Highly Qualified Professional (PAC) Visa in Spain: Delays & Positive Silence
Why the 20-business-day processing deadline has stalled in 2026 and how immigration attorneys invoke positive administrative silence.
A Spanish company or multinational firm hired you as a manager or specialized technical lead. Your file for the Highly Qualified Professional (PAC) authorization was submitted to Spain's Large Business Unit (UGE) under the statutory twenty-business-day promise. Two months have passed, and the portal still displays 'Under review'.
The residency authorization for highly qualified professionals under Law 14/2013 is renowned as one of Europe's swiftest corporate immigration paths. However, an unprecedented volume of applications has introduced operational bottlenecks that leave hiring companies and professionals in legal limbo.
Why the 20-business-day window is delayed in practice
Law 14/2013 explicitly sets twenty business days as the statutory window for the UGE to resolve intra-company transfer, digital nomad, and PAC filings. In practice, surge volume has stretched standard reviewing timeframes.
Crucially, any official request for additional evidence (requerimiento) suspends the statutory calendar until requested company or payroll records are uploaded.
The statutory power of Positive Administrative Silence
Unlike standard Spanish immigration procedures where silence often equates to rejection, Law 14/2013 establishes that if twenty working days pass with no formal decision or notification, the application is deemed approved by positive administrative silence.
By law, your residence authorization is granted. However, police fingerprint offices cannot issue your physical TIE card without a formal certificate validating that positive silence occurred.
How to file for formal administrative silence certification
To enforce approval, your certified immigration attorney or employer must submit an expedited petition to the State Secretariat for Migration requesting an official certification under Article 24 of Law 39/2015.
With this official certification in hand, the National Police proceeds directly with biometric fingerprinting and issues the three-year TIE card without resistance.
- Statutory processing timeframe20 business days counting from the day following electronic filing.
- Suspension by formal evidence requestAny formal inquiry pauses statutory counting until records are submitted.
- Legal presumption of approvalSilence after the statutory window automatically operates in favor of the employee.
- Mandatory official certificateRequired by police commissariats to execute fingerprint collection for the TIE card.
Notice: LANDESP is an independent legal and relocation consultancy not affiliated with Spain's UGE or Ministry of Inclusion, Social Security, and Migration.
