On 27 January 2026, the Spanish government announced a mass regularisation scheme expected to grant legal status to around 500,000 irregular migrants. Since the application window opened in April, nearly 1.2 million applications have been submitted. Alessandra Enrico Headrington, a DPhil candidate in Migration Studies at COMPAS, reflects on what comes next.
What is Spain's mass migrant regularisation scheme?
Spain's ‘Special Regularisation Programme’ (Regularización extraordinaria de personas extranjeras en España) is a one-off regularisation scheme for people already living in the country without legal status. Rather than admitting new migrants, the scheme provides a legal pathway for people who are already part of Spanish society but remain in an irregular situation. The government anticipated around 500,000 potential beneficiaries. However, by the end of the application period on 30 June, approximately 1.2 million applications had been submitted.
The scheme comes at a time when most European countries are introducing more restrictive immigration measures. In this context, the Spanish government's decision to implement more open immigration policies has been politically divisive, both within Spain and across Europe.
How many residence permits will the Spanish government grant?
It is still too early to know. The figure of 1.2 million refers to the number of applications received, not the number of residence permits granted. Importantly, regularisation is not automatic. To be eligible, applicants must demonstrate that they had continuously resided in Spain for at least five months before the eligibility cut-off date of 31 December 2025, in addition to meeting other legal requirements. The final number of residence permits granted will depend on how many applicants meet both legal and eligibility requirements.
Why did the scheme receive more than twice as many applicants as initially expected?
This is one of the key questions raised by the unexpectedly high number of applications. One possible explanation is that the scale of irregularity in Spain was larger than the government's initial estimates.
The number of applications may also reflect the strong demand for a legal pathway among people who had been living in Spain without legal status for some time. However, applications should not be confused with the final number of residence permits granted.
How has the scheme been received?
The scheme has generated mixed reactions across Spain. On the one hand, it builds on years of public mobilisation and advocacy, including a citizen-led initiative that gathered more than 700,000 signatures and helped elevate regularisation on the political agenda. Supporters therefore see it as a pragmatic response to the reality that many people have been living and working in Spain for years without legal status.
However, the introduction of the scheme by Royal Decree, rather than through the ordinary legislative process, has drawn criticism from more conservative politicians and civil society organisations. While supporters argue that the use of Royal Decree allowed the government to respond more quickly, critics question whether a measure of this scale should have been subject to greater parliamentary scrutiny.
Nevertheless, the use of a Royal Decree does not place the measure beyond legal scrutiny, with aspects of the decree already being challenged before the Spanish Supreme Court (Tribunal Supremo).
The scheme has also drawn criticism from opposition parties, the Partido Popular (PP) and Vox, which argue that the programme could create a pull factor by encouraging further irregular migration. However, it is worth noting that, by design, the programme is limited to people who resided in Spain before 31 December 2025.
More broadly, Spain's approach stands out in Europe. While debates across the EU are increasingly focused on tightening border controls, accelerating asylum procedures, and establishing return hubs, Spain has chosen to introduce a large-scale regularisation programme. This is not necessarily inconsistent with the EU's recent Pact on Migration and Asylum, which Spain is also implementing, but rather reflects a different policy emphasis within an increasingly restrictive European immigration agenda.
How does the scale of Spain's regularisation compare with previous programmes in Europe?
Spain stands out because of the unprecedented volume of applications received. With around 1.2 million applications, it has far exceeded the country’s previous large-scale regularisation programme, which, in 2005, received around 692,000 applications and was overseen by the former Secretariat of State for Immigration and Emigration of Spain.
In recent years, Italy (2020), Ireland (2022) and Germany (2022) have also introduced regularisation schemes or legal pathways. However, while these initiatives generally involved tens of thousands of people, or around two hundred thousand in Italy's case, the scale of Spain's current programme is exceptional by recent European standards. It is therefore likely to become one of the largest regularisation programmes seen in Europe in recent decades.
What challenges could arise during implementation of the scheme?
The main challenge is administrative capacity. The application period has now closed and the focus shifts to processing a very large number of applications. This will require sufficient resources and consistent decision-making, while ensuring that eligible applicants are not excluded because of practical barriers such as documentation requirements or difficulties navigating the process.
A second issue to watch is the ongoing judicial review of certain provisions of the Royal Decree. While the authorities continue processing applications, the Spanish Supreme Court is considering challenges to parts of the decree. These proceedings are unlikely to interrupt the ongoing processing of applications, but they may provide further clarification on how certain provisions should be interpreted and applied in practice.
What happens next?
Spanish authorities will need to process a very large number of applications. Under the Royal Decree, individual applications should be decided within three months, although the unprecedented volume of cases is likely to place significant pressure on administrative capacity. Spain's 2005 regularisation provides a useful point of comparison. Almost all applications had been processed within around ten months, but the current programme is considerably larger in participation.
Beyond the overall approval rate, attention should focus on how eligibility criteria are interpreted in practice, whether decision-making remains consistent across cases, and what data reveals about who ultimately benefits from the programme.
Read more from Alessandra on the topic: https://www.compas.ox.ac.uk/article/stability-for-now-what-spains-approval-of-mass-regularisation-means-for-irregular-migrants
