From a Ley 14/2013 Permit (Nomad, Entrepreneur, Highly Qualified Professional) to a Work Permit
A Spanish employer makes an offer, your Spanish client share crosses the forbidden 20%, the foreign contract ends, the startup winds down or grows into something else, a highly qualified professional permit was issued for one employer and you are moving to another - life regularly outgrows the Ley 14/2013 statuses. The good news: after your first year of residence, article 191.3 of the current regulation gives you a favourable switch to a general regime work permit with a card valid 4 years at once, no labour market test and no exit from Spain. Family included. The bad news: the window is narrow - three months from the day the conditions of your old status stopped being met, plus a ban on switching to the same employer.
Contents
- When this switch is needed
- How article 191.3 works
- Requirements and documents
- The family route
- If you’re open to relocating to Asturias
When this switch is needed
The Ley 14/2013 statuses are built around a specific model of life, and when the model changes, the status starts to pinch. Typical scenarios from practice:
- A Spanish company offers you a job. The employed digital nomad status simply does not allow a Spanish employer, so an offer means changing the legal basis.
- A self-employed nomad’s share of Spanish clients approaches the 20% income threshold. A growing local business is good news for your life and bad news for this status.
- The foreign employer or a key client is gone. With no live relationship abroad, a nomad has nothing to show at renewal.
- The startup behind the entrepreneur permit has closed, pivoted, or the founder has exited and wants ordinary employment.
- A highly qualified professional (PAC) permit is tied to a specific employer and role - changing companies outside that fast-track also calls for a switch to the general regime.
- The family wants stability without an annual dependence on foreign contracts: a 4 year work card is sturdier than a status anchored in another jurisdiction.
The general rule on timing here has two halves, and both matter. Your Ley 14/2013 permit must still be valid when you file: an application from a live status and an attempt to rescue a basis that has already collapsed are different cases with different odds. But the event that breaks the conditions of your nomad, entrepreneur or highly qualified status must have already happened. Criterio de Gestión DGGM 1/2025 opens the route into the general regime only once changes have occurred that prevent the Ley 14/2013 permit from being maintained, and it allows three months from the date of those changes to file. The next section unpacks that window.
How article 191.3 works
The legal basis is article 191.3 of the Immigration Regulation (RD 1155/2024). It applies when two conditions are met: at least one year in Spain in residence status, and a previous permit that already authorised work. Ley 14/2013 permits do authorise work (employed and self-employed, by express provision of the law), so digital nomads, entrepreneurs and highly qualified professionals fall squarely into this favourable scenario.
The advantage lies in the level of proof: you demonstrate not the conditions of an initial work permit but those of its renewal (articles 80 or 86 of the regulation). The practical difference is enormous: the national employment situation does not apply, meaning the position need not appear in the shortage occupation catalogue and the employer need not prove the vacancy could not be filled locally. Any genuine job with correct terms passes.
The result: a residence and work permit valid for 4 years at once, with no restriction on activity, employer or territory, covering both employment and self-employment. No visa is required in any variant of this switch. Those 4 years plus the year already lived deliver the 5 years needed for long-term residency; years on Ley 14/2013 statuses count in full.
On how that term is counted, the management criterion itself is not entirely consistent. Its general part, on article 191 modifications at large, provides for retroactivity: if the previous permit has expired, the new one takes effect from the day after that expiry. But the special section of the same document, the one devoted to switches from Ley 14/2013, states the term differently - four years from the date of the decision. In practice this means you should not plan your long-term residency calendar on the assumption of retroactivity: the wording that applies to your case is worth confirming in the file itself.
Either the employer or the resident may file. The case is handled by the provincial immigration office (not the UGE-CE), and the change of authority means a change of habits: different timelines, different forms, and ordinary rather than fast-track administrative silence. The decision deadline is three months and administrative silence is negative. Once the procedure closes, the immigration office reports the outcome to the UGE-CE and the two coordinate to extinguish (extinción) the old Ley 14/2013 permit - not an instant automatic switch, and the family calendar hangs on that seam.
When the filing window actually opens. This is the condition people most often discover only after a refusal. Ley 14/2013 permits live under their own regime, and the general-regime modification rules apply to them only subsidiarily - and only once changes have occurred that prevent the permit obtained under that law from being maintained. That is the express wording of section 3 of Criterio de Gestión DGGM 1/2025.
Two practical consequences follow:
- While the conditions of your status are still met, there is no basis for a modification into the general regime. A live contract, a functioning foreign client, income within range - and the administration takes the view that you fit your status, so you stay in it.
- The window is three months from the date of the event that broke those conditions: contract termination, the loss of a key client, crossing the 20% Spanish income threshold, the closure or pivot of the startup, the end of an ICT assignment or of a researcher’s hosting agreement.
The practical conclusion to draw before filing: document the date of that event. The three months run from it, and it is precisely what the administration will look for in the file. This mirrors the rule for moving within Ley 14/2013, incidentally: there, a change of category is available at any time, but only while the requirements of the status keep being met. Conditions broken - the general regime opens; conditions intact - movement within the law is what works.
If you don't have a year of residence yet
One year of legal residence is the line between two entirely different scenarios, and the second one is often overlooked.
If at the time of filing you have held the Ley 14/2013 status for less than a year, the favourable level of proof does not apply: you must meet the requirements of article 74 of the regulation - that is, an initial work permit with all its checks. The permit is then issued for one year from the date of the decision and counts as initial, not as a four-year card. It stays suspended until the worker is registered with Seguridad Social, which must happen within one month of notification of the grant.
No visa is required here either, and either the employer or the applicant may file.
The gap between the two branches is three years of card validity and a completely different burden of proof. If you are weeks away from the one-year mark and the event has already occurred, the filing calendar deserves careful arithmetic: the three-month deadline and the one-year residence mark are two independent clocks, and they do not always line up.
That arithmetic is easier if you know how long the original permits run. Criterio de Gestión DGGM 2/2025 confirmed that Ley 14/2013 sets no general minimum term: entrepreneurs get a fixed 3 years; nomads, the term requested up to a maximum of 3 years; highly qualified professionals, the contract term plus 3 months where the contract runs under three years, capped at 3 years overall; researchers, the term of the hosting agreement with the same cap; ICT, the term of the assignment (3 years for managers and specialists, 1 year for trainees). A card issued for less than a year automatically means the one-year mark may not be reached by the time the event occurs - and then the branch above applies, not the favourable one.
One important caveat: the route only works with a currently valid status at the time of filing. If your Ley 14/2013 permit has already expired or been annulled, article 191.3 does not apply - the way back to legal status is usually arraigo social (it does not depend on why you lost status) or arraigo de segunda oportunidad (if no more than 2 years have passed since you lost status and the reason was not fraud or a public-order issue).
Since April 2026, though, arraigo carries a restriction that rules out the popular idea of “filing the modification and preparing an arraigo in parallel, just in case”. The amendment introduced by RD 316/2026, in force since 16 April 2026, wrote an express requirement into the arraigo rules: you may not hold another stay or residence permit, and you may not be an interested party in a procedure for granting, extending, renewing or modifying such a permit. So arraigo social is simply unavailable while you hold a valid nomad card, and unavailable while a modification of yours is pending. These two routes exclude each other; you have to pick one.
The tax angle: the Beckham regime and beyond
Many nomads and relocated professionals sit on the Beckham regime (article 93 LIRPF): a flat 24% on Spanish employment income and an exemption for most foreign income. Changing the immigration basis does not by itself expel you from the regime: it lives by its own conditions, not by the type of card.
But those conditions must keep being met. Moving to employment with a Spanish company is the regime’s classic configuration and usually compatible with it. Moving into ordinary self-employment is the standard way to lose it: self-employment outside the special categories (entrepreneurial activity under Ley 28/2022, highly qualified services) does not fit the regime. Changes in your work situation are also subject to notification to the tax authority in the prescribed manner.
The conclusion is simple: the immigration and tax decisions are one package. I review every such switch from both sides before filing: sometimes the right move is to change the configuration of the switch itself (employment instead of self-employment, for instance) rather than lose a regime worth thousands of euros a year.
The alternative: staying within Ley 14/2013
Moving to the general regime is not the only exit. If the new situation fits another Ley 14/2013 category, it is often simpler to change category within the law through the UGE-CE: a nomad with an offer from a large Spanish company may qualify as a highly qualified professional; a self-employed project with an innovative profile, as an entrepreneur. The upsides: fast-track processing with positive silence, a single family filing, and a familiar authority.
When the general regime wins anyway: the employer does not meet the highly qualified criteria (salary, position profile), the activity is ordinary rather than innovative, or you value maximum flexibility over the next 4 years without being locked into one employment configuration. Choosing the branch is a calculation in each case, not a universal rule.
An important timing difference: switching categories within Ley 14/2013 - confirmed separately in official UGE guidance (FAQ on international teleworkers, question 18) - is available en cualquier momento, at any time, not only after a year of residence like the article 191.3 route into the general regime. The only condition is meeting the new category’s requirements at the time of filing. Moving specifically into the general regime (outside Ley 14/2013) follows a separate rule - Título XI of RD 1155/2024 - where the one-year residence requirement still applies.
That same guidance carries a detail which, combined with the management criterion, completes the picture neatly: the “any time” category change is open while the requirements of your original status keep being met. The result is a mirrored pair. Status conditions intact - the fast route within Ley 14/2013 through the UGE-CE. Status conditions broken - movement within the law closes and the route into the general regime through the provincial immigration office opens. Which branch you take is therefore driven largely by what has happened and when, not by preference.
Common mistakes
Filing while nothing has broken yet. The most common mistake, and it runs both ways. Criterio DGGM 1/2025 opens the route into the general regime only after a change has occurred that prevents the status from being maintained. A “just in case” application, filed while the contract is alive and the 20% threshold intact, has no basis under it. The opposite mistake costs just as much: waiting until the Ley 14/2013 permit expires or is annulled closes the route entirely. The correct point is a narrow one - the event has happened, the status is still valid.
Not documenting the date of the event. The filing window is three months from the change that broke the conditions of your status. Contract termination, notice of a client leaving, a document evidencing that Spanish income crossed 20%, the decision to wind down the startup - this is not paperwork for its own sake, it is the start of a clock the administration will check.
Negotiating the switch with the same employer or inside its group. An express prohibition in Criterio DGGM 1/2025, extended to subcontractors, service providers to the group and temporary work agencies. It produces an inadmisión rather than a refusal on the merits, which means the time is lost entirely.
Preparing an arraigo in parallel with the modification. Since the RD 316/2026 amendment you cannot apply for arraigo while holding another permit or while being an interested party in a procedure to modify one. The two routes exclude each other; pick one.
Switching the main holder and forgetting the family. Family cards under Ley 14/2013 do not survive without the main status; the filing calendar covers the whole family.
Losing the Beckham regime by inattention. The configuration of the switch (employment or self-employment) is chosen with the tax side in view, not after it.
Bringing a part-time contract with an insufficient annual salary. Renewal-level requirements are lighter than initial ones, but the genuineness of the contract and the employer’s solvency are checked in earnest.
Drafting a new business plan out of habit. For the switch into self-employment under article 191.3, the regulation asks for proof of continuity of an existing activity, not a new project - if the activity is already real, what you already have is often enough.
Trying to file a family member with no Ley 14/2013 history in parallel with the main applicant. For them this is not the article 191.3 route, it is ordinary family reunification, and it only opens once the main applicant holds the card in hand, not before.
Waiting for the main applicant to hold the card even when a family member already has their own Ley 14/2013 history. For an already-dependent family member, a modification onto a new dependent card (EX-02) is often enough, not a full reunification from scratch - and in practice it can be filed while the main applicant’s case is still under review, without waiting for approval.
Mixing up the authorities. The application goes to the provincial immigration office, not the UGE-CE; the forms, timelines and notification logic are different.
Requirements and documents
The mechanics of the switch are the same for all five Ley 14/2013 statuses - articles 191.3, 80 (employment) and 86 (self-employment) do not depend on which specific basis your current permit was granted under. The difference lies in a couple of history and document nuances specific to each status. Below are the requirements for each status separately - open yours.
Before the documents, though, there is a condition checked ahead of everything else, and it can close the route outright.
You cannot switch into employment with the same employer or within the same corporate group. Criterio de Gestión DGGM 1/2025 puts it without softening: a general-regime residence and work permit for employment may not be applied for if the employer is the same, or belongs to the same group of companies, as the one behind your Ley 14/2013 permit. The prohibition is expressly extended to three further configurations: subcontractors, companies providing services to that employer or its group, and temporary work agencies (ETT) supplying the worker to that employer or group.
The point of the rule is that the administration looks past the CIF on the contract to the real connection: common directors, ownership structure, the share of the “new” company’s revenue coming from the old one, and how the relationship is actually performed. A change of signage does not work - and according to Spanish colleagues’ practice, this is the paragraph currently producing refusals to admit applications for processing (inadmisión a trámite).
Who it hits hardest:
- Intra-company transfer (ICT). The most natural scenario - staying on at the Spanish office of the same group - is closed by definition of the status. For ICT holders, switching into general-regime employment almost always requires an employer outside the group, or the self-employment branch instead.
- Highly qualified professional. The idea of “staying with the same employer but moving to the general regime for the 4 year card and the freedom” does not work.
- Employed nomad. An offer from the Spanish subsidiary of the very foreign employer behind your permit falls under the prohibition.
- Self-employed nomad. Not directly affected: the prohibition is written for employment. But if a key foreign client decides to put you on payroll, the configuration becomes a problem again.
The practical conclusion: work through who the employer is and how it connects to the old one before signing the contract, not after filing. Rewriting a contract is cheaper than an inadmisión and the loss of three months of your window.
Digital nomad
A typical trigger for this switch: a Spanish company offers you a job (the employed nomad status simply does not allow a Spanish employer), a self-employed nomad’s share of Spanish clients approaches the 20% income threshold, or the foreign employer or a key client stops existing.
On the self-employment track (modification into cuenta propia), the paperwork is not built around a business plan but around proof that the activity is already genuinely running: RETA registration, filed tax returns (Modelos 130/303), turnover, social security contributions, the licences and registrations the activity requires, matching qualifications. The regulation here (article 86) literally speaks of continuity of an existing activity, not the viability of a future project. A practical nuance: the switch does not interrupt the activity, but it changes its legal frame - once approved, the restriction on Spanish clients disappears, so sequence the alta history, the change of basis and the notifications in advance so that no formal gap appears. From experience working with the Asturias immigration office: a nomad with an already-running self-employed activity was not asked for a new business plan, the activity itself was enough - but that is the experience of one specific office, and practice differs by province.
The paperwork for an employment-based switch: a signed contract guaranteeing activity for the duration of the permit, with a salary at or above the collective agreement level for the role; on part-time terms the annual amount must remain sufficient. The employer: registered with Seguridad Social, no debts to AEAT or social security, and the economic, material and staffing resources to sustain the contract. The applicant: qualifications matching the role (with homologation of the degree for regulated professions), no criminal record, fees paid.
Entrepreneur (startup visa)
A typical trigger for this switch: the startup has closed, pivoted, or the founder has exited and wants ordinary employment.
On the self-employment track (modification into cuenta propia), the same continuity logic (article 86) applies as for the other statuses, but with a shortcut: if the project keeps running on the business plan ENISA already approved, no second, new business plan is needed - the same document filed with ENISA is attached instead. From experience working with the Asturias immigration office: an entrepreneur was told exactly this - since the project already runs on the approved plan, no new one is needed. That is the experience of one specific office, and practice differs by province.
The paperwork for an employment-based switch: a signed contract guaranteeing activity for the duration of the permit, with a salary at or above the collective agreement level for the role; on part-time terms the annual amount must remain sufficient. The employer: registered with Seguridad Social, no debts to AEAT or social security, and the economic, material and staffing resources to sustain the contract. The applicant: qualifications matching the role (with homologation of the degree for regulated professions), no criminal record, fees paid.
Highly qualified professional
A typical trigger for this switch: the contract with the employer your highly qualified professional permit was tied to has ended, or you want to move to another company outside that fast-track procedure.
Note: staying with the same employer and simply changing the legal basis to the general regime is not possible - Criterio DGGM 1/2025 (above) prohibits it expressly, along with moving into the same group of companies, its subcontractors and its service providers. The new employer has to be genuinely new, and the connection is worth checking before the contract is signed.
The paperwork for an employment-based switch (the most common scenario for this status): a signed contract guaranteeing activity for the duration of the permit, with a salary at or above the collective agreement level for the role; on part-time terms the annual amount must remain sufficient. The employer: registered with Seguridad Social, no debts to AEAT or social security, and the economic, material and staffing resources to sustain the contract. The applicant: qualifications matching the role (with homologation of the degree for regulated professions), no criminal record, fees paid.
On the self-employment track (modification into cuenta propia), the general article 86 logic applies: the paperwork is not built around a business plan but around proof that the activity is already genuinely running - RETA registration, filed tax returns, turnover, social security contributions, the required licences and matching qualifications.
Intra-company transfer (ICT)
A typical trigger for this switch: the temporary assignment to a Spanish office of the same corporate group is ending, and you want to stay in Spain on ordinary terms - employed outside the group, or self-employed.
For this status the restriction from Criterio DGGM 1/2025 (above) bites harder than for any other: you cannot switch into employment inside the same group of companies the transfer was arranged within, and the prohibition also covers subcontractors, service providers to the group and ETT arrangements. Two realistic branches remain - a new employer outside the group, or self-employment. Plan for that early, not in the final weeks of the card.
The paperwork for an employment-based switch: a signed contract guaranteeing activity for the duration of the permit, with a salary at or above the collective agreement level for the role; on part-time terms the annual amount must remain sufficient. The employer: registered with Seguridad Social, no debts to AEAT or social security, and the economic, material and staffing resources to sustain the contract. The applicant: qualifications matching the role (with homologation of the degree for regulated professions), no criminal record, fees paid.
On the self-employment track (modification into cuenta propia), the general article 86 logic applies: the paperwork is not built around a business plan but around proof that the activity is already genuinely running - RETA registration, filed tax returns, turnover, social security contributions, the required licences and matching qualifications.
Researcher
A typical trigger for this switch: the hosting agreement (convenio de acogida) with a research or educational institution is ending, and you are staying in Spain on other terms - employed or self-employed.
The paperwork for an employment-based switch: a signed contract guaranteeing activity for the duration of the permit, with a salary at or above the collective agreement level for the role; on part-time terms the annual amount must remain sufficient. The employer: registered with Seguridad Social, no debts to AEAT or social security, and the economic, material and staffing resources to sustain the contract. The applicant: qualifications matching the role (with homologation of the degree for regulated professions), no criminal record, fees paid.
On the self-employment track (modification into cuenta propia), the general article 86 logic applies: the paperwork is not built around a business plan but around proof that the activity is already genuinely running - RETA registration, filed tax returns, turnover, social security contributions, the required licences and matching qualifications.
The family route
Family permits under Ley 14/2013 are legally tied to the main holder’s authorisation, so his or her move to the general regime cannot be planned in isolation: family cards left hanging in the air are the most common source of trouble on this route. Keep the administrative seam in mind too: the old Ley 14/2013 permit does not simply lapse the moment the new one is granted - the immigration office reports the outcome to the UGE-CE and the two coordinate its extinción. While that runs, the position of the dependent cards is formally suspended, and that is exactly the gap where filing-calendar mistakes land. From there, the route depends on whether a given family member holds their own Ley 14/2013 permit, and on whether they want independent status or are fine staying dependent.
Own Ley 14/2013 history, and independence makes sense. A spouse, partner, or dependent adult child documented alongside the main applicant under Ley 14/2013 holds their own right to work under that law, which means the favourable article 191.3 scenario is open to them too: after a year of residence, each switches to a personal residence and work permit valid 4 years, independently of and in parallel with the main applicant. The outcome is often stronger than the starting position: instead of dependent cards, the family ends up with a set of independent, fully fledged statuses. Minor children are documented through the child of a resident permit, their status follows the parents’ and needs no basis of its own.
The requirements for their own switch depend on where exactly the family member is heading. For employment (cuenta ajena), the regulation points to article 80 - a standard contract, no business plan needed. For self-employment (cuenta propia), article 191.3 points to article 86, which is written for renewing an already-existing activity, meaning it requires proof of its continuity specifically. If the family member has actually been working all along - as autónomo or under a contract, exercising the very right to work that their dependent card already gave them - there is something to show, and under article 86’s logic no new business plan should be needed, just as for the main applicant. If they never used that right and never ran any activity, there is nothing to show: article 86 itself only speaks to continuity, and the regulation does not directly spell out what happens for someone with none. The sensible approach here is to fall back on the logic of article 84 (the initial cuenta propia permit) and prepare proof that the project is viable, rather than count on the favourable renewal-level threshold on the strength of a formal right to work alone.
Own Ley 14/2013 history, but staying dependent is simpler. Not everyone in the family needs or wants their own job or activity - sometimes it is simpler to just re-file the dependent card under the main applicant’s new basis, without switching to an independent status. That is a modification (form EX-02), not a fresh family reunification from scratch: the dependent spouse, partner or child applies for a new dependent card, this time tied to the main applicant’s cuenta propia permit rather than to the previous nomad or entrepreneur basis. In practice, this modification can be filed once the main applicant has filed their own switch application and it is under review, without waiting for the main applicant to actually hold the new card - cases exist where a spouse’s modification was filed just weeks after the main applicant’s own filing, and both were approved. Official sources do not directly confirm this timing rule, so treat it as workable practice rather than settled law, and confirm it in your specific case rather than building a filing calendar on it blindly. Documents for the dependent typically include a copy of the passport and TIE, a housing-adequacy report (informe de adecuación de vivienda - required even for a childless couple, though alternative documents can follow within 30 days if the report is late), proof of family income (150% of IPREM for two, plus 50% per additional member), and the fee under Modelo 790, código 052, punto 2.1.
No Ley 14/2013 history at all. A new partner, a child born after the nomad or entrepreneur permit was granted, a spouse joining for the first time - none of them has a Ley 14/2013 history of their own, so there is no modification onto the main applicant’s new basis either: for them this is not re-filing an existing card, it is a filing from scratch. The only route is ordinary family reunification (reagrupación familiar, articles 65-71 of the current regulation and articles 16-19 of Ley Orgánica 4/2000), sponsored by the main applicant once he or she holds the general regime permit.
The logic here is different again - not parallel, and not tied to the main applicant’s application merely being filed, but strictly sequential. The main applicant must first actually hold the new card (not merely have applied for it), show at least one year of legal residence, and demonstrate income of at least 150% of the monthly IPREM for a two-person family unit plus 50% IPREM per additional member (a lighter threshold applies where minors are involved), a housing-adequacy report from social services, and health insurance for everyone. Only once that file is approved does the family apply for visas, enter Spain within a month, and only then receive their cards. This cannot be bundled into a single filing with the main applicant’s own switch - it is inherently a second stage.
The good news under the current regulation: the card of a reunited spouse, partner or working-age child authorises work, employed or self-employed, immediately, with no separate work permit needed. That used to be a separate step; now one card covers both residence and work. That said, reunification is expressly carved out of article 191 - it has its own, separate path to independence: a year for a spouse or partner, later for children, under the rules of that same chapter of the regulation, not the favourable one-year article 191.3 scenario.
The key to all three routes is synchronisation, just built differently. For family members with their own Ley 14/2013 history, there is a choice between independence and a dependent modification, and in the second case filing can run in parallel with the main applicant’s case, without waiting for it to close. For those with no history to build on, the opposite applies: the reunification file simply cannot open until the main applicant holds the new card in hand. Working out which of the three routes fits each family member, and building that calendar, is the first thing I do in these cases, before any documents are gathered.
If you’re open to relocating to Asturias
For the switch to cuenta propia under article 191.3, it makes no difference which province you currently live in - but the province where you file does matter for the case itself: it is handled by the provincial immigration office covering your real domicile, not any office of your choosing. Domicile is proven by your padrón (empadronamiento) in a municipality that has to be the actual centre of your life, not just an entry in the file.
If you are not geographically tied down - working remotely, or in the process of moving into self-employment - and you are weighing different parts of Spain to live in anyway, this is worth discussing. I run my practice in Asturias and work with this specific office’s procedure on an ongoing basis. If a move there fits your plans, I can help you assess whether it is worth doing before filing, and take on the practical side: finding housing for a genuine change of residence rather than a paper one, timing the padrón sensibly against the filing, and preparing the cuenta propia file itself (proof of continuity, funds and qualifications, and a business plan where one is actually needed) with an eye to how this office actually assesses this kind of application.
One thing worth stating plainly: this is about an actual relocation, not a formal registration without physically living there. The immigration office already treats the padrón as one indirect indicator of residence among several, not decisive proof on its own - a mismatch between your registered address and your real life causes more problems than it solves, and not only at this filing but at future renewals too.
Frequently asked questions
Can you switch from a Ley 14/2013 permit (nomad, entrepreneur, highly qualified professional) to an ordinary Spanish work permit?
Yes, without leaving Spain. After one year of legal residence, article 191.3 applies: Ley 14/2013 permits authorise work, so you only meet the renewal-level requirements of a work permit. The new permit is issued for 4 years at once and drops every restriction: any employer, any activity, employment or self-employment, anywhere in Spain. But the route does not open at any moment of your choosing: under Criterio de Gestión DGGM 1/2025 it becomes available only once the conditions of the old status have stopped being met, and you must file within three months of that event. Without a year of residence, a different branch applies - initial-permit requirements and a one-year card.
Is there a labour market test?
No. The labour market test applies to initial work permits, while the article 191.3 route requires renewal-level conditions: a genuine contract, an employer with no AEAT or Seguridad Social debts, matching qualifications. That is the advantage of switching from a status that already authorised work: the position need not appear in the shortage catalogue.
Does the Beckham tax regime survive the switch?
Changing the immigration basis does not end the regime by itself, but the conditions of article 93 LIRPF must keep being met. Employment with a Spanish company is usually compatible with the regime; moving into ordinary self-employment is the classic way to lose it. Assess the tax side together with the immigration side, before filing.
Can you choose which province handles your application?
Not directly - the case is handled by the provincial immigration office covering your real domicile, proven by your padrón, not any office of your choosing. But if you are not geographically tied down - working remotely or moving into self-employment - you do have a choice of where to establish that domicile. Relocating to a specific region before filing is a legitimate step, provided it is a genuine move and not registration without actually living there.
When can you file the modification, and how long do you have?
Criterio de Gestión DGGM 1/2025 opens the switch into the general regime only after changes have occurred that prevent the Ley 14/2013 permit from being maintained: loss of the contract or of a key client, crossing the 20% threshold, the startup closing, an ICT assignment ending. While the conditions of your status are still met, there is no basis for a modification. You then have three months from the date of that change to file, and the Ley 14/2013 permit must still be valid on the filing date. Document the date of the event - the clock runs from it.
Can you move to the general regime and stay with the same employer?
No. Criterio de Gestión DGGM 1/2025 expressly prohibits applying for a general-regime residence and work permit for employment if the employer is the same, or belongs to the same group of companies, as the one behind the Ley 14/2013 permit. The prohibition also covers subcontractors, companies providing services to that employer or group, and temporary work agency (ETT) arrangements. The administration assesses the real connection rather than a matching CIF, and in practice this produces an inadmisión a trámite. It hits intra-company transfers (ICT) and highly qualified professionals hardest.
Could you apply for arraigo social instead of a modification?
Not while holding a valid Ley 14/2013 card. The amendment made by RD 316/2026, in force since 16 April 2026, wrote an express requirement into the arraigo rules: you may not hold another stay or residence permit, and you may not be an interested party in a procedure for granting, extending or modifying one. That also rules out running a modification and preparing an arraigo in parallel. Arraigo social remains an option only for those who have already lost status.
Do I need a new business plan to switch into self-employment?
Usually not, if the activity is already genuinely running. Article 86 of the regulation, which governs this switch, asks you to prove continuity of an existing activity - RETA registration, filed tax returns, turnover, social security contributions - not to present a forecast of a future project. That is renewal-level language, not initial-permit language. In my own practice in Asturias, a nomad with an already-running self-employed activity was not asked for a new business plan, and an entrepreneur was told the same thing in a different way: since the project already runs on the plan ENISA already approved, attach that same plan, no new one needed.