Effective immediately, Spain has implemented the EU Directive on the posting of workers. There are three main changes to the requirements for these applications.
First, the Communication of Transfer (COT) will be required to be filed electronically. The central register is expected to be in operation in six months. Until then, COT may be submitted as previously, online or manually.
Second, the COT must contain the details of the natural or legal person in Spain who represents the foreign company in regards to the communication of transfers as well as in regards to the workers and the negotiation related to posted workers. Previously it was only the data, rather than the contact details, of the representative that were required.
Third, the following documents must be available and translated to Spanish, if in another language, during the transfer and termination of foreign nationals: the employment contract and documentation evidencing the work conditions, pay slips, registry of working hours, and Work Permit (when applicable).
What This Means for Employers and Foreign Nationals
Employers and foreign nationals submitting posted worker applications in Spain will need to take these new requirements into account when preparing the applications.
Fragomen can assist with applications and ensure they fully comply with the new requirements.
This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].
Explore more at Fragomen
Media mentions
Partner Jill Bloom explains how the new wage-based H-1B selection rule may influence hiring decisions and prompt employers to reassess workforce planning and explore alternative visa options.
Media mentions
Partner K. Edward Raleigh discusses how companies are rethinking their H-1B strategies amid evolving policies.
Awards
Senior Counsel Mitch Wexler is recognized by EB5 Investors Magazine as a 2025 Top 25 award recipient, reflecting leadership and long-standing impact in the global investment immigration space.
Media mentions
Partner K. Edward Raleigh commented on proposed changes to US entry requirements.
Video
Business Immigration Consultant Marisa Gizzi from Fragomen explains everything about the Schengen C Visa: who needs it, how to apply and key travel tips to stay compliant in the Schengen Area.
Media mentions
Partner Rick Lamanna discussed Canada’s $1B plan to attract global researchers.
Blog post
Manager Alex Hood, Senior Associate Kimberley Ong and Immigration Paralegal Ataa Rajput explain the final extension and settlement deadlines for UK Tier 1 Investor visa holders and outline who can still qualify and why early action is essential.
Media mentions
Partner K. Edward Raleigh on how the $100K H‑1B fee factors into hiring international talent.
Media mentions
Managing Director Magdalene Tennant and Director Kitty Lo highlight Hong Kong as an attractive destination for global investors.
Blog post
IPM Business Process Manager Hazel Yaman outlines key visa, work authorisation and border considerations for athletes, media, event staff and spectators travelling to Italy for the Milan–Cortina 2026 Olympic and Paralympic Winter Games, including the impact of the EU’s new Entry/Exit System.
Media mentions
Corporate Services Director Elena Caron highlights key considerations for UK nationals moving to the UAE.
Media mentions
Associates Charlotte Roberts and Karina Casey highlight how the UK’s earned settlement proposal may influence global talent and HR planning.
Media mentions
Partner Jill Bloom explains how the new wage-based H-1B selection rule may influence hiring decisions and prompt employers to reassess workforce planning and explore alternative visa options.
Media mentions
Partner K. Edward Raleigh discusses how companies are rethinking their H-1B strategies amid evolving policies.
Awards
Senior Counsel Mitch Wexler is recognized by EB5 Investors Magazine as a 2025 Top 25 award recipient, reflecting leadership and long-standing impact in the global investment immigration space.
Media mentions
Partner K. Edward Raleigh commented on proposed changes to US entry requirements.
Video
Business Immigration Consultant Marisa Gizzi from Fragomen explains everything about the Schengen C Visa: who needs it, how to apply and key travel tips to stay compliant in the Schengen Area.
Media mentions
Partner Rick Lamanna discussed Canada’s $1B plan to attract global researchers.
Blog post
Manager Alex Hood, Senior Associate Kimberley Ong and Immigration Paralegal Ataa Rajput explain the final extension and settlement deadlines for UK Tier 1 Investor visa holders and outline who can still qualify and why early action is essential.
Media mentions
Partner K. Edward Raleigh on how the $100K H‑1B fee factors into hiring international talent.
Media mentions
Managing Director Magdalene Tennant and Director Kitty Lo highlight Hong Kong as an attractive destination for global investors.
Blog post
IPM Business Process Manager Hazel Yaman outlines key visa, work authorisation and border considerations for athletes, media, event staff and spectators travelling to Italy for the Milan–Cortina 2026 Olympic and Paralympic Winter Games, including the impact of the EU’s new Entry/Exit System.
Media mentions
Corporate Services Director Elena Caron highlights key considerations for UK nationals moving to the UAE.
Media mentions
Associates Charlotte Roberts and Karina Casey highlight how the UK’s earned settlement proposal may influence global talent and HR planning.