For Spain’s startup visa, the business plan is assessed by the state agency ENISA.
It checks three things: how innovative the project is, whether it can scale and whether its economics add up.
The financial section must show investment and funding sources for the next 18–24 months and a four-year forecast. All data must be verifiable and consistent across sections.
The startup visa is the residence permit for entrepreneurs under Law 14/2013 (autorización de residencia para emprendedores), and it is not granted without a favourable ENISA report on the project.
This article is not about the visa procedure but about the project’s economics: what exactly ENISA looks at in the business plan, which numbers the form will ask for and how to prepare a financial model that survives the review.
The procedure, documents and filing are covered in detail by our partner Relotus — links below.
How the project review works
- Who decides. The application is filed electronically with the Large Companies and Strategic Groups Unit (Unidad de Grandes Empresas y Colectivos Estratégicos, UGE) of the Ministry of Inclusion. UGE itself asks ENISA for a report on the project. The report is mandatory and ENISA has 10 working days to issue it (arts. 69 and 70 of Law 14/2013).
- What a favourable report needs. The activity must be innovative and/or of special economic interest for Spain (art. 70.1).
- What the permit gives. The right to live in Spain and run the business for 3 years, renewable for 2 more, with permanent residence possible after 5 years (art. 69.1).
- How the project description is prepared. The founder fills in a form in the private area of ENISA’s website. ENISA’s guide says it plainly: “we don’t know your project” — the clearer and more concise the information, the easier the assessment, and the data must be truthful and verifiable.
Besides the project, the law sets general requirements: health insurance, no criminal record and sufficient funds for yourself and your family during residence (art. 62.3).
That is a separate check, and those funds do not replace investment in the project. Documents and filing: Spain startup visa at Relotus.
The law’s three criteria and what lies behind them
Article 70.2 of Law 14/2013 names three assessment criteria. ENISA’s guide breaks them down into specific questions:
| Legal criterion | What ENISA looks at | What to prepare |
|---|---|---|
| The founder’s profile and involvement; with several partners, each one’s contribution | The team’s industry and management experience, partners’ experience in other companies, their financial standing | Roles, years of experience, evidence (LinkedIn, documents); shareholding structure |
| The business plan: project, product or service, and financing including required investment and sources | Business model, stage, market, competitors, suppliers, customers, investment and funding plan | Revenue model, an 18–24-month investment plan, funding scheme, four-year forecast |
| Added value for the Spanish economy, innovation, investment opportunities | The project’s innovation and scalability | Evidence of novelty, a calculation of growth without proportional cost growth, jobs |
Innovation: how ENISA checks it
There is a shortcut: meeting just one objective criterion is enough for innovation to be accepted. According to ENISA’s guide, these are:
- public support for R&D or innovative entrepreneurship projects in the last three years without the funding being revoked;
- an award or recognition as an innovative company (winner or finalist) at least at regional level;
- a binding reasoned report from the Ministry of Science on a high degree of innovation (under arts. 35 and 39 of the Corporate Income Tax Act);
- social security contribution rebates for employing researchers;
- the Innovative SME seal (Sello Pyme Innovadora) or AENOR certificates for young and small innovative companies and R&D management systems.
Without any of these, innovation is shown in one or more ways:
- patents and other rights — software, know-how (trademarks and trade names do not count): at least filed, preferably granted, directly linked to the business;
- own technology — R&D spending of at least 15% of the company’s total costs over the last two years (or the last year for companies under two years old);
- new processes — a new or significantly improved production or delivery method in a territory or sector;
- a new product or service — new or significantly improved for the territory or sector;
- a different business model — a feature that makes the product unique and gives a clear edge over competitors.
Supporting documents can be attached to each point, and they should be. “Our product is innovative” without evidence is worthless.
The financial model is evidence here too: 15% R&D spending is a budget line ENISA can check against the forecast.
Scalability: eight questions about the project
ENISA assesses special economic interest for Spain through scalability — the ability to grow without a proportional increase in resources. The guide’s questions and what lies behind them in numbers:
- Market attractiveness — demand growth, sensitivity to the economic cycle, entry barriers, level of competition. Show the market size and why the product is in demand.
- Company stage — whether the product is on sale and since when, or how long until it is.
- Business model — the activity and revenue model, the company’s history, the purpose and breakdown of investment, its calculation and funding sources, the four-year forecast.
- Competitors — direct and potential, their estimated market share and how you differ.
- Team — industry and management experience. ENISA may check the data against LinkedIn and other sources.
- Shareholders — their experience in other companies, involvement and financial standing. A professional investor in the capital (fund, venture capital firm, business angel) is flagged separately.
- Suppliers — key suppliers and how easily they can be replaced.
- Customers — whether there are any, their concentration, revenue from key customers in the last year, repeat business and seasonality, contract length, customer acquisition cost.
Note the last point: customer acquisition cost, repeat sales and seasonality are unit economics. ENISA asks about them directly, and the answers must match the financial model.
The financial section: which numbers the form will ask for
In the “Business model” section ENISA’s guide asks not just for a forecast but for a linked set of numbers:
- Purpose of the investment — what the money is for, what it costs, how it will be funded, how many jobs it creates, start and end dates.
- Investment breakdown — the budget for tangible and intangible assets, and the share for working capital and other items.
- Investment calculation — a schedule covering at least 18–24 months, consistent with the breakdown.
- Funding scheme for the same 18–24 months — how much partners contribute through capital increases and how much comes from the company’s own cash flow.
- A forecast for each of the next four years, plus actuals for the last closed year if there is one.
What a funding scheme looks like: an illustrative example
| Use | Amount over 24 months, € | Source |
|---|---|---|
| Product development (intangible assets) | 60,000 | Founders’ capital contribution |
| Equipment (tangible assets) | 15,000 | Founders’ capital contribution |
| Working capital: salaries and marketing until break-even | 45,000 | Business angel (capital increase) — 30,000; company cash flow — 15,000 |
| Total | 120,000 | Capital — 105,000; own cash flow — 15,000 |
The figures are illustrative; the logic is what matters.
Every amount in the scheme appears in the investment budget, every source appears in the capital plan or the cash flow forecast, and money “from cash flow” appears no earlier than revenue appears in the model.
How to bring an investor into an SL’s capital: How to structure startup investment in Spain.
What to show in the four-year forecast
ENISA’s form sets a four-year table. To fill it in without contradictions, the model should give at least the following for each year:
- revenue and its drivers — customers, average ticket, repeat purchases;
- costs and result — including staff, marketing and taxes;
- headcount, i.e. jobs created;
- investment and funding sources by year;
- cash flow showing there is enough money until break-even.
How to build such a model: Financial model: what it is and how to build one; how to check it before filing: How to check a financial model.
Common mistakes in the project’s economics
- Numbers differ between sections. One amount in the purpose of investment, another in the breakdown, a third in the funding scheme. ENISA’s guide explicitly requires the calculation to match the breakdown.
- No named source of money. There is investment but nobody providing it — or revenue covers everything from month one while the product is still in development.
- Scalability without a calculation. “We will grow exponentially”, while in the model staff and costs grow in proportion to revenue — so there is no growth without cost growth.
- Innovation without evidence. No patents, R&D spending, or differences in product or processes — only wording.
- Unverified team. Experience does not match public profiles or is unrelated to the project’s industry.
- A template business plan. Generic market talk without the project’s competitors, customers and suppliers. ENISA does not know your project and will not fill in the gaps for you.
Who does what
The startup visa procedure — the document package, filing with UGE, family members, renewals — is handled by our partner Relotus.
We handle the project’s economics: a financial model that stands up to ENISA’s questions, and an independent viability assessment before filing.
If the project will soon go to an investor too, the same model will be needed there, so it is worth building once and properly.
Frequently asked questions
Who reviews the business plan for Spain’s startup visa?
The state agency ENISA. UGE, which handles the application, itself requests a mandatory report on the project from ENISA, which has 10 working days to issue it (art. 70 of Law 14/2013).
What period should the financial forecast for ENISA cover?
Investment and its funding for at least 18–24 months, and a forecast for each of the next four years, plus actuals for the last closed year if available.
What does ENISA consider an innovative project?
One objective criterion is enough — for example, public R&D support in the last three years, an award as an innovative company or the Pyme Innovadora seal. Otherwise innovation is shown through patents, own technology with R&D spending of at least 15%, or a different product, process or business model.
Do you need a company already registered in Spain?
No. ENISA’s form covers both cases: if there is no company yet, you give the project name, the activity and the province where it will operate.
How much must you invest in the project for a startup visa?
The law sets no fixed investment amount for the project. The amount should follow from the investment plan and have clear sources. Separately, the law requires sufficient funds for the founder’s and family’s living costs (art. 62.3).
Can the same business plan serve the visa and an investor?
The financial model, yes — and that is the best approach: investors and ENISA ask similar questions. The plan text for ENISA is shorter and follows the sections of their form.
Key points about the business plan for a startup visa
- ENISA assesses the project: innovation, scalability and the financial section.
- Investment and its sources for 18–24 months, a four-year forecast; numbers consistent across all sections.
- Innovation and scalability are proven with facts and calculations, not wording.
- ENISA asks directly about acquisition cost, repeat sales and seasonality — that is unit economics.
- The visa procedure is Relotus’s job; the project’s economics and financial model are ours.
Sources
- Ley 14/2013 de apoyo a los emprendedores — arts. 62, 69, 70 (as amended by Law 28/2022).
- ENISA: Autorización de residencia para emprendedores. Guía para cumplimentar el formulario.
The funding scheme example is illustrative. Legal provisions and ENISA’s guide checked as of 3 October 2026.


