Golden visa renewals after the repeal: how holders keep their residence in 2026
Spain closed its golden visa on 3 April 2025. The organic law that did it — a justice-efficiency statute with a final provision tucked in at the end — emptied the five articles of the 2013 entrepreneurs law that had created the investor visa, and no new application has been possible since. What it did not do is take anything away from the people who already held one. Many owners in Costa Adeje, Corralejo and across the islands bought their home with the visa in mind; for them the question is no longer how to get it but how to keep it, and what it is actually worth now that the door behind them has shut.
We touched on the repeal in our overview of NIE, residency and the routes that still exist. This piece is for holders: what the transitional rules protect, what a renewal file must prove, the timing, the family, and the two traps — absences and the passage to permanent residence — that catch investors who assumed the card was the finish line.
What the repeal did, and what it left standing
The Spanish "golden visa" was never one document. The 2013 law created two titles: a residence visa for investors, issued by the consulate for one year, and a residence authorisation for investors, granted in Spain by the Directorate-General for Migration through its large-companies unit. Since a reform at the end of 2022 the initial authorisation ran for three years (two before that), and each renewal for five years "as long as the conditions that generated the right are maintained". The investment routes were four: property of at least €500,000 per applicant, €1 million in shares, funds or bank deposits, €2 million in public debt, or a business project of general interest.
The 2025 organic law left those articles "without content" from 3 April 2025 and added two transitional provisions to the 2013 law. The first: anyone who had filed an application before that date may still receive the visa or authorisation under the rules in force when they applied. The second: visas and authorisations valid on 3 April 2025 keep their validity for the period they were issued, and "if renewal applications are filed, they will be processed and decided under the rules in force on the date the initial authorisation was granted."
Two things follow. There is no new golden visa, in any form, for anyone who did not apply in time — the Government's own portals say so in plain words. And nothing in the transitional rule limits the number of renewals: it freezes the old regime for existing holders for as long as the file still qualifies.
One footnote for readers who follow the European angle. In April 2025 the Court of Justice of the EU struck down Malta's citizenship-by-investment scheme as incompatible with Union law. Residence-by-investment is a different animal and that judgment does not touch a Spanish holder's permit — but it explains the political weather in which these programmes are closing across Europe.
Who can renew, and under which rules
Read the second transitional provision slowly, because its heading and its text do not say quite the same thing. The heading speaks of renewals "for investors by acquisition of real estate"; the text speaks of "visas and authorisations for investors", full stop. The processing unit has published its reading, and it is the generous one: every renewal application is admitted, whatever the investment route — property, shares, deposits, debt or a business project.
The date that matters is the date of your initial authorisation, because that fixes the rulebook. A holder whose first authorisation was granted in 2021 renews under the 2021 text (two-year initial period, five-year renewals); a holder granted in 2023 or 2024 renews under the three-year version. In both cases the renewal itself is for five years, and nothing in the transitional provision limits how many times it can be sought.
The ministry's management criteria for the repeal, issued on 10 June 2025, answer the questions the law left open:
- Holders of the one-year consular visa who had not yet applied for the residence authorisation on 3 April 2025 may still apply, provided the visa itself was requested before that date — even if its effect was deferred to a later one. The old law let a visa holder apply while the visa was in force or within ninety days after it expired; the application is examined under those rules.
- Renewals are admitted across the board, on one condition: the initial authorisation must have met every requirement for its grant. The unit re-reads the original file, so a defect at the start — a mortgage over the qualifying €500,000, say — can surface years later at renewal.
- A deposit contract was not enough. Buyers who on 3 April 2025 held only a signed arras agreement, not the purchase deed, are outside the regime: the criteria treat the pre-contract as renounceable by nature.
- A change of nationality does not cost the permit, provided it was notified in due time and form.
What is not a grey zone: a permit that has lapsed. Let the authorisation expire without filing, sell the property before renewing, or fail the file, and there is no second application to fall back on. Refusals under the old regime could be cured by reapplying; under the transitional regime a refusal is final in a way it never was before.
"Investment maintained": what the file must show
The renewal condition is the same sentence that governed the first authorisation: the conditions that generated the right must be maintained. For a property investor that means, concretely:
- Ownership proven by the Land Registry, with a certificate of title and charges dated within ninety days before filing. The registry, not the deed, is what the unit reads.
- At least €500,000 free of any charge. The old law allowed a mortgage only on the part of the investment above the threshold. An owner who has since refinanced and now carries a loan against the whole property may have quietly disqualified the file.
- The same investment, or a substitute that still fits the old article. The law allowed the investment to change during the authorised period provided one of the qualifying routes was still met, and it expressly disregarded changes of value due to market movements — a villa bought at €520,000 and now appraised lower is still a qualifying villa. Selling it and buying another of €500,000 or more keeps the ground under the permit; selling it and moving the money into a fund keeps it too, because the June 2025 criteria accept a switch from property to any other route, at the qualifying amounts. What they do not accept is the reverse: an investor who qualified through shares or deposits cannot now convert into property.
- The right is personal and the investment is not transferable. The same criteria refuse any transfer of the qualifying investment made after 3 April 2025 — by inheritance, by gift, between spouses or into a company — as a basis for the permit. An heir who receives the villa does not receive the residence with it, and moving the property into a company ends the ground under the permit.
- Tax and Social Security compliance. The old article listed it among the requirements, and it is where island files most often stumble: an owner who has never filed the non-resident return on the imputed income of the home, or who sits on unpaid IBI, may be asked to regularise before the unit signs. Our guides to wealth tax for non-residents and selling as a non-resident describe the taxes that travel with the property.
- The general requirements again: no criminal record in Spain or in the countries of residence of the last two years, health insurance with an insurer authorised in Spain, sufficient means for the family, and the fee.
The unit may also ask for whatever report it needs to satisfy itself that the conditions hold, and the law lets it refuse or not renew where the holder is considered a threat to public order or security on a police or intelligence report.
Timing, procedure and the family
Renewals are filed electronically with the same unit and decided by the Directorate-General for Migration. The law gives it twenty days to decide, after which silence counts as approval, and it provides the cushion for a slower file: filing the application extends your existing residence until the decision. The customary window is the sixty days before expiry, and a late filing within ninety days after expiry is still processed, at the price of a possible fine. Once renewed, the residence card is applied for at the police as for any permit.
Family members renew with the holder. The old law admitted the spouse or unmarried partner, children under eighteen or adult children who depend on the holder and have not formed their own family unit, and dependent parents. The June 2025 criteria draw the line at the repeal date: a family member whose residence was in force after 3 April 2025 keeps it and renews alongside the investor, proving that the tie and the dependence persist; a family application filed after that date — including for a marriage or a birth that came later — is not admitted under the investor route and goes through the ordinary family-reunification rules of the 2024 immigration regulation. A child who has since married or started working on their own account may need a permit of their own.
Absences, permanent residence and the passport
Here is the part most holders were never told when they bought. The 2013 law contains a special provision: a residence for investors may be renewed even with absences of more than six months a year. That is the golden visa's real privilege — a residence permit that does not require you to reside — and the transitional rule carries it into the renewals.
But the same provision opens with a warning: it is "without prejudice to the need to prove continuity of residence" for long-term residence and for Spanish nationality. Long-term residence — the permanent status after five years — requires five years of legal and continuous residence, and the immigration regulation defines continuity: absences of no more than six months in a row and no more than ten months in total across the five years (eighteen for work reasons). An investor who spends the winters in Fuerteventura and the rest of the year at home cannot reach it, however many five-year renewals stack up. Nationality is stricter still: ten years of legal, continuous residence immediately before the application — two for nationals of Latin American countries, Portugal, Andorra, the Philippines, Equatorial Guinea and Sephardic Jews — and in practice the Civil Registry and the courts look for effective residence, not for a card in a drawer.
The mirror image is the tax trap. A holder who does move to the islands for good will spend more than 183 days a year in Spain and become tax resident — worldwide income under the income tax, worldwide net wealth under the wealth tax instead of Spanish assets only. The golden visa never asked where you paid your taxes; the tax office does — our tax team plans that move before the days are counted, not after.
If the permit lapses, or you never had one
Without a valid investor permit a non-EU owner is back to the 90/180 rule for visits — read how it works now that entry-exit checks are fully live. For residence there remain the ordinary routes: the non-lucrative visa for those living on their own means, the digital-nomad permit for remote workers, the highly qualified and entrepreneur permits of the same 2013 law, and, for those already here, the residence-through-roots routes of the new regulation. Each has requirements the golden visa never had — income floors, health cover, effective residence — and each is a different file. None of them is bought with a property.
A holder's checklist
- Find the date of your initial authorisation: it fixes the rulebook for every renewal to come.
- Diary the expiry and file in the sixty days before it; never let the card lapse.
- Order a fresh registry certificate within ninety days of filing, and check that at least €500,000 of the property carries no charge.
- Do not sell before you renew — and if you must, replace the investment within the qualifying routes before the file goes in.
- Bring the non-resident taxes up to date: imputed-income returns, IBI, wealth tax if it applies.
- Renew the family in the same act, with the ties and the dependence documented — and route a spouse or child who joined after 3 April 2025 through family reunification instead.
- Decide what you want the permit for. If the goal is permanent residence or a Spanish passport, plan the days in Spain now; if the goal is to keep a winter home with the right to stay, the renewals alone will do it.
The golden visa was closed to newcomers, not to holders — but a holder's permit now lives on one file at a time, and there is no second application behind it.
We renew investor residences and their family permits for owners across Tenerife and Fuerteventura — the registry certificate, the tax position, the family file — and we tell you plainly when a sale or a move abroad would cost you the permit. Read how we work in immigration and residency, or tell us your dates at our Costa Adeje or Corralejo offices.
Common questions
Can I still renew my golden visa after the repeal?
Yes. Visas and authorisations valid on 3 April 2025 keep their validity, and renewals are processed under the rules in force when the initial authorisation was granted — five-year renewals, as long as the investment and the other conditions are maintained. The ministry accepts renewals for every investment route, not only property.
Can I sell the property and keep the permit?
Only if the investment is replaced within the routes the old law recognised — another property of at least €500,000, or a switch to shares, funds, deposits or public debt for the qualifying amounts. A switch from a financial investment into property is not accepted. Selling without replacing ends the ground for renewal, and there is no new application.
Do I have to live in Spain to renew?
No. The 2013 law lets an investor's residence be renewed even with absences of more than six months a year. Living abroad only becomes a problem for long-term residence and nationality, which require continuous residence in Spain.
Can I get permanent residence or nationality with a golden visa?
Only by actually living here. Long-term residence needs five years of legal residence with absences of no more than six months at a time and ten months in total; nationality needs ten years of legal, continuous residence, or two for nationals of Latin American countries and a few others. The permit counts as legal residence, but the days must be real.
What happens to my family's permits at renewal?
Spouse or partner, dependent children and dependent parents whose residence was in force after 3 April 2025 renew alongside the investor, proving that the family tie and the dependence persist. A family member who joined later — by a marriage or a birth after that date — cannot use the investor route and goes through ordinary family reunification.
This article is general information about Spanish immigration law as it stands at the date of publication, not legal advice for your specific situation. The transitional regime is applied file by file and the processing unit's criteria evolve — have your renewal reviewed with your own dates and documents before it is filed.
This note is general information, not legal advice. For advice on your specific situation, consult a lawyer.
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