Posted: Mon Sep 7, 2020 9:24pm
That requirement is only for citizenship.
There WAS discussion about introducing a basic conversational Spanish test for TIE to fall into line with the UK basic English requirements in their new Points-based immigration law, however I don’t believe that came to anything.
There is a step-by-step blog post from an American who outlines the process for a Third Country National that should be looked at by anyone coming over post 2020. In particular the need to get your Visa first, which appears to allocate your NIE number, then arrive within 3 months of receiving visa, and apply for TIE within 30 days of arrival. It’s dated 14th October 2019, so still pretty relevant.
https://www.wanderingearl.com/spanish-residency-card-tie-all-you-need-to-know