Spain’s Social Security inclusion rules for students on internships have now been in force since January 1, 2024. In 2025 and early 2026, additional official guidance and related measures have helped clarify responsibilities, contribution mechanics, and how certain Erasmus+ situations should be handled.
This 2026 update is written for universities, vocational schools, Erasmus+ coordinators, and host companies that need a clear operational view of the rules, including what is confirmed, what has evolved since 2024, and what to watch next.
Internal reference: If you want the full background and the original 2024 breakdown, read our previous article here: Spain Social Security for Erasmus Internships (2024 Guide).
2026 headline: The Social Security inclusion framework remains active, and official guidance continues to reinforce a key point for international mobility: inbound students from foreign institutions undertaking internships in Spain under their home programme are generally not covered by the DA 52 obligation.
— Based on SEPIE guidance and Social Security information pages (sources below)
What this 2026 update covers
- What remains the same since 2024 (DA 52 LGSS fundamentals).
- What became clearer in 2025: operational rules and exclusions.
- How Erasmus+ “Beca 0” and international programmes are treated in official guidance.
- Contribution mechanics and what changed for certain surcharges.
- How the special agreement for past internships works.
- A practical checklist for universities and host companies in 2026.
- Common risk scenarios that cause delays or duplicate procedures.
- What to monitor next (including proposed reforms still not in force).
- Official sources for compliance and partner communication.
- Suggested wording for internal policy notes.
1) The legal foundation that remains in force in 2026
The core rule is still the same: students carrying out “prácticas formativas” or “prácticas académicas externas” included in training programmes fall under the Social Security inclusion framework introduced via Royal Decree-Law 2/2023 (DA 52 LGSS), effective from January 1, 2024.
Social Security maintains dedicated guidance pages for these internships (including procedure and stakeholder-specific guidance through Importass).
2) Scope in 2026: who must be registered
As a general rule, Social Security inclusion applies to students participating in internships that are part of recognised training programmes, including:
- University students (official degrees and regulated external academic placements).
- Vocational training students in standard pathways (with specific programme-based exceptions).
Operational focus for 2026:
The main complexity is not whether the framework exists, but who holds the “employer-equivalent” responsibility for registration and reporting in each mobility scenario.
Use official pages as your single source of truth:
Social Security’s dedicated “Prácticas formativas” and Importass guidance are designed to reduce contradictory interpretations.
3) International student mobility (still the most important clarification)
For Erasmus+ and other international exchanges, the most consequential clarification remains:
- The DA 52 framework does not apply to international inbound students coming from foreign universities or foreign VET centres to carry out internships in Spain as part of their home programme.
This clarification is explicitly stated in SEPIE’s informative note, which is frequently used by international offices and host organisations as the reference for inbound mobility cases.
4) Erasmus+ in 2026: practical interpretation by mobility direction
Outgoing Erasmus+ traineeships (Spanish institutions → abroad)
- Applies to students enrolled in Spanish institutions, even if the placement is in another country.
- The entity designated by the framework (often the financing/sending side) may need to complete Social Security steps.
- “Beca 0” cases are addressed in official Social Security guidance (treated as non-remunerated under Erasmus+ in that context).
Incoming Erasmus+ traineeships (foreign institutions → Spain)
- Generally exempt from DA 52 obligations when the student is part of a foreign institution’s programme.
- Host companies should still ensure compliant documentation (training agreement/Learning Agreement and insurance requirements).
- Confirm the sending institution and programme basis before initiating any Social Security process to avoid duplicate administration.
5) Contributions: what changed in 2025 and what to watch in 2026
Key operational update from 2025: Official “Noticias RED” guidance indicates that practices (paid and unpaid) are excluded from certain “finalist” contributions (including the Intergenerational Equity Mechanism and the additional solidarity contribution), reducing complexity and potential cost assumptions for institutions and entities managing registration.
2026 note: Contribution amounts and detailed annual rules are normally developed through yearly “Orden de cotización.” For 2026, public consultation drafts exist, but institutions should rely on published official norms and Social Security guidance until a 2026 order is formally enacted and consolidated.
6) New pathway since 2024: counting past internships through a special agreement
Since 2024–2025, a major development for individuals is the option to compute Social Security contributions for certain internship periods carried out before the 2024 entry into force, via a special agreement (“convenio especial”) regulated by ministerial order.
This matters for universities and alumni support offices because former students may request certification of past internships to access this mechanism.
7) Practical 2026 checklist for universities and host companies
- Classify the case: Is the student enrolled in a Spanish institution or a foreign institution?
- Confirm mobility direction: outgoing (Spain → abroad) vs incoming (abroad → Spain).
- Define responsibility: who acts as “employer-equivalent” for registration and reporting.
- Align dates: Learning Agreement/training agreement dates must match the reporting timeline.
- Standardise documentation: keep proof of the applicable legal basis and exemption rationale where relevant.
- Partner communication pack: send a one-page explanation + official sources to host companies.
- Reduce friction: centralise processing where possible to avoid host-company drop-off.
- Prevent duplicates: do not start registration if the student is inbound from a foreign institution and exempt.
- Handle “Beca 0” explicitly: confirm how your institution operationalises the process.
- Track updates quarterly: monitor Social Security “Noticias RED” and BOE for changes.
8) What to monitor next (context for 2026)
In late 2025, public discussions and draft proposals around a broader “internship statute” or reform framework were reported by legal and policy outlets. These proposals are not automatically in force and may require parliamentary processing and final publication. Still, they signal that internship regulation remains an active policy area, especially regarding safeguards against misuse and potential cost allocation between universities and host entities.
FAQ
Is the 2024 Social Security rule still active in 2026?
Yes. The DA 52 framework remains active, supported by Social Security guidance pages and operational instructions.
Do inbound Erasmus+ students in Spain need Social Security registration under DA 52?
SEPIE guidance states the rule is not applicable to inbound international students from foreign universities/VET centres undertaking internships in Spain as part of their home programme.
What changed in 2025 that matters operationally?
Noticias RED guidance clarifies exclusions from certain additional contributions for practices, and Social Security maintains structured guidance resources for stakeholders.
Can past internships be counted for Social Security purposes?
Yes. A specific ministerial order establishes conditions and procedure for a special agreement to compute contribution periods for eligible internships carried out before 2024.
Sources and official references
- BOE — Real Decreto-ley 2/2023 (legal basis; includes DA 52 LGSS framework)
- SEPIE — Nota informativa sobre cotizaciones de estudiantes en prácticas a la Seguridad Social (includes international mobility clarification)
- Importass (Seguridad Social) — Guía para alumnos en prácticas formativas
- Seguridad Social — Prácticas formativas (info hub)
- Seguridad Social PDF — DA 52 guidance and procedures (Prácticas no remuneradas)
- Seguridad Social — Boletín Noticias RED 05/2025 (updates impacting contribution treatment for practices)
- BOE — Orden ISM/386/2024 (special agreement to compute contributions for internship periods prior to 2024 entry into force)
- BOE — Orden PJC/178/2025 (annual contribution rules for 2025; relevant context for practices)
- Seguridad Social — Prácticas en programas formativos internacionales (includes Erasmus+ “Beca 0” clarification)
- DLA Piper — Summary of the 2025 draft proposal to regulate non-labour practical training (policy context; draft stage)
