Last updated: 22-Sep-2026. Salamanca, Spain
Each memorandum is a separate comparative legal analysis divided into three main topics - travel, access to documents, and authorisation. The research and conclusions are based on current Belarusian law and practice cross-analysis, Spanish law and practice analysis, current Belarusian Embassies practice, active International Agreements between Belarus and Spain.
The proposed solutions for Spain are based on the applicable Spanish law and stress-tested against 3 main criteria: S1 — identity / residence documentation / travel / return; S2 — getting the required Belarusian document / representation / inability to acquire; S3 — apostille/ legalisation / translation / Spanish receiving-side acceptance / substitute evidence.
The remaining gap is identified as the need for a certain reform, new legislation, or an instruction to address it. The proposed solutions requests are mapped to specific institutions and competent authorities.
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Existing Spanish Documentation Mechanisms and a Proposed Generalized Travel-Document Solution
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Authentication, Apostille, and Evidentiary Substitution of Belarusian Public Documents in Spain
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Access to Belarusian Public Documents in Spain
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Common proposal mechanism
The document-by-document Priority 1 and Priority 2 batches below are implementation modules of one common solution architecture.
The general mechanism and its institutional-action layer are linked in the two cards immediately below.
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Generalised Solution — common solution architecture
Solution architecture by streams — Spain/Belarus documentary gap | 22 September 2026
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Institutional Request — proposal & authorities
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Document by Document Solution
Priority 1
Criminal Record
P1.1 — Pilot solution — Belarus criminal-record evidence in Spain | 22 September 2026
Travel and Return Documents
Civil Status Documents
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Document by Document Solution
Priority 2
A — Birth, child and citizenship
P2-A1 — Belarus/BSSR birth certificate | 22 September 2026
P2-A2 — Spanish birth / child born in Spain | 22 September 2026
P2-A3 — Determination of Belarusian citizenship | 22 September 2026
P2-A4 — Birth certificate outside nationality | 22 September 2026
P2-A5 — Death certificate / death-record information | 22 September 2026
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B — Education and qualifications
P2-B1 — University diploma | 22 September 2026
P2-B2 — Academic transcript / detailed certificate | 22 September 2026
P2-B3 — Diploma/transcript for employment and professional access | 22 September 2026
P2-B4 — Temporary-protection academic documents | 22 September 2026
P2-B5 — Missing qualification evidence under recognised international protection | 22 September 2026
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C — Regulated professions
P2-C1 — Medicine | 22 September 2026
P2-C2 — Nursing | 22 September 2026
P2-C3 — Pharmacy | 22 September 2026
P2-C4 — Physiotherapy | 22 September 2026
P2-C5 — Regulated teaching | 22 September 2026
P2-C6 — Architecture | 22 September 2026
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D — POA, representation and notarial access
P2-D1 — Power of attorney for Belarus use | 22 September 2026
P2-D2 — Spanish administrative representation versus Belarus-use POA | 22 September 2026
P2-D3 — Remote Belarusian notarial actions | 22 September 2026
P2-D4 — Electronic appeal / evidence of attempted access | 22 September 2026
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E — Transport, property and ownership
P2-E1 — Belarus driving licence | 22 September 2026
P2-E2 — Vehicle registration/deregistration/disposal in Belarus | 22 September 2026
P2-E3 — Belarus real-estate registration/disposal from abroad | 22 September 2026
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Since 2023, Belarusian nationals residing outside Belarus have faced significant practical barriers to obtaining or renewing Belarusian passports through diplomatic and consular channels. For those lawfully residing in Spain, this can create a documentary gap: their nationality and legal residence continue to exist, while their national passport may expire and cannot reasonably be replaced. The consequences extend beyond travel and may affect immigration procedures, identification, access to public documents, authentication requirements and professional or personal mobility. Spain has already recognized part of this problem through its January 2026 administrative instruction allowing expired Belarusian passports to be accepted for immigration procedures and TIE (foreigner residence cards) issuance.
The Belarusian Documentation Gap in Spain is a structural problem arising when a Belarusian national remains lawfully resident and identifiable in Spain but cannot effectively obtain valid national identity or travel documentation from Belarusian authorities abroad. Spain has introduced a partial administrative response by accepting expired Belarusian passports for specified immigration procedures, but separate gaps may remain in travel documentation, administrative identification, access to Belarusian public documents, and authentication or apostille requirements. This policy issue examines whether existing Spanish and EU legal mechanisms can provide a coherent, predictable and proportionate framework for persons affected by this situation, without conflating identity, residence, travel and document-authentication functions.
How should Spain's administrative and documentary framework respond when a Belarusian national lawfully residing in Spain is unable to obtain or renew valid Belarusian identity or travel documents, while preserving legal certainty, effective access to administrative procedures and international mobility?