Spain Digital Nomad Visa: Do Freelance Clients Who Are Private Individuals Count? (2026)

No. If you apply for Spain's Digital Nomad Visa as a freelancer, the clients you use to qualify must be companies. Income from private individuals does not count.

The rule comes from the law itself. Article 74 ter d) of Law 14/2013 requires freelancers to prove a commercial relationship with "one or more companies not located in Spain" for at least the last three months. Article 74 ter a) adds that each of those companies must show at least one year of real and continuous activity.

A private individual cannot meet either condition. That income cannot support your application or count toward the €2,849 monthly threshold for 2026. Hoply's legal team confirms this reading.

That does not always put the visa out of reach. If you are a coach, tutor, therapist, designer or consultant with private clients, you may still have a way forward, and this guide explains each option.

Key Takeaways

• Spain's Digital Nomad Visa requires freelance clients to be companies located outside Spain (Art. 74 bis.1 and Art. 74 ter d) of Law 14/2013).
• Each client company must prove at least 1 year of real and continuous activity with an official registry certificate.
• Your relationship with each client company must be at least 3 months old on the day you apply.
• Only income from company clients counts toward the €2,849 gross monthly threshold for 2026.
• One company client is enough. The law sets no minimum number of clients.
• If your clients are individuals, the realistic options are to qualify on company clients alone, contract with an intermediary company, apply through your own company, or use a different residence route.

Table of Contents

• Can You Get Spain's Digital Nomad Visa With Individual Freelance Clients?
• What the Law Requires From a Freelancer's Clients
• Why Private Individual Clients Cannot Be Documented
• Mixed Client Base: Company Clients and Private Clients
• Options If Most of Your Freelance Clients Are Individuals
• How This Differs From Fiverr and Upwork Income
• UK Sole Traders With Private Clients
• Mistakes to Avoid Before You Apply
• Check Your Client Base Before You Apply

Can You Get Spain's Digital Nomad Visa With Individual Freelance Clients?

Not on that income alone.

Definition: Spain's Digital Nomad Visa, officially the residence authorisation for international teleworking (teletrabajo de carácter internacional), allows a non-EU national to live in Spain while working remotely "for companies located outside national territory", using only computer, telematic and telecommunication systems. The definition is in Article 74 bis.1 of Law 14/2013, added by Law 28/2022, the Startups Law.

The word that matters is companies. The law does not say "clients" or "customers".

For freelancers, the requirement is a commercial relationship (relación mercantil) with one or more companies. A commercial relationship is a professional services arrangement between you and a business, documented with a contract, invoices and matching payments.

A freelance UX designer who invoices a UK design agency fits the definition. A yoga teacher who sells online classes directly to 60 private students does not, however much she earns.

For every other requirement on this route, see our freelancer guide to Spain's Digital Nomad Visa.

What the Law Requires From a Freelancer's Clients

Four client-related requirements apply to every freelancer application, and each one is tied to a specific document.

The official UGE documentation for initial applications uses the same wording. It asks for proof of the relationship "with the foreign company or companies" and for an official certificate from the commercial registry, or its equivalent, in the company's country.

Even the rule on Spanish work is written this way. A freelancer may work for "a company located in Spain" as long as that work is no more than 20% of total professional activity (Art. 74 bis.1).

Why Private Individual Clients Cannot Be Documented

The obstacle is practical as well as legal.

For every client you present, the UGE (Unidad de Grandes Empresas y Colectivos Estratégicos, the unit that decides these applications) expects a registry certificate proving that the client has operated for at least one year. Companies House issues it for UK companies. In the United States it comes from the Secretary of State where the company is registered.

A private person has no such certificate. There is no registry to request it from, and nothing to apostille or translate.

Contracts and invoices do not fix this. You can hold a signed agreement and three months of bank transfers from a private client, and the application still lacks the one document the law requires about that client.

One situation is less clear: clients that are businesses but not incorporated companies, such as sole traders or partnerships. Neither the law nor the UGE's published documentation addresses them directly. It depends on whether the client can produce an official registry certificate, or an equivalent official document, showing one year of activity. That needs a case-by-case review before you rely on it.

Mixed Client Base: Company Clients and Private Clients

If you have both, the rule is simple: only income from company clients counts.

The threshold for a single applicant in 2026 is €2,849 gross per month. That is 200% of Spain's minimum wage (SMI) as set by Royal Decree 126/2026. Our guide to the Digital Nomad Visa income requirements covers the amounts for family members.

Take two illustrative cases. The names and figures are invented.

Daniel is a career coach. He earns €3,400 a month from a US training company that contracts him to coach its staff, and €900 from private clients. His company income alone clears €2,849, the contract is eight months old and the company was incorporated in 2019. He can apply on the strength of the company contract.

Priya is an online tutor. She earns €1,500 a month from a UK tutoring company and €2,200 from parents who pay her directly. Her total is €3,700, but only €1,500 counts. She does not yet qualify as a freelancer.

Savings can sometimes cover a small shortfall, as the income guide explains. They do not replace the need for a qualifying relationship with a company.

Private-client income cannot be used to qualify, and the authorisation itself is defined as remote work for companies. If private clients are part of your activity and you plan to keep them, have that reviewed before you apply, not after.

There is no minimum number of clients. The law says "one or more companies", so a single company client that pays enough and meets the three-month and one-year conditions is sufficient.

Options If Most of Your Freelance Clients Are Individuals

There are four realistic options. Which one fits depends on how your work is structured today.

Qualify on Company Clients Alone

If part of your work already comes from companies, check whether that part reaches €2,849 a month on its own.

If it nearly does, growing one company contract may be simpler than restructuring everything. Keep the timing in mind: each company relationship needs three months of history, with invoices and matching bank payments, before you apply.

Contract With a Company That Serves Your Clients

In some professions the same work can be delivered through a business, such as a tutoring company, a coaching or training provider, a clinic group or an agency. The company contracts you, invoices its own customers and pays you. Your client is then the company.

This only works if it is real. The contract must be a genuine professional services agreement, the company needs one year of activity and the relationship needs three months of history.

Apply Through Your Own Company

If you already run your business through a company, for example a UK limited company or a US LLC that sells courses or sessions to individuals, the business-owner route may fit. On that route the relationship the UGE examines is the one between you and your own company, not the one between you and each customer.

The UGE's documentation asks owners with effective control for proof of ownership, the company's latest corporate tax return, evidence of investment in productive assets and a social security report showing its employee history. The company also needs at least one year of real activity, so a newly formed company does not work.

Whether this route fits a business that sells to individuals depends on the case, and Hoply's lawyers assess it one by one. Our business owner guide and our article on how the UGE decides between the employee and business-owner routes cover the details.

If you are not sure which of these options matches your situation, a free case evaluation lets Hoply's Spain-based lawyers look at your client base and tell you which route is realistic before you spend money on documents.

Consider a Different Residence Route

If none of the above fits, the Digital Nomad Visa may not be the right permit for you. Spain's general immigration rules include residence and work authorisations for self-employed activity, with their own requirements. Our comparison of autónomo status and the Digital Nomad Visa is a good starting point.

How This Differs From Fiverr and Upwork Income

Platform income is a related question with a different problem.

On Fiverr or Upwork your contract is with the platform, not with the end client, so the difficulty is documenting a direct relationship with a registered company. With private clients the relationship is direct, but the client is not a company.

The solution is the same in both cases: a direct contract with a registered company outside Spain that has at least one year of activity and three months of history with you. The freelancer guide has a section on platforms.

UK Sole Traders With Private Clients

The rule is the same for every nationality. Nothing in Law 14/2013 or in the UGE's documentation sets a different standard for UK applicants.

Strong HMRC records do not change the answer. An SA302 tax calculation, a Tax Year Overview and a Self Assessment return are valuable because they prove you are registered as self-employed, which the UGE also checks. Our guide to self-employment registration proof explains how to use them.

They prove your status, not your clients' status. A personal trainer in Manchester with £60,000 of Self Assessment income from private clients has excellent tax records and no qualifying client.

If you trade through a UK limited company instead, the analysis changes. Our article on UK limited company directors and the Digital Nomad Visa is the place to start.

Mistakes to Avoid Before You Apply

• Counting total income instead of company income. Only what company clients pay you counts toward €2,849 a month.
• Assuming a signed contract with a private client is enough. The missing piece is the client's registry certificate, and a contract cannot replace it.
• Forming a company and applying straight away. The one-year activity rule applies to your own company too.
• Relabelling invoices. Changing the name on an invoice does not change who your client is. Contracts, invoices and bank payments must tell the same true story.

Check Your Client Base Before You Apply

Spain's Digital Nomad Visa is built around remote work for companies. If your freelance clients are private individuals, that income will not qualify you, but one solid company contract, an intermediary company or your own company might.

The right answer depends on who pays you, how long they have paid you and what they can document. Hoply's Spain-based lawyers review, guide and file every case, backed by a simple promise: approved or your money back.

Start with a free case evaluation. Tell us who your clients are and how you are paid, and we will tell you whether you qualify today, which route fits and what to change first if you do not.