Foreign degree recognition and equivalence in Spain: six months to plan for

The procedure in force is the one set by Royal Decree 889/2022 of 18 October (BOE-A-2022-17045). The maximum period to decide and notify is six months from the day the application enters the electronic register of the Ministry of Science, Innovation and Universities. If six months pass with no notification, the application is deemed refused by administrative silence.

Three different routes, and who decides each

Royal Decree 889/2022 governs three things that hiring files confuse every week, and telling them apart is what sets the calendar.

Homologación converts a foreign university degree into the Spanish degree that gives access to a regulated profession. It is the route a doctor, a nurse, an architect or a chartered engineer needs when the job requires professional registration. The ministry responsible for universities decides it.

A declaration of equivalence states that a foreign degree corresponds to a Spanish academic level, Bachelor or Master, and to a field of knowledge, without granting access to any regulated profession. It is used to evidence level to an employer or in a public competition. The ministry decides this one too.

Partial recognition of studies is a different thing altogether: the person is not seeking a degree but credit for subjects already passed, in order to continue studying in Spain. The university where the application is made decides it, not the ministry, so its queue and its deadline have nothing to do with the ministry's six months.

Six months, and silence that means no

The six month period in Royal Decree 889/2022 runs from the entry of the application in the electronic register, not from the day the applicant gathers the papers nor from the day the issuing university produces the transcript. Any request to correct the file suspends the count while the applicant replies, so a file that draws two such requests runs past the calendar half year in practice.

What matters is the effect of expiry. Once six months pass with no notification, the application is deemed refused. The silence is negative, not positive: the applicant does not acquire the Spanish degree by the passage of time, only the right to appeal. An employer planning on the opposite assumption, that silence confirms recognition, is planning on a rule that does not exist.

The application carries the degree certificate and the academic transcript legalised through diplomatic channels or with a Hague apostille, translated into Spanish by a sworn translator where required. The applicable fee is paid on the ministry's form 790 before the file is submitted.

When the employer has to wait, and when not

This is the part that decides whether the role is filled in March or in October. Recognition is only required for regulated professions. If the job is nursing, physiotherapy or engineering with project sign off, no start date is possible before the decision, and the hiring calendar has to absorb those six months or more.

If the job is operational and unregulated, a welder, a line operator, a chef, a driver, the employer does not have to wait for any ministry decision. The qualification is evidenced by experience, by a practical trade test and by whatever sector certificates the collective agreement requires, while the immigration file moves on its own track. Plenty of companies stall a process for months over a degree their own vacancy never asked for.

The opposite mistake also shows up: a company hires a foreign graduate into a regulated role, registers the worker and puts them on the job while recognition is pending. At that point the problem is no longer timing but professional authorisation, and it is the employer who answers to the Labour Inspectorate and to the professional body.

The practical way through it is to read the occupation first and the degree second. If the occupation sits on the SEPE shortage occupations catalogue, the corridor runs through the employer procedure for a residence and work permit and ends at social security registration, with recognition off the critical path.

If you have a regulated role and a candidate with a foreign degree, the date that governs is the day the file enters the ministry's electronic register, and it is worth fixing before the start date.