Memorandums

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MEMO I

Existing Spanish Documentation Mechanisms and a Proposed Generalized Travel-Document Solution

MEMORANDUM I — Addressing the Documentary Gap for Belarusian Nationals Lawfully Residing in Spain Who Are Unable to Obtain or Renew a Valid National Passport

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MEMO II

Access to Belarusian Public Documents in Spain

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MEMO III

Authentication, Apostille, and Evidentiary Substitution of Belarusian Public Documents in Spain

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Context

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.

Executive Summary

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.

Research Question

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?

Sub-questions

What is the current legal and administrative framework applicable to Belarusian nationals with expired passports in Spain?
What existing Spanish mechanisms may provide alternative or substitute documentation for international travel?
What evidentiary standards should apply when inability to obtain or renew a Belarusian passport must be demonstrated?
How should Spanish authorities address Belarusian public documents that cannot reasonably be obtained from Belarus?
How should authentication and apostille requirements operate where access to the underlying document or competent authority is objectively unavailable?
What solutions have been adopted by other EU Member States, and which elements could be incorporated into Spanish administrative practice?
What administrative framework could provide a consistent, transparent and legally sustainable response to the documentation gap?