Do you need to file for administrative silence on a Spain digital nomad visa after 20 working days?

A filing, not a fix

His approval arrived. Hers did not. Call them the Novaks. It isn't their name. They applied together for Spain's digital nomad visa, him as the main applicant and his wife on the same application. After 20 working days his resolution came through. Hers was still missing. So he asked the group: is the deadline counted for the two of them together, or for each person separately?

His question landed under a long post by an immigration consultant. The rule, as the consultant set it out: under Spain's Startup Law, these applications are to be resolved in 20 working days, or they are "granted by administrative silence" (treated as approved because the office did not answer in time). "There is NO legal requirement to request this," the post said. "The moment Day 20 passes, you are legally approved."

Then a line for anyone paying a firm. A PAS request is a formal letter asking the office to confirm approval by silence. On why their firm files them: "We do file PAS requests for our clients most of the time, but we only do it because our clients expect it, mostly because of the panic generated in this group."

Three of the firm's own cases, filed in March with no request sent, were approved after 32 or 33 working days. Asked whether a request would help if the office asks for documents after day 20, the consultant answered: "no difference whatsoever, the immigration authorities do what they want." The remedy then is the courts, "which takes years".

On the Novaks' question, the group's experience pointed one way. Files from the same family are often resolved at different times, days or weeks apart, even when submitted together, and each person's 20-working-day window counts on its own. The exception the consultant named was the forgotten file: a main applicant and three dependents, all but one approved within 15 working days, one still floating weeks later. "In a specific case like that, we would absolutely chase it up."

We do not know when the second approval arrived.

The trap in a short phrase: a filing, not a fix. A request for approval by silence is a document the office receives. In the consultant's words, "it means nothing legally." Where a firm files one, it buys reassurance, not a faster answer.

This is one consultant's reading and one group's experience, not legal advice. How the office handles its deadlines can vary, and the official source is where to confirm it before acting.

For anyone holding a quote, the line worth reading is the one about waiting. Some quotes list steps: filing, follow-up, requests to the office. A step on a quote is not always a step that changes the outcome. The consultant's one example where chasing matters was narrow: a single family member left behind.

Paying for a step and paying for a result are different purchases.

For Spain's digital nomad visa, we have fees from 9 firms on file. The typical fee is about €1,000. The middle half sit between €950 and €4,000. Some cover the application only, some the full package.

While you waited on a visa, did a firm charge you to chase it? What did it change?

Based on a real case, shared publicly in an online group and anonymised. Fees on file as of November 2026.