Spain complies with the Single Permit Directive

We wanted to flag a piece of EU news with direct relevance for anyone considering relocating to Spain to live and work, particularly our British members, who since Brexit are treated as third-country nationals under EU immigration law, the same category as other non-EU nationals.

On 16 July 2026, the European Commission confirmed that Spain has fully complied with the EU’s Single Permit Directive (EU 2024/1233). Seventeen other Member States missed the deadline and received formal warning letters. Spain was one of only eight countries, out of the 25 the directive applies to, that got it right on time.

What the directive does

It replaces separate residence and work permit applications with a single combined procedure, so non-EU nationals, including British citizens, apply once rather than twice. Once an application is complete, the receiving country now has a maximum of 90 days to issue a decision, a firm deadline that didn’t exist before. Applicants can apply either from abroad or, if they already hold a valid residence permit, from within Spain itself.

Crucially, the directive gives permit holders the right to change employer without losing their right to reside. Under the old system, permits were often effectively tied to a single job, so leaving or losing that job could put your legal status at risk. That is no longer the case. The directive also requires mandatory monitoring and inspections of employers, accessible complaint mechanisms, legal redress, and equal treatment rights that extend into everyday life, including access to private rental housing.

How Spain has actually implemented this

Spain transposed the directive through Real Decreto 1155/2024, of 19 November, which approved the new Reglamento de Extranjería (the regulation implementing Spain’s Foreign Nationals Law). It came into force on 20 May 2025, ahead of the EU deadline.

The right to change employer is not just a general principle, it is written into the regulation as a specific, numbered rule. Article 79 of Real Decreto 1155/2024 sets out that a permit holder can change employer once three months have passed since their authorisation took effect, and within the first year of holding it. The new employer must show they have the financial and operational capacity to fulfil the job contract, and the immigration office then has a maximum of three months to decide on the request.

Important note: this is not retroactive. If you already hold a permit granted under the old regulation (before 20 May 2025) and that application was fully resolved before that date, Article 79 does not apply to it automatically, the old rules continue to govern that permit until renewal or a fresh application. If you had an application still pending on 20 May 2025, you may be able to request that the new regulation be applied to your case instead, but this has to be actively requested and you must show you meet the new requirements, it does not happen automatically. Anyone applying for a permit now is covered by Article 79 from the outset.

Why this matters for British members specifically

Since the UK left the EU, British nationals no longer have automatic rights to live and work in Spain and fall under the same rules as any other non-EU applicant. That makes the reliability of the process, not just the rules on paper, genuinely important. Spain’s government has said its existing migrant worker protections were already close to the new EU standard, so only minor legal adjustments were needed, and the fact that the employer-change right is already sitting in force as Article 79, rather than still pending, is a good sign of that. In practice, British and other non-EU applicants going through Spain should expect a functioning, predictable single permit system, including this employer-change protection, rather than the delays or legal uncertainty still possible in the 17 countries that missed the transposition deadline.

If you are a British or other non-EU member weighing a move to Spain for work, this is a reassuring signal: the legal machinery you’ll rely on is already in place and operating to the new EU standard.

We’ll continue to monitor developments and update you as needed.

Please note: The information provided is based upon our understanding of current legislation. It is not legal advice but is provided freely to enable you to be properly informed. We recommend that if you are considering taking action, you should seek professional advice.