We are receiving an increasing number of enquiries from people who have submitted an application for authorisation before the Large Companies and Strategic Groups Unit (UGE) and are seeing the days go by without obtaining an express decision. In the context of the extraordinary regularisation process of 2026, following more than half a million applications submitted, the pressure on the immigration processing bodies is becoming increasingly intense and is only adding to the uncertainty. The practical question is usually the same, if the UGE does not reply within the deadline, can the authorisation be deemed granted, or must you continue waiting?

WHAT DOES IT MEAN IF THE UGE DOES NOT REPLY WITHIN THE TWENTY-DAY PERIOD?

It is important to be clear that Law 14/2013 governs certain residence authorisations linked to international mobility and provides that their processing is carried out by the UGE through electronic means. For these authorisations, the maximum period for issuing a decision is twenty days from the electronic submission of the application to the body competent to process it. As the period is expressed in days and has not been declared to refer to calendar days, the calculation must be made in accordance with the general rules on working days.

However, not every file that was submitted twenty days ago can simply be treated as granted. The key date will depend on when the valid electronic submission was properly made, with the corresponding registration receipt, and on the receiving body.

Positive administrative silence, for its part, is a legal effect that may arise when the maximum period has correctly expired without an express decision by the Administration. It is therefore essential to verify whether the period has genuinely elapsed and whether your file falls within the legal regime that allows this favourable effect.

WHEN CAN THE APPLICATION BE DEEMED APPROVED BY POSITIVE ADMINISTRATIVE SILENCE?

As we mentioned above, approval by silence may occur in authorisation procedures processed under Law 14/2013, provided that the applicable period has expired without a decision. However, the file must first be reviewed, because an error in calculating the deadline could completely change the strategy.

The period may be affected by requests for rectification, requests for documentation, complementary actions, suspensions or other procedural incidents that must first be assessed. If the UGE notified you of a request and it is not taken into account, it must be considered for the purposes of calculating the expiry of deadlines. The same applies if the initial submission was not properly received, if a signature was missing, if it was submitted through an incorrect channel, or if there is any communication that altered the normal administrative timeline.

It is also important to make a clarification here, because many people online refer to files approved by silence, a decision by silence, favourable presumed acts or certificates of positive administrative silence as though they were all the same thing; they are not. Positive administrative silence is the effect that may arise from the expiry of the deadline. The express decision is the formal act issued by the Administration. The certificate serves to record that situation. Subsequent formalities may then exist, such as the foreigner identity card, where applicable.

HOW DO YOU REQUEST THE CERTIFICATE OF A FAVOURABLE PRESUMED ACT?

When the period has correctly expired and there is therefore no express decision on record, it is possible to request the certificate accrediting positive administrative silence, also commonly referred to in practice as a certificate of a favourable presumed act. This certificate does not create silence if it has not validly arisen, but, where applicable, it serves to evidence it and to assert it before the Administration.

That said, the request must be submitted correctly; it is not enough simply to write to the Administration stating that twenty days have passed. It is advisable to identify the applicant, the type of authorisation, the file number or reference if already available, the date of electronic submission, the registration receipt, the competent body, and a straightforward explanation that the maximum period has elapsed without notification of an express decision. It is also advisable to attach a copy of the initial registration receipt.

The submission must be made through the electronic channel corresponding to the file. In procedures before the UGE, documentation relating to this type of authorisation is submitted electronically through the competent Ministry platform, known as Mercurio. In some cases, a specific registry channel may be considered, but it should be made clear that Mercurio should not be treated as a universal channel for any document addressed to the UGE without first checking that it is appropriate.

The certificate has its own legal regime. Administrative procedure legislation provides for its issue within fifteen days, and, as interested parties, you may request it — or we may do so on your behalf — at any time once silence has arisen, with the period being calculated from the entry of the request in the competent registry.

WHAT SHOULD YOU DO IF THEY ALSO FAIL TO REPLY TO THE CERTIFICATE REQUEST?

The fact that there is no immediate response to the certificate request does not mean that your right has disappeared, nor that the file will return to its starting point. Nor does it mean that you should submit documents every two days or anything similar. In these cases, although we understand the anxiety caused by a lack of response, prudence is usually more useful than compulsive insistence.

First, it is necessary to confirm that the certificate request was submitted correctly, that the registration receipt is valid, and that the document correctly identified the file. It is then advisable to review the electronic notifications, the Citizen Folder, the electronic office and the actual current status of the file once again. Sometimes the problem does not lie in silence, but in a notification that was overlooked, not opened, a pending communication, or an incident that was not known about.

If, after a reasonable margin, no reply is received, we can consider reiterating the request in an orderly manner. In practice, waiting approximately seven to ten working days before reiterating it is, in our view, usually a prudent margin, but you should be clear that this is not a new legal deadline or a guarantee of response. The reiteration should attach the previous request, its registration receipt and a brief explanation. In any event, it should not be understood as an administrative appeal or a new main application. Its purpose is merely to insist on the issue of the certificate and to leave a clear record of what had been requested from the Administration.

HOW SHOULD A SOUND STRATEGY BE PREPARED BEFORE TREATING THE FILE AS RESOLVED?

Before treating positive administrative silence as having arisen, we must check certain matters in an orderly manner. We will begin by reviewing the initial application, confirming that it concerns an authorisation under Law 14/2013 processed by the UGE, identifying the effective date of entry before the competent body, correctly calculating the twenty working days according to the legal calendar, and checking whether there have been any requests, rectifications, suspensions or communications that could have affected the deadline.

Next, we must prepare the certificate request using your precise details and the necessary supporting documents. Once it has been submitted through the appropriate channel, the registration receipt must be kept, notifications must be reviewed periodically, and the file must be monitored. If there is no response to the certificate within the applicable framework, we may therefore consider submitting a reiteration, always linked to the previous request and to the actual status of the procedure.

At Servicios de Extranjería, we review this type of situation with a very clear approach. We do not intend to promise you that every file that has not received a response will automatically be granted, but we will check whether silence has correctly arisen and, if so, we will handle all the necessary formalities to assert it. In files before the UGE, our experience can help you avoid both unnecessary action and wasted time.

If you have submitted an application for authorisation before the UGE and have not received a reply within the deadline, we can help you calculate it, check for possible suspensions, prepare the certificate request and define a documentary strategy. For this reason, we encourage you to CONTACT US TODAY AND LET US HELP YOU BRING YOUR CASE CLOSER TO SUCCESS