A Major Shift in DNV Strategy: Why We Now Recommend Applying from Spain - LAKBYTE

For years, a common question from our clients, particularly those from the Philippines, has been: “Should I apply for my Spain digital nomad visa from my home country or from Spain?”

Before 2025, our answer was always nuanced: “It depends on your circumstances.”

Today, that advice has changed. Based on our recent and challenging experiences with the Spanish consulate in Manila, and despite guiding over 100 successful applicants from the same consulate, our recommendation is now clear and urgent: it is significantly better to apply for your visa from within Spain.

The New Recommended Strategy: The Schengen Visa Route

The most effective method we now recommend involves the main applicant flying to Spain on a Schengen visa to lodge the application directly. This approach has several key advantages:

• Only the main applicant needs to travel. Dependents can remain in the Philippines, saving significant cost and disruption. We talk about this here.
• It’s incredibly fast. The application can be lodged on the first day of a trip as short as 3 to 5 days and the decision is out in a maximum of twenty (20) working days. It is still recommended that you try and obtain a minimum 30-day Schengen visa.

This strategy allows you to bypass the increasingly difficult and unpredictable consular process, which has become a major source of frustration and risk for applicants.

Why We No Longer Recommend Applying from the Consulate

Our shift in advice isn’t arbitrary. It’s a direct response to a pattern of recurring issues at the consulate that create unnecessary delays, stress, and even outright denials. Here’s what we’ve been facing:

1. Constantly Changing and Unpredictable Requirements

The consulate has demonstrated a pattern of changing application requirements at the last minute. A procedure that has been standard for months can suddenly be rejected without warning.

• Application Form Formatting: In September 2024, we saw sudden changes to how forms needed to be filled out, photocopied, signed, and dated. These minor, unannounced changes forced clients to go back and resubmit documents, sometimes more than once, eroding trust and causing delays.
• Extreme NIE Delays: In early 2023, obtaining a NIE (Número de Identificación de Extranjero) took about two (2) weeks. By mid-2024, that timeline has ballooned to three (3) months or more, and that’s only after the documents are finally submitted, not including the initial wait time to get an appointment (which can also sometimes also range from 1 to 3 months). There was a short period recently between April and May of 2025 where the release came as fast as 1-2 weeks, but after then, it’s back to hearing silence for weeks when we try and request any appointment, even if it’s by an email that they have dealt with many times before. 
• Sudden Closure of Application Pathways: A perfect illustration of this volatility occurred in the last year. Until late November 2024, a loophole allowed employees of Philippine companies to apply. This was a viable path for many. Then, in December, not only was this loophole abruptly closed, but a new, stricter requirement was suddenly enforced: applicants must now provide official government documents to prove their work experience. While this new rule is technically aligned with regulations, its sudden enforcement without a grace period is exactly the kind of unpredictable change that can derail a well-prepared application.

2. Requests for Documents Not Required by Law

This is one of the most concerning trends. The consulate has started asking for documents that are not legally required for the visa.

• The “Justificación de RETA”: Recently, the consulate began demanding a Justificación de RETA to prove you’ve registered as self-employed (autónomo). This is not a requirement under Spanish law. In fact, it’s a catch-22: you cannot fully register as autónomo until you have a right to work, which you only get after visa approval. We found a temporary workaround, but this loophole has since been closed as of June 2025. We are now forced to plan to submit letters from Spanish lawyers explaining that this demand is not legally founded.
• Excessive Financial Proof: The law clearly states that applicants need to provide three (3)  months of bank statements. However, the consulate has begun asking for one (1) year worth of financial records. To avoid potential rejection, we have proactively started asking our own clients for one year of statements to preempt this overreaching request.
• Requests for Tax Documents Beyond Legal Requirements: The consulate has also begun demanding a BIR Certificate of Registration (Form 2303) and Income Tax Returns from virtually all applicants. This is a significant overreach and directly contradicts official guidelines. The UGE in Spain, the very unit that sets the standards, only requests these documents in one specific situation: for applicants proving their qualifications through years of professional experience instead of a university degree. The consulate, however, has turned this narrow exception into a blanket requirement for all applicants, creating an unnecessary hurdle for everyone else.

3. Unexplained Denials and Lack of Due Process

Perhaps most frustratingly, we are seeing a rise in outright application denials, even for perfectly complete and qualifying files. The most striking proof of this disconnect is what happens next: when these clients re-apply directly in Spain after a denial, the UGE approves their applications without issue. This proves the initial applications were valid all along, creating a lottery-like system at the consulate. It’s a risk that applicants should not have to face.

Under Spanish law, if an application has a correctable error or a missing document, the administration should notify the applicant and give them time to provide it. The UGE in Madrid consistently follows this rule. The consulate, however, does not.

Instead, we’ve seen:

• Outright Denials: Complete applications are being denied without a request for additional information.
• Confusing Rejections: Clients who clearly meet the income and qualification requirements are being denied for reasons that lack a clear basis in the stated regulations.
• “Phantom” Document Requests: In some cases, after months of waiting, the consulate will claim they sent a request for additional documents that neither we nor our clients ever received. We then receive a backdated letter and are left scrambling to comply with an impossible deadline.

Our Final Recommendation

Navigating bureaucracy can be slow, but the consular process has become unacceptably unpredictable and fraught with risk.

For these reasons, our professional advice has shifted.

Unless you are not in a rush, have an impeccable income tax return, and are willing to endure a slow and unpredictable bureaucratic process, we strongly suggest you avoid a consular application.

Instead, the most secure and efficient path to your Spanish visa is for the main applicant to travel to Spain on a Schengen visa and apply directly from here. It’s a small logistical step that can save you months of uncertainty and protect your application from the arbitrary challenges of the current consular climate.

We have already provided all our current clients with their strategic options for their Philippine applications.

• If you are a current client, please use the private link sent to your email to book your call for clarifications if you haven’t already done so.
• If you are not yet a client, and you are considering the DNV, we urge you to start with the correct strategy. You can book a consultation with us here to discuss your specific path forward here.