Since Spain brought the Golden Visa scheme for new investors to an end, one of the questions we receive most often is what happens to people who already hold an investor residence permit and now need to renew it.
The good news is that the end of the Golden Visa does not mean that all existing permits have automatically become invalid or that they can no longer be renewed.
However, renewals now require much more careful preparation.
The Large Companies and Strategic Groups Unit (UGE) has introduced new administrative criteria for investor permits, and some of these criteria are causing significant problems in cases that were previously much more straightforward.
Deposit agreements, changes of property, changes in the type of investment, new family circumstances, or even documentary issues can now make a renewal much more complicated.
There is also another factor that makes it especially important to prepare the application correctly: if you lose your Golden Visa now, you can no longer submit a new Golden Visa application from scratch under the old scheme.
That is why, if your permit is approaching its expiry date, it is advisable to review your situation before filing the renewal.
Can the Golden Visa still be renewed after the scheme ended?
Yes.
The Golden Visa stopped being available for new applications from 3 April 2025, following the reform of Law 14/2013.
However, the legislation introduced transitional rules to protect certain existing situations.
Investor residence permits that were still valid when the reform entered into force remain valid for the period for which they were originally granted.
When a renewal is due, the application must generally be processed and decided in accordance with the legislation that was in force on the date the original permit was granted.
Therefore, if you already hold a Golden Visa, the abolition of this residence route does not automatically mean that you have lost the right to renew it.
The real issue is different: you must continue to meet the conditions required for renewal and take into account the new criteria currently being applied by the authorities.
What requirements must be maintained to renew a Golden Visa?
A Golden Visa renewal is not granted simply because the applicant previously held investor residence status.
The legislation governing these permits required applicants to continue meeting the conditions that originally gave rise to the right of residence.
This means reviewing both the general requirements and the specific requirements linked to the investment.
Depending on the case, it may be necessary to check:
- that the qualifying investment still exists;
- that the investment can be properly documented;
- that the general residence requirements continue to be met;
- that the applicant is up to date with tax and Social Security obligations;
- that the necessary documents are valid and ready;
- and that no changes have taken place that could affect the original basis of the Golden Visa.
Some of these changes are precisely what is causing the greatest difficulties in renewals at the moment.
My Golden Visa was granted on the basis of a deposit agreement. Can I renew it?
This is probably one of the most sensitive situations we are currently seeing.
The short answer is that renewal may still be possible, but the application is likely to encounter difficulties at the administrative stage.
The current administrative position on deposit agreements
Before the Golden Visa scheme ended, some investors obtained their initial permit before the property purchase had been fully completed, on the basis of a deposit or reservation agreement that met the requirements applicable at the time.
Following the abolition of the investor residence scheme, the UGE published a specific criterion under which deposit agreements are no longer considered sufficient to prove the investment, among other reasons because they do not in themselves constitute the final property purchase agreement.
This is leading to refusals in renewal applications where the initial Golden Visa was granted on the basis of a deposit agreement.
However, there is an important distinction.
What if you later completed the property purchase?
Obtaining the original Golden Visa on the basis of a deposit agreement is not the same as never completing the transaction.
If, after the initial permit was granted, the purchase was completed and the investor became the legal owner of the property, the legal position is different.
At Sterna Abogados, we have challenged refusals of this type before the courts and obtained favourable outcomes in cases where the purchase had subsequently been completed and ownership could be proven through the corresponding Land Registry certificate of ownership and charges.
Therefore, receiving an administrative refusal for this reason does not necessarily mean that the renewal is lost.
It will be necessary to assess:
- how the original permit was granted;
- when the property purchase was completed;
- whether the property is still owned;
- what Land Registry documentation is available;
- and the precise legal reasoning used by the authorities to refuse the renewal.
What if you never completed the purchase?
The situation is considerably more difficult if the original Golden Visa was granted on the basis of a deposit agreement but the property purchase was never completed.
In that situation, there is not the same basis for proving that the qualifying property investment was ultimately made and maintained.
That is why the individual case should be reviewed before the renewal application is submitted.
In which cases can a Golden Visa renewal be refused?
Although every case must be assessed individually, there are several situations that currently present a particularly high level of risk.
1. Failing to maintain the investment used to obtain the Golden Visa
One of the basic principles of renewal is that the conditions that gave rise to the original permit must continue to exist.
If the Golden Visa was granted because of a specific investment and that investment no longer exists, the authorities may consider that the requirements for renewal are no longer met.
It is therefore not enough to have been an investor in the past.
It is necessary to identify exactly which investment supported the original application and what its current status is at the time of renewal.
2. Selling the original Golden Visa property and buying another one
This situation requires particular caution.
It may seem logical to assume that if someone sells the property used to obtain the Golden Visa and then buys another property of the same or even greater value, they remain an investor and should still be able to renew.
However, you should not carry out this transaction assuming that the new property will automatically replace the original investment for immigration purposes.
The criteria applied after the abolition of the scheme are much more restrictive in relation to changes and transfers made after the relevant cut-off date.
If you are considering selling the property linked to your Golden Visa, our recommendation is clear:
review the immigration consequences first and complete the transaction afterwards.
A property transaction may make financial sense while at the same time creating an immigration problem that had not been anticipated.
3. Changing the type of investment
The same risk can arise when the investor does not simply change the asset, but changes the investment category altogether.
For example, imagine that the Golden Visa was originally granted on the basis of a financial investment and the investor later decides to withdraw that capital and use it to buy property in Spain.
It should not be assumed that the two forms of investment are automatically interchangeable for renewal purposes.
The authorities may assess which specific investment gave rise to the original permit and whether that investment is still being maintained.
For this reason, before changing bank deposits, shares, funds or other assets linked to a Golden Visa, it is advisable to assess the immigration consequences of the transaction.
4. Having a child after the end of the Golden Visa scheme
This situation requires an important clarification.
The birth of a child after 3 April 2025 does not mean that the main Golden Visa holder automatically loses their permit or that their renewal will automatically be refused.
The issue concerns the possibility of adding the new family member under the former investor family residence route.
The UGE criteria provide that new family circumstances arising after 3 April 2025, including births, must be dealt with under the relevant routes available under the general immigration regime.
Therefore, if you have had a child since the Golden Visa scheme ended, it will be necessary to assess which residence permit is currently appropriate for the child.
5. Marriage or a new relationship after 3 April 2025
A similar issue arises when the marriage or family relationship was established after the Golden Visa route was abolished.
Family members who already held a residence permit can continue to retain their status while the permit remains valid and the relevant requirements continue to be met.
However, a new spouse or a new family relationship created after 3 April 2025 cannot simply be added using the former investor family residence procedure.
It will be necessary to assess the appropriate alternative under the general immigration regime.
6. Outstanding debts with the Tax Agency or Social Security
Another common mistake is to focus exclusively on the investment and overlook the remaining renewal requirements.
The Golden Visa framework also requires compliance with the relevant tax and Social Security obligations.
Before submitting a renewal application, it is therefore advisable to check whether any outstanding debts exist.
In practice, issues can arise from amounts that the applicant may not even have been aware of, such as an outstanding tax assessment or another unpaid administrative obligation.
Although each situation must be assessed individually, it is far better to identify these problems before the renewal application is already being processed.
A prior review may allow the issue to be corrected before the application is submitted.
7. Failing to prepare criminal record certificates in time
Another issue we see in practice concerns criminal record certificates.
Depending on the applicant’s personal circumstances and residence history, the authorities may require additional criminal record documentation from countries where the applicant has lived.
The problem is not simply obtaining the certificate.
In many cases it may also be necessary to:
- request the certificate from the relevant country;
- legalise or apostille it;
- obtain the original document;
- and arrange a sworn translation where required.
All of this takes time.
If the authorities issue a formal request for additional documentation, the general period for remedying the application is 10 days, although Spanish administrative law provides for certain circumstances in which an extension may be granted.
Waiting until that point to start requesting a certificate from another country can unnecessarily put the application at risk.
If you have spent significant periods outside Spain, it is therefore advisable to review this issue before submitting the renewal.
Can I change my investment and still renew my Golden Visa?
This is one of the questions that now requires the most caution.
The former legislation allowed certain changes to investments provided that the relevant legal requirements continued to be met.
However, since the Golden Visa scheme was abolished, the authorities have adopted restrictive criteria regarding certain changes, transfers and transactions carried out after 3 April 2025.
For example, the UGE has expressly stated that certain transfers carried out after that date cannot be used to prove the qualifying investment, including certain inheritances, gifts and transfers between living persons.
This means that it is now particularly risky to make a financial or property decision while considering only its economic consequences.
If an investment is linked to your right to reside in Spain, you should first assess the immigration consequences and only then decide whether to make the change.
What should I do if my Golden Visa renewal is refused?
Receiving an unfavourable decision does not necessarily mean that the process is over.
The first step is to assess why the renewal was refused and whether the interpretation applied by the authorities can be challenged.
This is particularly relevant in cases involving deposit agreements.
At Sterna Abogados, we have represented clients whose renewal applications were refused because their original permits had been granted when only a deposit agreement was in place, even though the investor later completed the purchase and became the legal owner of the property.
In these cases, we have taken the matter to court and obtained favourable decisions for our clients.
This does not mean that every refusal can be successfully challenged or that every case is identical.
It does mean that a Golden Visa should not automatically be considered lost simply because the authorities have applied a particular interpretation at the initial administrative stage.
The original application, the investment, the current status of the asset and the reasoning contained in the refusal decision must all be reviewed carefully.
How to avoid problems when renewing your Golden Visa
The best approach is to review the renewal before submitting the application and, above all, before making any changes to the investment.
Several steps are particularly important:
- Review how the original Golden Visa was obtained. It is essential to identify exactly which investment and which documents supported the original approval.
- Check that the investment still meets the requirements. Do not assume that any replacement asset will be accepted.
- Do not sell or change the investment without first assessing the consequences. A transaction that is difficult to reverse may affect the next renewal.
- Check tax and Social Security obligations. It is preferable to identify and resolve any issue before the application is submitted.
- Prepare foreign documents in advance. This is particularly important where criminal record certificates, apostilles or sworn translations may be required.
- Review any family changes that occurred after 3 April 2025. The former investor family residence route is no longer open to new family circumstances arising after that date.
- Seek legal advice if a renewal has already been refused. The administrative decision is not necessarily the final word.
Why is it now especially important to prepare the renewal properly?
Before the Golden Visa scheme ended, there could be more room to consider different strategies.
The situation is now different.
Since 3 April 2025, new initial Golden Visa applications can no longer be submitted.
That means that a problem affecting an existing permit now has much greater consequences.
If the permit is ultimately lost, there is no longer the option of starting again and applying for a new Golden Visa under the former regime.
This makes the renewal stage particularly sensitive.
It is not simply a matter of submitting documents before the expiry date. The investor’s financial, family and documentary situation should be reviewed in advance to ensure that it remains compatible with renewal.
Frequently asked questions about Golden Visa renewals
Can a Golden Visa still be renewed in Spain?
Yes. Permits that remained valid when the scheme was abolished continue to be valid for the period for which they were granted, and their renewals may be processed under the rules that applied when the original authorisation was issued.
Can I renew if my Golden Visa was originally granted on the basis of a deposit agreement?
It may still be possible, but this is currently one of the most contentious situations.
The authorities are applying a restrictive interpretation to permits that were initially based on deposit agreements. However, where the purchase was later completed and ownership of the property can be proven, an eventual refusal may be open to legal challenge.
At Sterna Abogados, we have already obtained favourable court outcomes in cases with these characteristics.
Can I sell the property I used to obtain the Golden Visa?
We do not recommend selling the property without first assessing how the transaction may affect your residence status.
Selling the original property and subsequently buying another one may create problems for renewal under the criteria currently being applied by the authorities.
Do I have to maintain the investment to renew?
Yes. Maintaining the conditions that gave rise to the original residence permit is one of the fundamental elements of renewal.
Can I add a new spouse or a newborn child to my Golden Visa?
New family circumstances arising after 3 April 2025 can no longer be incorporated through the former investor family residence route. It will be necessary to assess which option under the general immigration regime is appropriate in each case.
What can I do if my renewal is refused?
A refusal should be reviewed on a case-by-case basis. Depending on the reason and the circumstances of the file, it may be possible to challenge the administrative decision and, where appropriate, take the case to court.
Do you need to renew your Golden Visa?
If you hold a Golden Visa and your renewal date is approaching, do not wait until the application is filed to find out whether there is a problem.
This is particularly important if:
- your original permit was granted on the basis of a deposit agreement;
- you have sold or are considering selling the property;
- you want to change your investment;
- you have changed the type of investment;
- your family circumstances have changed;
- you have spent long periods outside Spain;
- or your renewal has already been refused.
At Sterna Abogados, we can review your original permit, assess the current status of the investment and prepare the appropriate strategy for your renewal.
If the authorities have already refused your application, we can also assess whether there are legal grounds to challenge the decision and defend the continuation of your residence status.
Book a consultation with our immigration lawyers before a financial decision or documentary issue puts your Golden Visa at risk.