What is silencio administrativo positivo?
Under Spanish administrative law, when a public body doesn't respond to your application within a legally fixed deadline, the silence itself counts as a decision. For Law 14/2013 highly-qualified renewals (HQP), that decision is positive: your application is considered approved.
The specific deadline for HQP renewals is 20 business days (días hábiles) from the date of submission, counted from the day after you filed. Weekends, national holidays, and regional holidays don't count.
How the clock actually runs
- Day 0 is the date on your Acuse de Recibo (the "Fecha alta").
- Day 1 is the next business day after that.
- Weekends don't count.
- Spanish national holidays don't count.
- Madrid regional holidays don't count — UGE-CE (Unidad de Grandes Empresas y Colectivos Estratégicos) operates out of Madrid.
Our status tracker does the counting for you and shows the exact date on which the silencio clock expires.
What stops the clock
Two events can pause or restart the 20-day clock:
- Requerimiento: if UGE-CE asks for additional documents, the clock pauses until you respond. You have 10 business days to respond, or the application can be archived.
- Pendiente de informes: when the file is waiting on a report from another body (e.g., antecedentes penales), the clock can pause while that report is pending.
Watch your notifications
If a requerimiento has been issued and you miss the 10-business-day response deadline, your application can be archived (desistimiento). Check the portal notifications inbox regularly — UGE-CE does not always send an email.
Confirming silencio applies
Once the 20-day threshold has passed with no requerimiento and no resolution, you can safely treat the file as approved by silence. In practice, this means:
- Check the Law 14/2013 portal and infoext2 for any notifications.
- If both are clean, request an acreditación / certificación de silencio positivo from UGE-CE — a written document confirming your file was approved by silence.
- With the certification (or the later formal resolution), book a cita previa at your local Comisaría de Policía Nacional for fingerprints and TIE collection.
How to request the certification
There are four ways, ranked by practicality:
- Email UGE-CE at movilidad.internacional@inclusion.gob.es — the lowest friction option. Include your registration number (número de expediente) and submission date.
- Via Sede Electrónica using a digital certificate or Cl@ve — see our authentication guide.
- At any Registro Público using the 060 network — works without a certificate but requires an appointment.
- In person at UGE-CE, Calle de José Abascal 39, Madrid — only if you're nearby and the other channels have failed.
Not legal advice
This guide is informational. If your file is blocked, a requerimiento was issued, or the silencio window passed but the portal still shows "en trámite," consider consulting an immigration lawyer.