What the 2026 internship regulation in Spain means for foreign students

TL;DR

TL;DR — Since the 2023 reform (RD-Ley 2/2023), all interns in Spain — paid and unpaid — must be registered with Social Security by their host company from day one. For foreign students, this changed nothing about the visa but changed a lot about what your Convenio must include.

What the 2023 regulation actually did

Historically, unpaid interns in Spain existed in a grey zone: no salary, no Social Security cover, minimal legal protection. RD-Ley 2/2023 (in force since 1 January 2024, fully applied by 2026) closed that gap.

The core changes:

1. Mandatory Social Security registration for all interns, whether paid or not
2. Employer pays 100% of Social Security contributions for unpaid interns
3. Interns count toward the company's Social Security workforce for statistical purposes
4. A mandatory Convenio de Prácticas between university, company and intern
5. Cap on hours — 5h/day for CFGS/CFGM students, longer for university interns
6. Right to compensation for expenses in some cases

What this means for foreign students in 2026

The visa process didn't change. The paperwork on the Spanish side did. Your host company must now:

• Get your NUSS before your first day
• File your alta in the Régimen General de la Seguridad Social
• Provide a written Convenio with duties, hours, mentor, dates
• Keep proper attendance records
• File your baja (deregistration) on your last day

Ask your host company to confirm all of the above in writing — before you accept the placement.

What your Convenio must include (2026)

• Full identification of student, university, company
• Programme of activities (tasks, competencies, learning outcomes)
• Duration and daily/weekly hours
• Mentor at the company + tutor at the university
• Insurance coverage
• Confidentiality clauses if applicable
• Signatures of all three parties

Common compliance issues

• Company doesn't want to register you — walk away. This is now illegal and puts them (and you) at risk.
• NUSS not requested in time — delays your start date but doesn't cancel it.
• Hours exceed the cap — you can refuse. Your Convenio governs this, not verbal instructions.
• No named mentor — Convenio is invalid.

Impact on students already in Spain

If you were already interning under a pre-2023 Convenio, your host company had until December 2024 to migrate you to the new regime. In 2026, no active Convenio in the old regime is compliant.

Impact on the intern's experience

Practical positives:

• You're covered for workplace accidents — properly this time
• You accrue contribution days counted toward Spanish social security history (relevant if you plan to work in Spain long-term)
• You have a clearer legal record of the placement

Practical realities:

• Some smaller companies became more selective — they now pay a monthly Social Security contribution per intern (~€60/month depending on category)
• Onboarding paperwork is more rigorous — bring originals of everything

What to ask your host company before signing

• Confirm the Social Security alta will be filed before day one
• Confirm the named mentor + weekly time commitment
• Confirm hours and any compensation for expenses
• Get a copy of the Convenio in Spanish + English
• Confirm workplace accident insurance is active

Key takeaways

1. All interns — paid and unpaid — are now on Social Security from day one.
2. Your host company must obtain your NUSS and file your alta before you start.
3. The Convenio is the legal spine of the placement — read it carefully.
4. If a company resists compliance, walk. It's not worth the risk.

FAQ

Does this raise the taxes I pay? Interns still don't pay income tax on unpaid placements. Employers cover the Social Security cost.

Do I get a payslip if I'm unpaid? You get a justificante of Social Security registration. No payslip unless you're paid.

Do the new rules apply to remote interns based abroad? The Convenio law applies when the host company is Spanish. Some remote-from-abroad setups sit outside Spanish jurisdiction — clarify with your placement coordinator.

What about Erasmus+ traineeships specifically? Same rules. Erasmus+ trainees hosted by Spanish companies must be on Social Security like any other intern.