Renewal isn't a formality. The UGE (Spain's immigration unit for large companies and strategic sectors) checks again that the conditions under which your permit was granted are still in place. Here's what that review looks at, and what's worth preparing ahead of time.
The official instruction the UGE works from is short: renewal checks whether the conditions that justified granting the permit are still met. In practice, that breaks down into:
A lot of people have heard: "under 183 days a year and you're not a resident, so no taxes to pay." That's a dangerous oversimplification. The law works differently.
Tax residency kicks in if you meet any one of two independent tests (plus a family presumption) — not necessarily all of them.
The Digital Nomad permit, implies that your professional activity is carried out from Spain — which, in practice, usually lines up with test B. You don't need to physically spend 183 days in the country for your center of economic interests to count as relocated: it's enough that the activity is in fact carried out from Spain. If the permit was granted for the whole family, the family presumption also applies.
This isn't an arbitrary requirement from a case officer — it's a direct consequence of the filing calendar for the annual return, Modelo 100.
The return is filed once a year — in the April–June campaign of the year following the one it covers.
The permit is granted for 3 years and renewed for 2. By the time you apply for renewal, you can have, at most, two annual returns already on file — for the first and second full years. A return for the current, still-unfinished period can't exist yet at this stage: its filing campaign hasn't opened.
Getting a requerimiento (a formal request for more information) doesn't mean you've been denied — it's a standard part of the process, used when the authority is missing a document or a clarification. What matters is not missing the response deadline and, where possible, not leaving the missing paperwork until the last minute.
Before renewing is a good time to fix gaps in tax filings or self-employment registration — see how this affects your renewal.
A few questions, and you'll see the document list for your situation: employed, self-employed, or with family.
Check what I need for my renewal