Institutional Action — Authorities and Requests

AI working output mapping documented problems to competent institutions, legal basis, requested action, evidence required and follow-up status. Human action is required where an actual request must be sent or an institutional response obtained.

Architecture status — 22 September 2026. KEEP ACTIVE AS A DOWNSTREAM IMPLEMENTATION PROJECT. This page is not a research master and is not part of the narrative text of Memo I–III. Its role begins after the memorandum/evidence layer has identified a sufficiently documented problem: convert that finding into a competent recipient, precise request, legal basis, evidence package and review/follow-up path. It is therefore a future institutional-action layer complementary to the Memo I–III package. No request is treated as sent, agreed or adopted merely because a module is drafted here.

Working result — 20 September 2026

Private analytical mapping. Current scope: Spain + Belarus source-law/document-access issues arising from Memorandums I–III. Portugal is outside the present workstream: IBDED is not currently proposing or requesting action from Portuguese institutions on this page. The source pages describe norms, documented institutional mechanisms, problems and hypotheses; the absence of private case files does not substantiate a prevalence estimate or any particular person's case. “Prepared” means a private analytical/request design, not submission or institutional agreement.

Problem → authority → request

ID / documented research problem	Competent recipient and route	Precisely requested action	Evidence / legal anchor	Status and boundary
ES-1 / Memo I: expired passport and immigration-document acceptance	Body processing the immigration application; DGP for police/TIE functions; central migration and police authorities for existing guidance	Identify the current implementing guidance and the procedure for documenting that the applicant falls within the January 2026 instruction. For an individual refusal, request a reasoned decision addressing the relevant scope conditions.	January 2026 joint instruction; application category, presence date and dated rejection if an actual case is pursued.	Research request prepared. No individual refusal supplied; do not allege one.
ES-2 / Memo I: remaining travel-document gap	Ministry of the Interior / DGP for present documentation practice; responsible legislative/regulatory bodies for reform	Request an assessment of a separate category-based travel-document instrument, including the enabling legal instrument, issuing authority, eligibility, validity, return conditions and external recognition. Preserve the individual art.211 route.	RD1155/2024 arts210–211; Orden INT/3321/2011; anonymised examples still needed for impact evidence.	Policy proposal prepared. Art210(12) is not asserted to authorise the proposed travel reform.
ES-3 / Memo II: inaccessible Belarusian criminal-record certificate	The Spanish body handling the relevant DA20/DA21 application; policy questions to the migration administration	Request existing operating guidance and recorded aggregate counts for diplomatic retrieval, non-response and subsequent procedural outcomes. Distinguish applications made within the 2026 filing window from later inquiries.	Applicable DA20/DA21 text; actual application, certificate request and elapsed-time evidence for an individual claim.	Information-request module prepared. Do not portray a closed filing window as presently open or promise a declaration will replace the certificate.
ES-4 / Memos II–III: birth/marriage evidence and authentication obstacle	Responsible Registro Civil office; central civil-registry authority for general existing instructions	Identify the exact document and fact required, and assess the particular statutory authentication/verification route. Request a reasoned explanation of why the offered evidence does or does not satisfy that route.	Ley20/2011 arts95 and98; original/copy, provenance, fact to register and record of actual attempts.	Draft module prepared. Civil-registry rules cannot be exported to every immigration, education or nationality procedure.
ES-5 / Memo III: divorce decree or diploma treated as a generic apostille problem	For a judgment: competent recognition/registry route; for academic recognition: body responsible for that specified procedure	Separate recognition of legal effect from authenticity and translation; identify the specific missing requirement before proposing substitution.	Ley20/2011 art96 for the registry/foreign-judgment issue; academic procedure and applicable exceptions still require verification.	Research questions prepared; no ready-to-file individual application.
Portugal — out of current scope	None in the present workstream	No Portuguese institutional request or policy proposal is being developed here.	Earlier Portugal research remains separate from the present Spain/Belarus memorandum work.	Inactive for this mapping; do not treat as pending outreach.
Portugal — no active request	Not in current scope	No action.	No Portugal analysis is being advanced through this mapping.	Superseded by the 22.09.2026 scope decision.
EU / cross-border dimension of the documentary gap	EU institutions for policy coordination; national authorities for national document issuance	Prepare a comparative policy brief separating issuance, residence, border crossing and recognition. Ask what coordination measures exist; do not ask an EU body to issue a national passport.	National matrices and verified EU source review needed for any specific EU obligation.	Research framing only; exact institutional submission channel not yet selected.
BY / source-country document access and special representation barriers	Authoritative Belarusian legal sources, competent issuing body/archive and published consular/administrative channels; direct authority contact only after separate case/risk assessment	Use the current ETALON-derived route for the exact document: identify issuer/holder, procedure, representation rule, authentication route and any verified exception. Do not request a Belarusian act that the current source package already resolves; return to ETALON only for a new concrete legal question.	Current package: No.278/249, No.200, No.305-Z/No.63, No.610, No.274/450, No.754, MFA No.15, Law No.136-Z/Decree No.209, No.635, the current liquidation/archive framework, plus the RB4 sectoral layer: Law No.313-Z + Council of Ministers No.691 (vehicles), Council of Ministers No.441 (driving licences), Law No.133-Z + State Property Committee No.29/35/38/39 (real estate), and Ministry of Justice No.67/2025 (civil-status forms).	Normative acquisition is no longer generally blocked. No finite expanded list under Decree No.278 item 2.2 is reconstructed for this project; individual accessibility, risk and actual authority response remain case facts.

Reconciliation update — 22 September 2026

Spain/Belarus only. The institutional map must now use the substantive source results already established in 02, 03, the ETALON reconciliation, the Madrid/H-DOC research, the Step 3 Spanish receiving matrix, the Step 4 regional pareja matrix and the C01–C46 integrated chains rather than reopening generic source requests.

Receiving-side routing: identify the exact Spanish procedure before choosing an institutional recipient. DGT, Registro Civil, an autonomous pareja register, an Oficina de Extranjería, nationality, university-recognition bodies and professional regulators do not share one documentary-substitution rule.
Pareja: where the issue is autonomous registration, address the competent regional register using that region's own eligibility/document rules. Where the issue is immigration based on a stable unregistered relationship, address the immigration authority and use the RD 1155/2024 evidence branch; do not ask the regional register to decide immigration sufficiency.
Education: a request about missing transcript must identify the art.13.1(d) information missing; a title-issuance certification resolves only art.13.1(c). A request for more time should cite the bounded RD 889/2022 completion/extension mechanism rather than ask for a general waiver.
2026 criminal-record files: institutional questions are limited to timely historical DA20/DA21 files and recorded processing; the route is closed to new filings and diplomatic non-response is not a final waiver.
Expired passport / domestic procedures: first apply the Joint Instruction of 19 January 2026 within its actual personal, temporal and procedural scope; do not treat it as a travel-document rule.
Travel-document gap: preserve existing Articles 210–211 and special protection/statelessness regimes; any broader category-based travel-document route remains a proposal and must pass the cross-memo compatibility tests.
Criminal-record evidence: distinguish Madrid consular output, MVD/E-Pasluga 3.19.02 and the closed-window DA20/21 diplomatic-retrieval mechanism. For C29 (a non-Belarusian former resident of Belarus), use Law No.94-Z art.15 as a person-based own-data route: no citizenship/current-residence bar was identified, persons abroad have a diplomatic/consular channel and notarised representation is provided in the stated cases; do not import the Belarus-citizen No.278 POA restriction or the Madrid Belarus-citizen identity checklist. Portal/mission operation for a particular foreign national remains an empirical check. A request for statistics/guidance must not imply that the filing window is still open or that diplomatic retrieval is a final waiver.
Civil-status documents: use current Belarusian 5.9/5.14, No.610, Ministry of Justice No.67/2025, Decree No.278/249 and the identified archive routes; distinguish the existence/form of a Belarusian certificate from applicant eligibility and from the exact Spanish fact to be proved. On the Spanish side distinguish Registro Civil authenticity, missing data and recognition of foreign decisions.
Education: use No.274/450, procedure 6.1.1 and the current liquidation/archive route together with RD889/2022, DT2, Valida-TE and Article 30 Regulation 2024/1347 according to status. No PRD draft is an operative waiver.
Representation: a generally valid Spanish-notary power does not automatically satisfy the special Belarus-executed-power condition in Decree No.278 Annex 1 procedures; a new Belarusian consular POA is not a verified workaround. No finite expanded list under item 2.2 is reconstructed or maintained as a residual research question.
Authentication: No.754 and MFA No.15 distinguish apostille and legalisation; H-DOC/MAEC confirms the separate Spanish route for consular documents. Authentication never proves substantive sufficiency by itself.

Evidence rule: without an actual requerimiento, refusal, notification or case file, this page may map legal rules, competent authorities, official procedures and institutional/normative gaps. It must not state that Valencia/Madrid systematically refuses a document or that a particular person received an unlawful refusal.