The Directorate General for Migration Management (DGGM) has published Official Guidance 10/2025, a particularly relevant document for international students, researchers and individuals undertaking non-employment internships who wish to change their immigration status in Spain and access a residence and work authorisation or a residence authorisation with an exemption from the work permit.
This new guidance aims to unify the interpretation applied by Immigration Offices and to clarify one of the most common practical doubts that arose following the entry into force of the new Immigration Regulation approved by Royal Decree 1155/2024.
Below, you can access the full text of Official Guidance 10/2025 issued by the Directorate General for Migration Management (in Spanish):
⏺️ The origin of the issue: article 190 of the new Immigration Regulation
Article 190 of Royal Decree 1155/2024 introduces, as a general requirement for changing from a stay for study purposes to a residence status, that the foreign national must not have been granted a scholarship or subsidy by public or private bodies within programmes for sustainable development cooperation or humanitarian action, whether Spanish or from the country of origin.
This requirement did not exist under the previous regulatory framework set out in Royal Decree 557/2011. As a result, significant uncertainty arose for students whose permits had been granted under the former rules and who now intended to change their status in accordance with the new regulation.
⏺️ What the Official Guidance 10/2025 clarifies
Official Guidance 10/2025 clarifies that the requirement of not having been granted a scholarship or subsidy does not apply where the foreign national holds an authorisation for stay for study purposes, research or training activities, or non-employment internships granted under Royal Decree 557/2011.
This interpretation is based on the transitional regime provided for in Instruction SEM 3/2025, which allows these individuals to access residence and work status, or residence with an exemption from the work permit, under Article 190 of Royal Decree 1155/2024, provided that they meet the requirements set out in paragraphs two and following of that article.
Accordingly, where a change of status is requested under Article 190 of the new regulation and the initial authorisation was granted under Articles 37.1 (points a, b or d) and 43 of Royal Decree 557/2011, Immigration Offices should not require proof that the applicant has not been granted a scholarship or subsidy. This is a requirement specific to the new regulatory framework and does not apply to these transitional situations.
⏺️ Practical importance for students and professionals
This clarification has a direct and very positive impact on many applications currently being processed or yet to be filed. It avoids unnecessary requests for additional documentation, reduces the risk of refusals due to differing interpretations between Immigration Offices, and provides greater legal certainty for those planning their transition from an academic environment to the labour market in Spain.
From a practical perspective, applications can now focus on the truly essential elements: obtaining the relevant qualification or certificate, meeting the applicable economic and employment requirements, and ensuring that the employment contract or professional activity complies with the current immigration rules.
⏺️ Do you need to change your stay for studies into a residence and work permit?
If you are finishing your studies in Spain or have already obtained your qualification and are considering taking the next step towards a residence and work authorization, ARC Legal can assist you throughout the entire process. Our support includes assessing the applicable legal framework, preparing the application and managing follow-up before the relevant Immigration Office.
Related publications
- Spain’s immigration Guideline 8/2025 on mobility program stay permits
- Spain leads the EU in residence permits granted for study purposes in 2024
- International students in Spain: the end of annual stay renewals
¿Prefieres leer este artículo en español 🇪🇸? Aquí tienes el enlace: La Dirección General de Gestión Migratoria aclara en el Criterio 10/2025 el requisito de no haber sido becado para modificar de estancia por estudios a residencia y trabajo
The content of this article is provided for information purposes only and does not constitute legal advice. Immigration regulations are subject to ongoing legislative, administrative and interpretative changes. At ARC Legal, we make every effort to keep information up to date and aligned with official sources; however, we always recommend seeking advice from a specialised professional before starting any procedure or making legal decisions. If you require personalised advice regarding your specific situation, please contact our firm.