
Spain’s Official State Gazette (BOE) of 5 March 2026 published Order ISM/164/2026 establishing the new Electronic Register of Extranjería Collaborators. The register will allow authorised trade-union organisations and NGOs with at least three years’ legal presence in Spain to file residence- and work-permit applications electronically on behalf of foreign nationals. By broadening who can legally represent migrants before the administration, the government hopes to relieve the chronic backlogs that have dogged Spain’s Foreigners’ Offices since application volumes began surging in 2024. Under the new rules, entities that meet governance and data-protection standards can apply online to the Directorate-General for Migration Management. Once approved, their accredited personnel will be able to submit and monitor cases through Spain’s common e-administration platform, bypassing the requirement for the foreign national to appear in person. The Ministry of Inclusion, Social Security and Migration argues that the measure is fully aligned with the 2024 overhaul of Spain’s Immigration Regulation (RD 1155/2024) and with Law 39/2015 on electronic administration. For companies moving staff to Spain, the register should translate into faster appointment availability and fewer proxy-authorisation hurdles—particularly valuable as the country gears up for the extraordinary regularisation programme due to open in April. NGOs that specialise in humanitarian or refugee cases will likewise gain a streamlined channel to lodge applications for vulnerable groups. Importantly, individual representation rights remain untouched, so assignees may still file on their own or through lawyers. Practically, mobility managers should update their power-of-attorney templates and verify whether their preferred relocation providers are planning to obtain collaborator status. The order took effect on 6 March 2026, the day after publication, and the ministry will launch the online application form later this month. Penalties for unauthorised electronic filing range from warnings to removal from the register and administrative fines. In the medium term, officials expect the register to cut average processing times for initial residence permits from today’s 71 days to below the statutory 45-day target, easing one of the biggest friction points for inbound assignments.
Source: Boletín Oficial del Estado
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