Do Brits in Spain with Irish citizenship need to exchange their green certificates for TIEs?

The UK Embassy is urging British nationals residing in Spain to exchange their old green certificates for Tarjetas de Identidad de Extranjero (TIEs) to avoid being classified as overstayers under the European Union’s forthcoming Entry-Exit System (EES). This directive raises an important question: how does this apply to those Brits who have acquired Irish citizenship since Brexit?

In a recent communication, the British Embassy in Madrid reiterated its guidance concerning the necessity of swapping green EU residency certificates for biometric TIE cards, which serve as the official residency documents for third-country nationals. Originally issued to UK nationals living in Spain before Brexit, these green certificates (Certificados de Registro de Ciudadano de la Unión) were recognized under the Brexit Withdrawal Agreement. However, since July 2020, Spain has transitioned to issuing TIEs to UK nationals officially residing in the country.

Despite the fact that the exchange has never been mandatory, both British and Spanish authorities have increasingly encouraged UK nationals to make the switch over the past five years. The embassy’s latest warning highlights the potential risks for those who have not yet complied: “You could be treated as a tourist at the border, subject to full EES checks and potentially accused of overstaying in the Schengen Zone.”

The implementation of the EES is anticipated to begin in October 2025, signaling a critical timeline for British nationals in Spain.

For British nationals in Spain who have also obtained Irish citizenship, the situation is somewhat nuanced. An estimated six million people in the United Kingdom have at least one Irish grandparent, leading to a surge in applications for Irish passports via ancestry since Brexit. The UK’s Office for National Statistics reports that applications for Irish passports have increased tenfold over the past decade, resulting in approximately 160,000 British-Irish dual citizens.

While exact figures on British-Irish dual nationals residing in Spain are not available, it is likely that many eligible individuals have pursued Irish citizenship to sidestep the complexities introduced by Brexit. With an Irish passport, these individuals can navigate the post-Brexit landscape with greater ease, including expedited airport security processes.

Notably, those who have acquired Irish citizenship are no longer classified as third-country nationals by Spanish authorities. Consequently, British-Irish nationals in Spain holding pre-Brexit green residency certificates do not need to obtain a TIE, as this document is specifically for non-EU citizens.

However, if their old green certificates list British nationality, they are technically required to update these documents. The green certificates remain valid for EU nationals, and Spain’s Interior Ministry mandates that any changes in nationality or residency status must be reported to the local Immigration Office or Police Station.

Updating to a new green certificate does entail some bureaucratic steps, including acquiring an appointment, known as cita previa. Nevertheless, for those who have invested the effort to secure an Irish passport, it is prudent to obtain a residency document that aligns with their EU nationality.

Having a residency document that does not match one’s passport could create complications in various official processes, such as opening bank accounts, voting in EU elections, or applying for jobs. While holding dual nationality does not equate to a full change of nationality, utilizing Irish nationality in Spain to access enhanced rights should prompt British-Irish dual nationals to secure a new green residency certificate reflecting their Irish citizenship.

It is worth noting that although EU green residency certificates do not expire, EU nationals can apply for a permanent green certificate after five years of residency in Spain, which offers additional rights.