Posted: Wed Aug 5, 2020 1:38pm
Just want to make a correction to my earlier answer. I incorrectly stated that arrivals would have until 30 June 2021 to sort out Residency.
THIS IS INCORRECT and I apologize to any that may have been misled / given a false sense of security by this. This was the date originally given in relation to obtaining residence, but since Spain has formally adopted the declaratory system is no longer the case.
From arrival / establishing legal residence, you will have 90 days in which to pursue residence. Now, this means registering on the Padrón as the most immediate thing as that will establish to the satisfaction of Funcionarios in the various oficinas de Extranjeria that you arrived prior to 31/12. The next step will be seeking a “cita previa” at the Oficina de Extranjeria for your region. It will not matter if your appointment is after your 90 days - only that you sought the appointment within that 90 day period.
Advice on Brexpats in Spain is that ideally a Cita Previa should be sought prior to 31/12. I cannot contradict this - there is not as yet obviously sufficient evidence to say whether this will be the case or not.
Spain HAS declared that for those not arriving before 31/12 it will review each application on a case by case basis to see if the applicant(s) should still benefit from 18(4) of the withdrawal agreement - I am guessing (Please note “guessing”) that this will apply to those who arrive prior to 31/12, but for whatever reason could not start the administrative proceedings.
Arrival on 26/12 will be cutting it fine, but if you can get a Padrón, that establishes proof of legal residence prior to end of transition period.