Last updated: 30-Sep-2026. Salamanca, Spain
Update: Added separate municipal and other domestic-identification implementation requests and a supplementary schedule. The existing three-part travel and return proposal is retained.
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Preserve the Joint Instruction of 19 January 2026 as a limited domestic-use mechanism for expired Belarusian passports in its actual scope, and add a separate category-based Spanish travel-document route for lawfully resident Belarusian nationals who objectively cannot obtain a usable national travel document. The proposed route must operate alongside, not replace, Articles 210–211 and the special regimes for international protection and statelessness, and it must not turn passport acceptance for an administrative procedure into a claim of travel entitlement.
Why a separate solution is needed: some Belarusian nationals live lawfully in Spain but cannot obtain a usable national travel document either by attending the required procedure in Belarus or through an accessible consular route abroad. They do not all fall within the special travel-document regimes for international protection. The proposal identifies this documentation need separately: it does not require a person to seek asylum merely to obtain a travel document, change their nationality or create a new residence status.
These proposed provisions have not been adopted and do not establish an available application procedure.
Problem: an expired Belarusian passport may work for residence paperwork but not for travel, and can also block access to a cédula.
Solution: create three outputs: (1) an official Spanish decision confirming that the person cannot obtain or renew a Belarusian travel document; (2) a reusable Spanish travel document for lawful residents; and (3) a Spanish consular replacement/return document if it is lost or becomes unusable abroad.
Authority: Dirección General de Gestión Migratoria (DGG Migratoria); Comisaría General de Extranjería y Fronteras (CGEF); Secretaría de Estado de Migraciones / Subdirección General de Régimen Jurídico; Dirección General de la Policía; Ministerio de Asuntos Exteriores, Unión Europea y Cooperación (MAEUEC).
Additional domestic implementation: section 6.8 asks for clear municipal application of the existing padrón criterion and a procedure-specific assessment of other identity requirements. These two actions do not renew the Belarusian passport or create travel rights; they accompany, rather than replace, the travel proposal.
IBDED_Memo_I_institutional_action_plan.pdf
IBDED_Memo_I_implementation_supplement.pdf
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This document is an analytical memorandum. It does not assert that Belarusian nationals have an automatic right to a Spanish título de viaje. Its purpose is to identify the mechanisms already provided by Spanish law for addressing the documentary gap, to assess the scope of the Belarus-specific administrative response adopted in 2026, to identify the remaining travel-document gap, and to propose an additional generalized Spanish mechanism for travel purposes alongside the existing individual procedure under Articles 210 and 211.
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Contents
For the purposes of this memorandum, “documentary gap” is a descriptive term for a situation in which a foreign national retains the nationality of the State of nationality and legally resides ****in Spain, but lacks a valid national identity or travel document required for a particular administrative or travel purpose and is objectively unable to obtain or renew that document through the competent authorities of the State of nationality.
The term does not constitute a legal status. It must not be treated as synonymous with statelessness, international protection, irregular residence, or entitlement to a Spanish título de viaje.
The memorandum distinguishes between: (i) evidence of identity, nationality and origin; (ii) documentation used in immigration procedures; (iii) a Spanish título de viaje; and (iv) the ability to leave and re-enter Spain or another State. The legal consequences of each must be assessed under the applicable provision.
Following changes to the Belarusian system for documenting citizens abroad, Belarusian nationals outside Belarus may face an inability to obtain or renew national documentation through Belarusian diplomatic or consular authorities abroad. The precise legal and practical consequences depend on the type of document and the circumstances of the individual.
The problem has several distinct legal dimensions: (a) citizenship, (b) establishment of identity, (c) lawful residence in Spain, (d) the ability to use an expired national document, (e) the right to international travel, and (f) the ability to return to Spain. They are not the same legal question and must be analyzed separately.
Spanish law contains individual documentation mechanisms and also provides, through Article 210(12) of Royal Decree 1155/2024, a statutory basis for a ministerial order concerning the use of expired identity or travel documents of specified nationalities in defined administrative procedures where a generalized inability to renew those documents has been established. Article 210(12) should therefore be understood as an enabling provision rather than as the ministerial order itself. In addition, Spain adopted a Belarus-specific Joint Instruction dated 19 January 2026 concerning the use of expired Belarusian passports in specified immigration procedures.
The existing administrative instruction addresses a limited administrative and residence-documentation problem. It does not provide a generalized travel-document solution.
A central implementation gap arises at the intersection of that Instruction and the individual cédula-de-inscripción route. The Instruction gives an expired Belarusian passport limited procedural validity for specified immigration/TIE purposes because Belarusian nationals cannot generally renew their passports abroad. Article 210, by contrast, requires an individual assessment of whether the person can be documented by the authorities of another country and expressly allows expired documents to be used as evidence of identity. If the domestic administrative acceptance of the expired passport is treated as proving that the person is already effectively “documented”, access to the cédula route may be refused even though the same person still lacks a usable national travel document and cannot obtain a new one from Belarus. That produces the core dead end addressed by this memorandum: documented enough for limited Spanish administrative purposes, but potentially treated as too documented for cédula while still remaining without a usable national travel document. This memorandum does not treat that reasoning as established nationwide practice. Each refusal must be assessed against its stated grounds; the underlying distinction between domestic identification and access to a usable national travel document remains.
The principal provisions examined in this memorandum are Article 34(2) of Organic Law 4/2000, Articles 210 and 211 of Royal Decree 1155/2024, and the Joint Instruction on procedures concerning Belarusian nationals in Spain, dated January 2026.
Article 210(12) is relevant to the administrative side of the documentary problem: it provides for a ministerial order to authorize specified administrative procedures to be carried out with expired identity or travel documents of nationals of particular countries where a generalized inability to renew those documents has been established.
The remaining travel problem is distinct. Belarusian nationals who cannot obtain or renew a valid Belarusian passport may lack a practical travel document despite retaining their Belarusian nationality. This memorandum therefore proposes an additional generalized travel mechanism based on predefined eligibility criteria for the affected category, while preserving the existing individual travel-document procedure under Articles 210 and 211.