rights.

The regulation also provides for the authorization’s effects to relate back to the application date where applicable.

What Happens to Provisional Work Rights After Refusal?

A refusal causes the provisional work authorization to end automatically.

No separate cancellation decision is required.

If the person was working as an employee, they must immediately inform the employer of the outcome after receiving the refusal.

This makes monitoring official notifications particularly important.

Does EX-31 Stop an Expulsion Procedure?

A favorable EX-31 decision can have an important effect where the applicant is subject to certain return or expulsion proceedings connected with irregular immigration status.

Where the applicable statutory conditions are satisfied, approval results in:

• closure of the relevant expulsion or return procedure; and
• where applicable, revocation of the order.

This does not mean EX-31 automatically cancels every type of expulsion order regardless of its legal basis.

The special rule applies to the specific immigration infringements identified in the legislation.

How Long Is EX-31 Residence Valid?

The definitive EX-31 residence authorization is valid for:

one year.

It is classified as:

temporary residence due to exceptional circumstances by reason of arraigo social

under the special Twentieth Additional Provision framework.

Despite the special international-protection background, the final authorization therefore enters Spain’s residence system as an exceptional-circumstances arraigo authorization.

Can an Approved EX-31 Holder Work?

Yes.

The one-year authorization permits:

• employee work;
• self-employment;
• work anywhere in Spain;
• work in any occupation;
• work in any sector.

The holder does not need to obtain a separate ordinary employee work permit after EX-31 approval.

What Happens to the Asylum Application After EX-31 Approval?

If the international-protection application or appeal is still pending when EX-31 is approved, the applicant must withdraw it.

The person should obtain evidence showing that the withdrawal request has been submitted.

That evidence becomes important for the TIE.

This should not be confused with withdrawing asylum before knowing whether EX-31 has been approved.

The special legal structure specifically connects withdrawal with a favorable residence decision.

TIE After EX-31 Approval

The holder must request a:

Tarjeta de Identidad de Extranjero — TIE

within:

one month after notification of the favorable decision.

The TIE is requested personally through the competent Policía Nacional documentation service.

Where the asylum application or appeal was still pending, the applicant must provide the appropriate proof of withdrawal.

For the physical card procedure, see our EX-17 TIE Form guide and TIE Card Spain guide.

EX-31 and Family Members

The special framework also allowed certain adult relatives who formed part of the applicant’s household to apply simultaneously.

These included:

• first-degree ascendants;
• spouse;
• registered partner.

Each adult family applicant had to satisfy the applicable EX-31 requirements.

The existence of the family relationship alone was not enough.

The related applications could be processed and decided simultaneously.

Could a Spouse Apply Without Having Applied for Asylum?

The simultaneous-family provisions need to be read carefully.

EX-31 did not create an unrestricted family-reunification right for every relative of the principal applicant.

The family member had to fall within the specific special framework and satisfy the requirements applicable to that related application.

A person should not assume that simply being married to an EX-31 applicant automatically created residence.

Children of EX-31 Applicants

The 2026 reform included special protection for children.

Where an EX-31 applicant had:

• minor children; or
• adult children with disabilities requiring support,

qualifying residence applications could be submitted simultaneously under the foreign-minor provisions of Articles 159 or 160.

The applications could then be decided together.

Child Born in Spain

Article 159 normally covers qualifying foreign children born in Spain.

During the special 2026 measure, the normal requirement to submit the application within six months of birth was waived for qualifying cases submitted within the special period.

Child Not Born in Spain

Article 160 normally contains significantly more demanding requirements for children born outside Spain who are already living here.

During the 2026 measure, qualifying children benefited from temporary flexibility.

The usual requirements concerning:

• two years of previous presence;
• sufficient economic resources;
• adequate housing

could be waived.

However, the child still had to demonstrate:

five months of uninterrupted presence in Spain before the application.

How Long Is Residence for Qualifying Children?

The residence authorizations issued under the applicable Articles 159 and 160 framework have a validity of:

five years

subject to the current rules governing foreign minors.

The child’s best interests must be taken into account.

For the full minor-residence framework, see our EX-25 Foreign Minors guide.

Has the Special Child Filing Period Also Closed?

Yes.

The temporary EX-31-linked flexibility applied to qualifying applications made within the special programme period.

The statutory filing deadline was:

30 June 2026.

The rules remain relevant to applications already filed before the deadline but should not be presented as a new application route available indefinitely.

EX-31 vs EX-32

EX-31 and EX-32 were created for different 2026 regularization populations.

EX-31

Designed specifically around people with a qualifying history in Spain’s international-protection system before 1 January 2026.

EX-32

Connected with Spain’s separate 2026 extraordinary arraigo framework for qualifying foreign nationals meeting that procedure’s conditions.

Do not choose between EX-31 and EX-32 based simply on which form appears easier.

Each had its own statutory eligibility rules and deadline.

EX-31 vs EX-10

EX-10 is the standard form for Spain’s ordinary current arraigo and several other exceptional-circumstances residence categories.

EX-31 was a special, temporary 2026 procedure.

EX-31	EX-10
Special 2026 measure	Standard current exceptional-circumstances form
International-protection history required	Depends on ordinary arraigo category
5-month special presence rule	Standard arraigo generally uses its own presence rules
Asylum history central	Ordinary current arraigo has different asylum restrictions
Filing deadline 30 June 2026	Continues under ordinary immigration law
Initial authorization 1 year	Duration depends on category

A person who missed the EX-31 deadline should not simply submit EX-10 without checking whether they independently satisfy one of the ordinary current arraigo routes.

What Happens When the One-Year EX-31 Permit Is About to Expire?

This is now one of the most important sections of the EX-31 procedure.

The normal next step is not another initial EX-31 application.

The standard route is to request a:

modification under Article 191 of the Immigration Regulation.

The modification should normally be submitted during the:

two months before the EX-31 authorization expires.

For modification procedures, see our EX-26 Modification of Residence and Work Status guide.

Can You Apply After the EX-31 Permit Expires?

The modification can also be submitted during the:

three months after expiration.

Submitting during that late period can still extend the previous authorization until the modification procedure is decided.

However, late filing can expose the applicant to an administrative sanction.

The better strategy is to prepare during the two months before expiry.

Does Filing the Modification Extend the EX-31 Permit?

Yes.

A modification filed within the applicable period extends the validity of the previous authorization until the modification procedure is decided.

This is important for maintaining:

• lawful residence;
• work authorization;
• Social Security continuity;
• employment.

Which Modification Can Follow EX-31?

The correct destination depends on the holder’s circumstances at the end of the first year.

Potential routes can involve ordinary:

• employee residence and work;
• self-employed residence and work;
• another qualifying residence/work status under Article 191.

Do not wait until the final weeks of the authorization to determine whether the requirements can be satisfied.

Can EX-31 Be Extended Instead of Modified?

Yes, but extension is intended to be exceptional where the person cannot obtain the normal Article 191 modification.

The current EX-31 form includes specific extension options.

There are two important extension categories.

One-Year EX-31 Extension

Where the holder cannot obtain the normal modification, EX-31 can exceptionally be extended if the person demonstrates either:

• active job seeking and proper registration with the public employment service; or
• a favorable integration-effort report recommending the extension.

This extension has a validity of:

one year.

Active Job Search Requirement

A person relying on the employment-search route must demonstrate:

• active search for employment; and
• registration with the appropriate public employment service.

Merely stating that employment has been difficult to find is not enough.

Keep documentation showing active participation in the labour market.

Integration-Effort Report

An alternative can involve an:

informe de esfuerzo de integración

issued by the competent authority in the Autonomous Community where the applicant lives.

The favorable report should recommend extension.

It can examine matters including integration efforts and knowledge of the official languages of the place of residence.

Four-Year Exceptional EX-31 Extension

A much longer extension can be available where serious circumstances prevent access to employment.

The current rules identify situations such as:

• serious illness of the applicant;
• disability of the applicant;
• serious illness or disability affecting the applicant’s spouse;
• serious illness or disability affecting a first-degree descendant who is a minor;
• serious health circumstances affecting an adult first-degree descendant who cannot objectively provide for their own needs;
• the applicant having reached Spain’s legal retirement age.

Where the legal conditions are met, this exceptional extension lasts:

four years.

Is Active Job Search Required for the Four-Year Extension?

No.

Where the holder qualifies under the serious illness, disability or retirement provisions, the one-year active-job-search or integration-report requirements do not need to be demonstrated.

The legal basis for extension is different.

EX-31 Form Options After the Initial Filing Period

The current EX-31 form itself reflects its continuing use after the original application window.

Section 4 includes categories for:

• qualifying international-protection applicant;
• child born in Spain;
• child not born in Spain;
• qualifying family member;
• extension based on active job search or integration effort;
• extraordinary extension because of serious illness, disability or retirement.

This is why EX-31 should not be described in 2026 as a form that became completely useless after 30 June.

The initial application window closed, but the form continues to have legal relevance for existing beneficiaries.

EX-31 vs EX-26 After Approval

These forms can form part of the same immigration journey.

A common sequence is:

EX-31 → One-year exceptional residence → EX-26 modification → Ordinary residence/work authorization

EX-31 establishes the special 2026 residence.

EX-26 is generally used for the later Article 191 modification.

Where the holder cannot modify and qualifies for an EX-31 extension, the EX-31 extension route can instead be examined.

What If an EX-31 Application Is Still Pending?

If you filed before 30 June 2026 and have not yet received a decision:

• do not submit a second initial EX-31 application;
• monitor official notifications;
• keep your address current;
• respond quickly to any requerimiento;
• retain the communication confirming provisional residence/work rights;
• maintain employment and Social Security documentation if working;
• keep copies of all documents submitted;
• monitor the three-month decision period and any formal suspension;
• obtain professional advice if the statutory decision period expires without notification.

What If the Three-Month Period Has Passed?

Because EX-31 is subject to negative administrative silence, expiration of the statutory period is not automatic approval.

However, administrative silence and an express refusal are not identical procedural events.

If your case has exceeded the statutory period, review:

• whether processing was formally suspended;
• whether a requerimiento interrupted or affected the calculation;
• whether a criminal-record request caused suspension;
• whether the expediente is still actively being processed;
• what administrative or judicial options are available.

Do not simply assume that the residence has been granted because three months have passed.

What If EX-31 Is Approved?

After approval:

1. check the decision carefully;
2. if asylum or an appeal remains pending, request its withdrawal;
3. keep the withdrawal receipt;
4. request the TIE within one month;
5. continue employee or self-employed work as permitted;
6. note the authorization expiry date;
7. begin planning the Article 191 modification well before the final two months.

The one-year period passes quickly.

Planning the next status should begin long before expiry.

What If EX-31 Is Refused?

A refusal ends the provisional work authorization automatically.

The person should then review:

• the stated reason for refusal;
• whether documents were missing;
• whether the government applied the eligibility requirements correctly;
• available administrative appeal options;
• available judicial review;
• whether another independent Spanish immigration route is possible.

Do not continue relying on the provisional EX-31 work authorization after a refusal.

Does EX-31 Lead Directly to Permanent Residence?

No.

The initial authorization lasts one year.

The normal strategy is to transition into another qualifying Spanish residence authorization.

Time spent in legal residence can then become relevant to longer-term immigration goals subject to the requirements applicable to:

• long-term residence;
• Spanish nationality;
• other future statuses.

EX-31 itself is not a five-year permanent residence permit.

Does EX-31 Count Toward Spanish Citizenship?

EX-31 is a residence authorization rather than an asylum-applicant document.

Periods of legal residence can potentially be relevant when calculating residence for Spanish nationality, subject to Spain’s nationality rules and the individual applicant’s circumstances.

Do not automatically include previous asylum-applicant time as though it were ordinary legal residence for nationality purposes.

The periods before and after EX-31 can have different legal characteristics.

Can an EX-31 Holder Travel Outside Spain?

After obtaining the definitive residence authorization and valid TIE, the person can generally travel subject to:

• passport validity;
• residence-card validity;
• destination-country requirements;
• Schengen rules.

A pending EX-31 application and provisional work authorization should not automatically be treated as equivalent to possessing a valid residence TIE for international travel.

Travel while documentation is pending requires special care.

Common EX-31 Mistakes

Thinking Initial EX-31 Applications Are Still Open

The deadline was 30 June 2026.

Applying Because You Filed Asylum After 1 January 2026

The special international-protection cutoff was before 1 January 2026.

Thinking EX-31 Is an Asylum Application

It is not.

Confusing EX-31 With Hoja Informativa 31

A Modelo EX number and an information-sheet number are different things.

Confusing EX-31 With Ordinary Arraigo Familiar

Current standard arraigo familiar is a separate procedure.

Confusing EX-31 With EX-32

They were different special 2026 routes.

Assuming Asylum Had to Be Refused First

A qualifying asylum or appeal procedure could still be pending when EX-31 was filed.

Withdrawing Asylum Without Understanding the EX-31 Sequence

Where asylum was pending, withdrawal became particularly important after a favorable EX-31 decision and before TIE issuance.

Assuming Every Former Asylum Applicant Qualified

EX-31 had multiple cumulative requirements.

Forgetting the Five-Month Presence Requirement

Continuous presence had to be demonstrated.

Ignoring Another Pending Residence Application

Applicants could not simultaneously be interested parties in another qualifying stay or residence application procedure.

Ignoring Temporary Protection History

People who held the specified EU Temporary Protection residence were excluded.

Paying the Fee Too Early Without an NIE

Applicants without an NIE were told to wait until the admission communication requested payment.

Ignoring a Requerimiento

Failure to correct the file could result in it being closed.

Thinking Provisional Work Rights Begin Merely Because EX-31 Was Prepared

The important point is the official communication initiating processing.

Thinking Provisional Work Is Limited to One Employer

The special authorization covered employee and self-employed activity nationwide without occupational or sector restriction.

Continuing to Work After a Refusal

Provisional work rights end automatically after refusal.

Forgetting to Obtain the TIE

An approved applicant must request the physical card within one month.

Waiting Until the One-Year Permit Expires to Plan the Next Step

The normal modification period begins two months before expiry.

Assuming EX-31 Automatically Renews for Another Year

Modification is the normal next route. EX-31 extension is exceptional.

Missing the Difference Between One-Year and Four-Year Extensions

The legal requirements are completely different.

EX-31 Pending Application Checklist

If you filed EX-31 before the deadline and the application is still pending, check that:

• you have the submission receipt;
• you have the EX-31 expediente information;
• you retained the communication initiating processing;
• your provisional residence/work authorization is documented;
• your notification address is current;
• DEHú is monitored where used;
• the Modelo 790 Código 052 fee was paid when required;
• criminal-record evidence is complete;
• any special criminal-record annexes were submitted where needed;
• all requerimientos have been answered;
• employment documentation is retained if working;
• Social Security registration is correct;
• autónomo registration is correct if self-employed;
• any formal suspension of the case has been recorded;
• the three-month decision period is being tracked.

EX-31 Approval Checklist

After a favorable EX-31 decision:

• save the complete approval resolution;
• check the effective date;
• check the one-year validity period;
• withdraw the international-protection application if still pending;
• withdraw any applicable pending asylum appeal;
• obtain proof of the withdrawal request;
• book the TIE procedure;
• request the TIE within one month;
• retain evidence of work authorization;
• check Social Security status;
• calculate the two-month pre-expiry modification window;
• begin preparing the next residence route early.

EX-31 Extension Checklist

Before requesting an EX-31 extension, determine first whether an Article 191 modification is possible.

If modification is not possible, identify whether you qualify through:

One-Year Extension

Prepare evidence of:

• active employment search;
• registration with the public employment service;

or:

• favorable integration-effort report recommending extension.

Four-Year Exceptional Extension

Prepare evidence establishing the qualifying reason, such as:

• serious illness;
• disability;
• qualifying serious family health circumstances;
• legal retirement age.

Medical or other evidence should clearly demonstrate why access to employment is prevented.

Frequently Asked Questions About EX-31

What is EX-31 in Spain?

EX-31 is the special form created for the 2026 arraigo procedure for certain people who had entered Spain’s international-protection system before 1 January 2026.

Can I submit a new EX-31 application now?

No.

The initial application deadline was 30 June 2026.

Why is EX-31 still important?

Because applications remain under processing, approvals are being issued, holders need TIEs, and the form also contains extension options for existing beneficiaries.

Who could originally apply?

Qualifying adults who had entered Spain’s international-protection procedure before 1 January 2026 and met all of the special residence requirements.

Did I need to have an asylum application still pending?

No.

A person could potentially qualify even after losing international-protection applicant status.

Could I apply while asylum was still pending?

Yes, if the special EX-31 requirements were satisfied.

What happens to asylum after EX-31 approval?

If the asylum application or appeal remains pending, the person must request withdrawal and provide evidence of that step for the TIE procedure.

Is EX-31 the same as an asylum application?

No.

Is EX-31 the same as EX-10?

No.

EX-10 is the standard current form for ordinary arraigo and other exceptional-circumstances procedures.

Is EX-31 the same as EX-32?

No.

EX-32 belongs to the separate 2026 extraordinary arraigo framework.

How long did I need to be in Spain?

The special initial EX-31 route required five months of uninterrupted presence immediately before application.

Did asylum time count?

EX-31 was specifically designed around people with an international-protection history, making it different from ordinary current arraigo rules.

Could a Temporary Protection holder apply?

No, where they were or had been a holder of residence under the specified EU Temporary Protection framework.

Could someone with another residence permit apply?

No.

The principal applicant could not already hold another stay or residence authorization.

Could I have another residence application pending?

No, not one of the specified grant, extension, renewal or modification procedures.

Could an expired passport be used?

The special framework allowed complete copies of specified identity or travel documents even where expired.

What criminal record was required?

Applicants generally needed certificates from countries where they had lived during the five years before entering Spain.

What if I could not get the foreign criminal record?

The special procedure created a mechanism allowing Spain to seek the document diplomatically after the applicant demonstrated that the certificate had been requested and one month had passed without receipt.

Which fee applies?

Modelo 790 Código 052 under the exceptional-circumstances arraigo category.

When was the fee paid?

It became due when the application was admitted for processing and generally had to be paid within 10 working days.

What if I did not have an NIE?

Applicants without an NIE were instructed to wait for the admission communication before paying the fee.

Could EX-31 be filed online?

During the initial filing period, electronic presentation through Mercurio was available.

Could a representative file it?

Yes, under the rules governing representation.

How long does EX-31 take?

The official maximum decision period is three months, subject to permitted suspensions.

Is silence positive after three months?

No.

Administrative silence is negative.

Can I live in Spain while EX-31 is pending?

The special procedure provides provisional residence from the communication initiating processing.

Can I work while EX-31 is pending?

Yes, from the relevant initiation communication.

Can I work full-time?

The provisional authorization permits work without the limited-hours structure associated with some student permits.

Can I work anywhere in Spain?

Yes.

Can I become self-employed?

Yes, subject to the normal tax, Social Security and business requirements.

What happens if EX-31 is refused?

The provisional work authorization ends automatically.

How long is approved EX-31 residence?

One year.

Can I work after approval?

Yes, as an employee or self-employed person throughout Spain in any occupation or sector.

When do I need the TIE?

Within one month after notification of approval.

Which TIE form is used?

The physical TIE procedure is associated with EX-17.

Could family members apply?

Certain first-degree ascendants, spouses and registered partners forming part of the household could apply simultaneously under the special rules and had to satisfy the applicable requirements.

What about children?

Qualifying minor children and certain adult children with disabilities could have linked residence applications under Articles 159 or 160.

How long is the child’s residence?

Qualifying Article 159 or 160 residence is generally valid for five years.

Is the special child route still open?

The special 2026 filing window ended on 30 June 2026. The rules remain relevant to applications already submitted.

What happens when my one-year EX-31 permit is close to expiry?

The normal next step is to request a modification under Article 191.

When should I modify?

During the two months before expiry.

Can I modify after expiry?

A filing during the three months after expiry is possible under the applicable rule, although an administrative sanction can arise.

Does filing extend my old authorization?

Yes, when filed within the permitted modification period.

Which form is normally used for modification?

EX-26.

Can EX-31 itself be extended?

Exceptionally, yes, where modification is not possible and the statutory extension requirements are satisfied.

How long is the job-search or integration extension?

One year.

What do I need for that extension?

Either active job search plus registration with the public employment service or a favorable integration-effort report recommending extension.

Can EX-31 be extended for four years?

Yes, in specified circumstances preventing access to employment, including qualifying serious illness, disability or reaching legal retirement age.

Does the four-year extension require active job search?

No, where the specific serious-circumstances requirements are met.

What Should an EX-31 Applicant Do Now?

Because the initial filing period has closed, the correct action depends on your current stage.

You never filed EX-31 before 30 June 2026

→ EX-31 is no longer available as a new initial application. Check ordinary current immigration routes such as arraigo instead.

You filed EX-31 and are waiting

→ Monitor the expediente, provisional work authorization, notifications and three-month processing period.

You received EX-31 approval

→ Complete any required asylum withdrawal, request the TIE within one month and note the one-year expiry date.

Your one-year EX-31 permit is approaching expiry

→ Examine an Article 191 modification through our EX-26 Modification guide.

You cannot qualify for a normal modification

→ Check whether the one-year or four-year EX-31 extension rules apply.

Your EX-31 case includes children

→ Review our EX-25 Foreign Minors guide.

The wider route can therefore look like:

International-protection history before 1 January 2026 → EX-31 filed by 30 June 2026 → Provisional residence/work → Approval → TIE → One year of residence → EX-26 modification or qualifying EX-31 extension

For Spain’s normal current arraigo routes, read our EX-10 Arraigo guide.

For the physical residence card, see our EX-17 TIE Form guide.

You can compare all Spanish immigration forms in our Spain Immigration Forms guide.

For assistance reviewing a pending EX-31 case, preparing the TIE or planning the next residence authorization before the one-year permit expires, contact Newcomer.es.