Highly Qualified Professional Permit (PAC) for Spain

Residencia para profesional altamente cualificado (PAC)

~23 min read · Published 22 July 2026 Updated and checked against official sources 16 September 2026 Print / PDF

The highly qualified professional permit (profesional altamente cualificado, PAC) grants residency with the right to work to applicants who already have a job offer in Spain for a managerial position or a role requiring higher education. It is processed through the fast-track international mobility regime at the UGE-CE, and it includes a distinct European variant, the EU Blue Card (Tarjeta azul-UE), with its own salary threshold.

Contents

• What it is in plain terms
• Who may file, and what the company has to show
• Occupational group: which roles qualify
• 2026 salary thresholds
• The EU Blue Card: what makes it different
• Right to work
• Dismissal, part-time work and changing employer
• How the process works

What it is in plain terms

The highly qualified professional permit (residencia para profesionales altamente cualificados, or PAC) is a residency status with the right to work for non-EU nationals who already hold an employment contract or a firm job offer from a company in Spain for a managerial role or a position requiring a higher-education qualification. Legal basis: article 71 of Law 14/2013 on support for entrepreneurs and their internationalization, as amended by Law 11/2023, which partially transposed EU Directive 2021/1883 on the EU Blue Card into Spanish law. It runs through the same fast-track international mobility regime as the entrepreneur visa, via the UGE-CE.

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Who may file, and what the company has to show

Since the reform brought in by Law 11/2023, article 71 no longer sorts applicants into categories. The text in force asks for one thing: a company that needs a foreign professional for a highly qualified employment or professional relationship. The application may be filed by the company or by the professional, and in the second case the UGE-CE notifies the company that it has been received. Which of the two routes applies turns on the worker qualification, not on the type of employer.

Here is the part that usually goes unsaid: the UGE guidance sheets, which are what decisions are actually made against, predate the reform and still carry the old categories. Where each requirement lives today, and what each source is worth:

There is nothing left to base the DGCI report on. Three facts point one way. The category the report was attached to was removed from article 71 by the Law 11/2023 reform. The body that issues it does not exist under the name Dirección General de Comercio Internacional e Inversiones as of RD 410/2024: the Secretaría de Estado de Comercio has three units reporting to it and this is not one of them, with internationalization and investment competences moved to the Dirección General de Inteligencia Económica y Comercial. And the sheet that asks for the report is not a source of law: it is an undated ministry information document, not a statute, not a regulation and not an order. It cannot create a requirement that the law does not contain.

What follows in practice. If the UGE asks for a DGCI report, the thing to look for is the legal basis, not the body: we answer with an objection citing the text of article 71 in force and the structure of the ministry. Neither the statute nor the sheet defines what makes a sector strategic, and since 2024 there is no one left to define it. This is why the DGCI report is not part of our document checklist.

The third row is the one most often missed, and it stands on its own: CNO-2011 groups 1 and 2 is a test applied to the position itself. It is set out below, under Occupational group.

The baseline for the worker is a single one: a higher-education qualification relevant to the role, or documented professional experience in place of one. How much experience is needed depends on the route, which is set out under The EU Blue Card.

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Occupational group: which roles qualify

This is a requirement in its own right, and it is easy to walk past. Under criterion 4.1.3 of the Criterios de aplicación, the role the professional is hired into has to fall within major groups 1 and 2 of the Spanish national classification of occupations, CNO-2011. The classification was approved by RD 1591/2010, and the codes and titles sit in the annex to that decree.

Checking it takes one step. Every occupation carries a four-digit code, and the first digit is the major group.

The line runs through IT, not around it. Information technology is not a single block in the classification. It is split between the second and the third group, and the split follows what the work actually is, not the sector it sits in.

Subgroup 27 qualifies, Profesionales de las tecnologías de la información: 2711 Analistas de sistemas, 2712 Analistas y diseñadores de software, 2713 Analistas, programadores y diseñadores Web y multimedia, 2719 Analistas y diseñadores de software y multimedia no clasificados bajo otros epígrafes, 2721 Diseñadores y administradores de bases de datos, 2722 Administradores de sistemas y redes, 2723 Analistas de redes informáticas, 2729 Especialistas en bases de datos y en redes informáticas no clasificados bajo otros epígrafes. Sitting in the second group alongside them is 2653 Profesionales de la venta de tecnologías de la información y las comunicaciones.

Subgroup 38 does not, Técnicos de las tecnologías de la información y las comunicaciones: 3811 Técnicos en operaciones de sistemas informáticos, 3812 Técnicos en asistencia al usuario de tecnologías de la información, 3813 Técnicos en redes, 3814 Técnicos de la Web, 3820 Programadores informáticos, 3831 Técnicos de grabación audiovisual, 3832 Técnicos de radiodifusión, 3833 Técnicos de ingeniería de las telecomunicaciones.

What follows is counter-intuitive, and awkward for the hiring company. A developer coded 3820 sits in the third group and fails criterion 4.1.3. A software analyst or designer coded 2712 passes. User support at 3812 fails as well.

Testing has no code of its own. It lands by actual duties and can go either to 2712 or to 3820, so neither can be asserted in advance.

HR qualifies, against expectation. 1212 Directores de recursos humanos is first group. 2624 Especialistas en políticas y servicios de personal y afines and 2625 Especialistas en formación de personal are second. Only administrative HR support drops into the fourth group.

Classification follows the work actually done, not the job title in the offer. Two consequences, and they cut in opposite directions. If the professional really does design systems, the duties written into the contract have to show it: the authority reads the document, not the interview. If the professional really does write code to someone else’s specification, renaming the role fixes nothing. It stays in the third group, and a file built around an attractive title comes apart at the first question about duties.

This test is not the catalog of hard-to-fill occupations. Groups 1 and 2 is a requirement for any HQP role. The catalog bears only on the reduced Blue Card threshold, see 2026 salary thresholds.

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2026 salary thresholds

There are two parallel regimes here, and since June 2026 they have converged on a single figure. It runs off neither the IPREM nor the SMI but a third basis: the country’s average annual salary.

Average gross annual salary per INE (2024 survey): €29,540.26. Salary threshold for highly qualified professionals: €41,356.36 a year, reduced €33,085.09current for 2026

EU Blue Card route (art. 71.2.a + 71 bis). The threshold is set by Order PJC/44/2026 of January 27, 2026: gross salary of at least 1.4 times the average gross annual salary per worker in INE’s Structure of Earnings Survey. A 0.8 reduction coefficient applies in two cases: if the occupation is on the shortage-occupation list (CNO-2011 groups 1-2), or if the applicant’s qualification was obtained no more than 3 years before filing.

National route (without an EU Blue Card, art. 71.2.b). This route used to be assessed under criterion 4.1.4 of the earlier Criterios de aplicación de la Ley 14/2013: the average annual salary for the CNO-2011 occupational group per INE, EUR 54,142 for managers and EUR 40,077 for other technical and scientific professionals, with a 0.75 reduction coefficient for strategic SMEs and for applicants under 30. Since June 2026 the UGE publishes a single threshold for this route, equal to the general Blue Card threshold, with no reduction coefficient. So an applicant in a shortage occupation or a recent graduate gains nothing financially from the national route: the reduced threshold lives only in the Blue Card.

What counts as salary for the threshold. The guaranteed part only. Criterion 4.1.4 of the Criterios de aplicación states it plainly: «para el cálculo de las cuantías señaladas no se computará la parte variable de las retribuciones». Bonuses, incentives and commission do not count toward the figure at all. The same criterion caps payment in kind: it may not exceed 30% of the worker’s salary payments. Criterion 6.1.6 repeats the rule for intra-company transfers. The practical consequence: an offer built on a modest base plus a bonus scheme does not reach the threshold, and that only becomes apparent on refusal.

When the threshold changes. Not in January, as the date of the order might suggest. Under article 3.2, a new threshold applies to applications filed one month after a new INE survey is published. The 2024 survey came out on May 28, 2026, so the current threshold has applied since June 28, 2026. Applications filed before that date are assessed against the previous figure. The ministry must publish the result of the calculation on the UGE portal (art. 4), which is where to check it before filing.

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The EU Blue Card: what makes it different

The EU Blue Card (Tarjeta azul-UE) is not a separate permit. It is the second route within the same article 71, and it shares the authority, the permit term, the positive silence rule and most of the paperwork with the national route. The differences sit in four places, and each of them changes how the holder lives.

Who qualifies. The Blue Card calls for a qualification at EQF level 6 (MECES Nivel 2), meaning higher education of at least three years, or five years of professional experience equivalent to that qualification and relevant to the profession in the contract. For IT professionals and IT managers the statute lowers that bar to three years of experience within the previous seven. The national route accepts level 5A (MECES Nivel 1) or three years of equivalent experience under the instructions of additional provision 20.

Which leads to the opposite of what is commonly assumed: a degree is not compulsory for the Blue Card. An IT specialist with no higher education but three years of relevant experience qualifies for it, and with it gets the reduced threshold, the job-search window and intra-EU mobility, none of which exist on the national route.

The contract. The Blue Card requires a valid contract or a firm highly qualified job offer of at least six months, with continuity of employment guaranteed for the term of the card (art. 71 bis.1 b). The national route sets no minimum contract length.

Intra-EU mobility. Under art. 71 bis.4 the holder of a Blue Card issued by another member state may work in Spain for 90 days in any 180 without a separate Spanish permit. After 12 months of residence in one member state (six, where several were involved) the right to relocate opens: the application for the Spanish Blue Card is filed from inside Spain within one month of entry, and work may start from the moment the application is complete, without waiting for a decision. The national route has nothing comparable.

EU long-term residence. Under art. 176 RD 1155/2024 a Blue Card holder accumulates the five-year qualifying period across member states rather than in Spain alone, counting time spent on a national PAC, as a researcher, under international protection, or studying (studies count at half). The condition is two years in Spain on a Blue Card immediately before filing. Absences from the EU are tolerated up to 12 consecutive months and 18 in total. Once EU long-term residence is granted, former Blue Card holders and their families may be absent from the EU for 24 months rather than the usual 12 (art. 201 c).

What happens on losing the job is covered below, under Dismissal, part-time work and changing employer: the Blue Card carries a window that the national route does not.

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Right to work

Yes, the permit includes the right to work for the specific employer named in the application, throughout Spain. Changing employer is neither a notification nor an amendment to the existing card: a new application is filed and a new initial permit is issued for its full term. The detail, and the single exception, are in Dismissal, part-time work and changing employer.

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Dismissal, part-time work and changing employer

Three situations with a direct answer in the UGE criteria, and one fork that hides between them.

Dismissal. The permit does not lapse automatically. Under the UGE criteria of June 10, 2025, residence is maintained while you are receiving unemployment benefit, provided you are entitled to it, and for as long as you receive it. The conditions come from the general regime of RD 1155/2024, which applies here as the subsidiary rule. The earlier Criterios de aplicación, criterion 4.3 state the consequence in terms: where the professional has notified the UGE of the dismissal and is entitled to unemployment benefit, «se procederá a la renovación de la autorización». The criterion itself points to art. 71 of the earlier RD 557/2011, repealed on May 20, 2025, so the chain is worth keeping in its current form: today it runs through art. 80.2 c) of RD 1155/2024 to art. 38.6 b) of LO 4/2000, where the ground is stated in terms: «cuando por la autoridad competente, conforme a la normativa de la Seguridad Social, se hubiera otorgado una prestación contributiva por desempleo». Notifying the UGE-CE is what opens this route.

From there the route forks, and what decides it is what you have in hand.

Why a change of employer does not become a renewal. Criterion 4.3 points to the general-regime renewal article as a whole, and paragraph 2 b) 1.º of that article does allow a renewal on a new contract with a different employer, where the worker is registered or treated as registered with the Seguridad Social at the time of filing. Hence the question worth settling: does a dismissed professional end up better placed than one who left of their own accord. The two criteria describe different facts. Criterion 4.2.2 is headed «cambio de empleador» and does not ask why the previous relationship ended, so it governs wherever there is a new employer. Criterion 4.3 is headed «despido del trabajador» and is conditioned on entitlement to benefit, that is, on there being no new employer. The specific rule on changing employer displaces the general referral. On top of that, a permit under this law is tied to a named company, and a renewal that keeps the old link does not cover a new employer.

The door into the general regime does not open by choice. Criterio de Gestión DGGM 1/2025, section 3: the general-regime modification rules apply to Law 14/2013 permits subsidiarily, and only once changes have occurred that prevent the permit obtained under that law from being maintained. While the professional still meets the highly qualified test, no such change has occurred. The filing window is three months from the date of the event, and the same criterion bars a permit for employment with the former employer, within its group of companies, with its subcontractors or through a temporary work agency. The route is covered on the page modification of a Ley 14/2013 permit to a general regime permit.

What is left to practice here. Whether the UGE accepts a renewal under art. 80.2 b) 1.º from a professional with a new employer is stated neither in the rule nor in the criteria. On the text of the sources there is one route, through a new initial permit.

The Blue Card job-search window. A Tarjeta azul-UE holder has something the national route does not offer. Under art. 71 bis.3 the card is withdrawn or not renewed where there is no valid contract and unemployment runs beyond three months while the card is less than two years old, or beyond six months once it is older than that. The other side of the same rule is the time allowed to find new work: three months, and six once the card is two years old. The national PAC has no such window in the statute, only the general duty to report a change within 30 days under additional provision 7 of Law 14/2013. The card is also withdrawn where the holder has obtained a Blue Card in another member state.

Part-time work. The UGE criteria are explicit: on part-time employment the professional must in any event receive at least 100% of the annual salary required for a PAC. The threshold stays annual and whole, and part-time simply means earning the same amount in less time.

Changing employer. This is neither a renewal nor an amendment of the existing permit. Under criterion 4.2.2, a professional who wants to remain the holder files a new application and receives a new initial permit for its full term, provided the highly qualified requirements are still met. The same applies when moving to another company within the same group. There is one exception: on a merger or acquisition, what is granted is a renewal for the time remaining on the initial permit, where this is evidenced under art. 44 of the Workers’ Statute. Either way, the change of employer has to be notified to the UGE-CE under additional provision 7 of Law 14/2013, and criterion 4.2.2 names who does it: the worker notifies («comunicada por el interesado»), not the company.

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How the process works

The application goes to the UGE-CE through the single international mobility electronic form (MI-T), with the employment contract or firm job offer, evidence of the applicant’s qualification, a criminal record certificate and health insurance. Either the company or the professional may file, as may an authorized representative: art. 71.1 puts the two on the same footing, and where the professional files, the UGE-CE notifies the company that the application has arrived. In practice the employer usually files, because the corporate part of the bundle and the contract are its own anyway.

The national employment situation does not apply. Additional provision 5.1 of Law 14/2013 states it in terms: «no se tendrá en cuenta la situación nacional de empleo en las autorizaciones reguladas en la sección 2.ª del Título V». The exemption covers the whole section, so both the Blue Card and the national route. There is nothing to prove about the absence of a Spanish or EU candidate for the role, and no employment-service paperwork goes into the bundle.

One body handles the file, another grants the permit. Under art. 76.1 the UGE-CE handles the application electronically, while the permit itself is granted by the Directorate-General for Migration (Dirección General de Migraciones). The time limit is 20 business days from electronic filing, positive administrative silence applies where no decision issues, and decisions are reasoned and open to a recurso de alzada under arts. 121 and 122 of Law 39/2015. Company size has no bearing on this split. The same provision adds one more thing: filing the application extends the applicant’s existing residence or stay until the procedure is decided.

A passport is enough to register with Social Security. Under art. 76.5 a passport is sufficient evidence for registration with the Seguridad Social during the first six months of residence or stay in the categories of this section, while the NIE has not yet been issued. The NIE is applied for later. For an HR team this removes the usual delay in getting a new hire onto the payroll.

The UGE company register. Under art. 76.4 of Law 14/2013 a company evidences its compliance once and stays entered on the UGE-CE register. The entry runs for three years and is renewable while the conditions hold, so later applications do not repeat the corporate bundle. The provision covers chapter IV of the section by name, which is the highly qualified professional route. Any change in the conditions must be notified to the UGE-CE within 30 days, and the statute spells out the consequence of missing that: the company ceases to be registered. There is no separate electronic procedure for it. The notice goes through the same online trámite as applications, under “comunicaciones de variación de situación”.

The register is neither automatic nor permanent. Article 74.2 excludes from the simplified procedure and from the register any company penalized for a serious or very serious immigration offense in the three years before the application, or which failed to evidence compliance in checks made by the administration on its own initiative. For the hiring company this is a subject of its own, covered on the For employers page.

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Author Aleksandr Nazarov