Georgian fighter Ilia Topuria had spent nearly a decade training on Spanish soil when the Council of Ministers signed his Royal Decree. He didn’t pass any culture exam or wait the standard ten years of residency. What he did demonstrate was a sporting career built entirely in Spain, with the UFC world championship as its crowning achievement. His case perfectly illustrates what a letter of naturalization is: not a bureaucratic formality, but a discretionary recognition that the Spanish Government grants — or denies — without any obligation to explain itself.
If you’re here because you think your situation might justify one, you need to know the real numbers first. When you look at the data directly, they tell a very different story than what most generic articles on this topic suggest. Let’s start with the basics.
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What Is the Letter of Naturalization: The Most Exceptional Route in Spanish Law
The letter of naturalization is governed by Article 21 of the Civil Code. Its legal definition is clear, direct, and — at the same time — the reason it generates so much confusion:
“Spanish citizenship may be acquired by letter of naturalization, granted at the Government’s discretion by Royal Decree, when the applicant can demonstrate exceptional circumstances.”
Three words capture the full complexity of this legal instrument: discretionally, Royal Decree, and exceptional circumstances. Discretionally means the Government can grant or deny it without following a regulated administrative procedure. Royal Decree means the final decision is made by the Council of Ministers and published in the Official State Gazette (BOE). And exceptional circumstances means there’s no closed list of qualifying situations — every case is evaluated individually.
This has one very important practical consequence. It is not an enforceable right. You can file a petition, make a brilliant case, and submit impeccable documentation — and the Government can still say no, without detailed explanation. This discretionary nature sets the letter of naturalization radically apart from every other path to Spanish citizenship.
If you want a full overview of all available routes, our guide on types of Spanish citizenship and their requirements gives you a complete map before you decide which path to take.
Letter of Naturalization vs. Residency-Based Citizenship: The Key Differences
The comparison with residency-based citizenship is inevitable — they’re the two main naturalization routes for people without direct family ties to Spain. But they work in completely different ways.
| Criteria | Citizenship by Residency | Letter of Naturalization |
|---|---|---|
| Residency requirement | Mandatory (10 years in general, 2 for Latin Americans) | Not required |
| CCSE and DELE exams | Yes, mandatory | Not required |
| Grant criteria | Rule-based: you either qualify or you don’t | Discretionary: the Government decides freely |
| Resolution timeline | No fixed deadline, but follows administrative procedure | No legal deadline of any kind |
| Right to appeal | Yes, with broad grounds | Limited by the discretionary nature of the decision |
| Grant rate | Varies by profile, but predictable | Below 8% in the 2019–2024 period |
The most obvious advantage of the letter of naturalization is that it eliminates the residency requirement and the language exams. The downside: nobody can guarantee you anything.
Who Actually Gets It: Real-World Profiles
The law doesn’t define what an “exceptional circumstance” is. What does exist is an observable pattern in the Royal Decrees published in the BOE over the years. These are the profiles that have historically been granted citizenship through this route.
Athletes Who Represent or Will Represent Spain
This is the best-known profile and, outside of humanitarian cases, probably the most common. The implicit requirement isn’t simply being a public figure: the athlete must have, or have a realistic prospect of having, a formal tie to the Spanish national team. Lorenzo Brown (basketball), Nikola Mirotić (basketball), and Sergi Ibaka are examples of a well-established practice in which sports federations actively drive their athletes’ applications.
Topuria is the most recent and high-profile case, but far from the only one. At the 2024 Paris Olympics, more than a dozen athletes competing under the Spanish flag had a letter of naturalization in their pocket.
Artists, Scientists, and Intellectuals of International Standing
Pianist James Rhodes, ballet dancer Maya Plisetskaya, writer Mario Vargas Llosa. People whose careers have a cultural dimension unmistakably linked to Spain. In these cases, the Government weighs both objective merits and the international visibility of the person.
There’s no defined minimum threshold, but the administrative track record makes one thing clear: the reach has to be significant. An artist with regional recognition is unlikely to succeed through this route.
Humanitarian Grounds: Victims, Refugees, and Extreme Vulnerability
This is the largest group in absolute terms. In 2023, 98 of the 108 letters of naturalization granted were on humanitarian grounds. Victims of terrorism, people persecuted for political or religious reasons, stateless individuals in situations of extreme vulnerability.
This category is, paradoxically, the one that offers the most realistic options for people without a public profile — but it demands very solid documentary evidence of the situation of need.
Historical Ties: Sephardic Jews and the International Brigades
After Law 12/2015 closed to new applicants, descendants of Sephardic Jews who didn’t manage to apply for ordinary citizenship have, in theory, the letter of naturalization as their only remaining option. In practice, it’s an extremely difficult route that requires very robust documentary evidence and rarely succeeds for new applications.
The International Brigades situation is different and more recent. In 2025, 206 people received the letter of naturalization — the vast majority being descendants of International Brigades fighters who served in the Spanish Civil War, covered under a transitional provision of the Democratic Memory Law. This was a one-time phenomenon tied to a specific piece of legislation, not an open-ended route for any applicant.
What If You Don’t Have a Public Profile? The Reality You Need to Know Before Applying
Here’s the data point no competing article publishes: between 2019 and June 2024, the Ministry of Justice received 2,629 letter of naturalization applications. Grants during that same period totaled 192. That’s a success rate below 8%.
This doesn’t mean you should rule it out if you have a genuinely exceptional circumstance. It means you need to be honest with yourself before investing time and money in the application. If you’re not an elite athlete, an internationally recognized artist, or someone in a situation of extreme vulnerability — and if there’s a viable alternative available to you, like citizenship by option — that’s probably the more appropriate route.
Do you want a expert consultation? Contact us and we will help you.
How to Apply for the Letter of Naturalization: Step by Step
The Exceptional Circumstances Dossier: The Piece That Decides the Outcome
The formal application is the container. The exceptional circumstances dossier is the actual content the Ministry of Justice will evaluate. And this is where most applicants fall short.
A strong dossier doesn’t just claim that exceptional circumstances exist. It proves them with objective, verifiable, and hard-to-dispute documentation. For an athlete, that means international titles, contracts with Spanish federations, and accreditation from the national team. For a persecution victim, official documentation proving their situation, reports from recognized organizations, prior administrative decisions. For a scientist, publications in indexed journals, institutional recognition, affiliations with leading Spanish research entities.
The narrative matters, but the evidence drives the decision. A solid dossier anticipates the Ministry’s potential objections and addresses them before they’re raised.
Required General Documentation
- Official application form (modelo 790-026), available on the Ministry of Justice website or in person at Civil Registry offices
- Certified birth certificate, apostilled and — where applicable — translated by a sworn translator
- Criminal record certificate from your country of origin, apostilled and translated (applicants over 18 only)
- For residents in Spain over 18: criminal record certificate from the Central Criminal Records Registry
- Specific documentation proving the exceptional circumstances invoked
- If the applicant is married: marriage certificate and, if the spouse is Spanish, their certified birth certificate
- Any other document that strengthens the exceptionality argument
One important detail: you don’t need to be residing in Spain to file the application. Applicants abroad can do so through the relevant Spanish consulate, which will forward the file to the Sub-Directorate General of Nationality and Civil Status in Madrid.
Where to Submit the Application
The application is addressed to the Sub-Directorate General of Nationality and Civil Status, under the Directorate General of Legal Security and Public Faith at the Ministry of Justice. You can submit it at any of these locations:
- Public Service Office of the Ministry of Justice (Madrid)
- Civil Registry of your place of residence
- Any post office via administrative mail
- Registries of any Public Administration (Central Government, Autonomous Communities)
- Spanish consulate if you reside abroad
For more information on the official procedure, you can go directly to the Ministry of Justice page on the letter of naturalization.
What Happens After You Submit
Once your application is registered, the Ministry of Justice opens the file for review. This involves gathering reports from the National Police Directorate and — in cases with international visibility — from the Ministry of Foreign Affairs. The file then moves up to the Council of Ministers, which makes the final decision. If the outcome is favorable, a Royal Decree is published in the Official State Gazette.
After the grant, you have 180 days to complete the process: swear an oath or pledge of loyalty to the King and compliance with the Constitution, renounce your previous citizenship (unless you’re a national of a Latin American country, Andorra, the Philippines, Equatorial Guinea, or Portugal — in which case you can keep dual citizenship), and register in the Spanish Civil Registry. If you have questions about compatibility with your current situation, our guide on dual Spanish citizenship covers the most common questions.
Timelines and Real Success Rate: The Data Nobody Else Publishes
There’s no legal deadline for resolution. The letter of naturalization isn’t subject to general administrative procedure rules, which means the Council of Ministers can take months — or, in practice, years.
The factors that affect the pace are the Ministry’s workload at any given time, the complexity of the file, and especially whether there’s concrete institutional backing behind the application — the usual situation for athletes pushed forward by their federations. A private individual’s application, without prior institutional support, can wait indefinitely.
For context on Spanish citizenship timelines in general, our guide on how long Spanish citizenship takes has updated data to help you set realistic expectations. And if your application is already in progress, you can learn how to check the status of your citizenship application to track where things stand.
For a clearer picture of the real volume of grants, the data journalism work by Civio on letters of naturalization documents every grant since 1994 in detail, organized by recipient and year.
If You’re Denied: Real Options Before the National Court
A denied letter of naturalization can be appealed before the National Court (Audiencia Nacional) within two months of receiving the decision. You can also file an administrative law appeal if the resolution takes too long and you decide not to keep waiting.
This is where the discretionary nature of the decision complicates things. The National Court can void the resolution if it finds procedural defects or manifestly arbitrary reasoning — but it cannot force the Government to grant citizenship. What it can do is order that the file be re-evaluated. That’s an important distinction that shapes the strategy behind any appeal.
Which is why building a strong application from the start is always more efficient than relying on litigation to fix mistakes later.
If your situation doesn’t fit the typical profiles for a letter of naturalization but you have family ties to Spain, you may have stronger options through other routes. At ILLAY Legal, we analyze each case individually to identify the most efficient path with the strongest realistic chance of success. Tell us about your situation.
Frequently Asked Questions: Spanish Citizenship by Letter of Naturalization
How many letters of naturalization does Spain grant per year?
The number varies widely depending on the year and political circumstances. In 2023, 108 were granted, 98 of which were on humanitarian grounds. In 2025, the figure rose to 206, mostly under a transitional provision tied to the International Brigades. Excluding one-off mass grants, the typical range is between 10 and 120 per year.
Do you need to live in Spain to apply for the letter of naturalization?
No. Residency in Spain is not a requirement to apply. You can file from abroad through the relevant Spanish consulate, which will forward your application to the Sub-Directorate General of Nationality and Civil Status in Madrid. This is a fundamental difference from residency-based citizenship.
How long does it take to get a decision on a letter of naturalization?
There’s no legal deadline. Since the process falls outside general administrative procedure rules, the Council of Ministers can resolve the case in months — or go years without resolving it at all. Cases backed by sports federations or institutional support tend to move faster. Individual applications without that backing can wait indefinitely, and the silence doesn’t legally constitute a denial.
What circumstances are considered exceptional for the letter of naturalization?
The law provides no closed list. In practice, the Government has granted letters of naturalization to elite athletes representing Spain, artists and intellectuals of international standing, victims of terrorism, refugees and people in situations of extreme humanitarian vulnerability, Sephardic descendants in residual cases, and descendants of International Brigades fighters. Any other genuinely exceptional situation is theoretically possible, but it must be argued and documented with real substance.
Can I keep my current citizenship if I’m granted the letter of naturalization?
It depends on your nationality. If you’re a national of a Latin American country, Andorra, the Philippines, Equatorial Guinea, or Portugal, you can keep both. In all other cases, Spanish law requires you to renounce your previous citizenship as a condition for completing the acquisition. That renunciation is formalized at the time of registration in the Civil Registry.
What can I do if my letter of naturalization is denied?
You can file an administrative law appeal before the National Court (<em>Audiencia Nacional</em>) within two months of receiving the denial notice. That said, since this is a discretionary act, the Court can order that your file be re-evaluated — but it cannot compel the Government to grant citizenship. The real leverage is in building a strong file from the start, not in counting on an appeal to fix gaps later.
Is the letter of naturalization the same as naturalization by residency?
Not exactly. Residency-based naturalization follows a regulated administrative procedure with clear requirements and defined timelines. The letter of naturalization is also technically a naturalization act, but it’s discretionary and exceptional in nature — with no fixed procedure and no resolution deadline. Both routes result in the same Spanish citizenship, but they work in completely different ways and are designed for very different profiles.
