Spain: Digital Signatures to be Required for Initial Applications Submitted to Large Companies Unit

• Digitized signature. When using the company’s digital certificate to submit an initial application form to the Large Companies Unit, the employer must indicate the name of the company’s legal representative and the employer identification number.
• Wet signatures disallowed. Once this change in process has been published, which is expected before March 31, 2023, wet signatures will likely no longer be accepted on these application forms.
• Third-party signatures. Employers holding digital certificates may appoint a third party, such as a law firm, to digitally sign the applications. In order to do so, the employer must delegate this appointment through the online platform, “APODERA”. The appointment will be granted for up to five years and can be withdrawn at any time.

• Companies not currently holding digital certificates. Companies who do not currently hold digital certificates should obtain one as soon as possible in advance of the switch to digital signatures by coordinating with their immigration professional. Otherwise, they will not be able to submit new applications for work and residence permits to the Large Companies Unit. Employers should contact their immigration professional for additional support.

• Streamlined process. This change towards digital signatures will streamline the application process by reducing the documentation required to file applications.

• Digitization. Spain has been moving toward digitizing its immigration processes in line with processes in other EU countries in recent years.
• Large Companies Unit. The Large Companies Unit is responsible for adjudicating work and residence permits regulated under the Entrepreneurs Act, including investors, entrepreneurs, highly-qualified professionals, intra-corporate transfers, researchers and international teleworkers (i.e. remote workers).

Further digitization of immigration processes can be expected in Spain in the near future.