DNV Approvals And The Deviations That Standardize Its Requirements

STATEMENT

CONTEXT

• Contrary to general requirements, Filipinos applying for DNV, per BLS Manila required documentation, specifically omit any mention of Certificate of Coverage (COC) as proof of Social Security coverage

• All verified approved DNV Filipino Applicants in the Reddit and Facebook channels did not require COC

• For Americans, Contractors are referred to as “requiring 1099”; Employed with Employer as “requiring W2”

• For Americans/Canadians, it is assumed and advised in these channels by its moderators that only contractors (1099) are eligible for DNV

• By my own research, the first case of an applicant being issued a COC was an American in December of 2023

ASSUMPTIONS

• DNV applicants that are employed just need to supply a statement/affidavit promising to register into the local social security system (autónomo)

• Certificate of Coverage (COC) is not required; and only Certificate of Membership is (COM PH) sufficient to prove bilateral contributions but this is also not “required”, only the SSS number itself would be sufficient

VALIDATIONS

CASE #1

Approved DNV Testimonial (Reference)

• Filipino applied in BLS Manila without agent or law firm

• Lists entire requirements and timeline

• Employed in Philippines (Not a contractor) working remotely

Highlights

• Explicit advice on non-contractor requirements
• “Explicit permission from your employer/client to work in Spain - mentions you being allowed to work anywhere and specifically in Spain. also that you'll be using this document for your visa application. this needs to be notarized and authenticated”

• Explicit clarification of single SSS-related “extra document”
• “SSS membership certificate w/ apostille - proof do your responsibility as PH citizen”

• Explicit advice on “How to ask permission from employer” following questions published in the comments
• See Reference link above

Takeaways

• My application and documentation is categorically identical to Case1 with exception of where he applied and that he did not provide private health insurance

Get private health insurance?

CASE #2

Approved DNV Testimonial (Reference)

• American applied in US with law firm

• Employed as “W2 employee” in US (Not a contractor) working remotely

• Links to a previous post highlighting March 30 2023 updates to Applications for Visas and Residence Authorizations for Teleworking of an International Nature (Law 14/2013)

Highlights

• Explicitly lists four unique requirements quoted below:
• “Letter of approval from my employer (this was very simple, and did not mention anything about W-2/1099 status, just that they approve of me working for them remotely, including from Spain specifically if I desire).”
• “My employment contract (I think this might actually show that I'm directly employed, but it's long and windy).”
• “Last 3 months' bank statements showing income.”
• “An affadavit signed by me stating that I would sign up as autónomo in the Spanish social security after getting my approval (I will do this if I must; hoping that the US SSA-Spain SS situation improves though and that an alternative appears).”

• Autonomo affidavit deviates from applicant type and his additional “I will do this if I must” is a disclaimer that acknowledges and validates the insecurity of the system in its early stages of adoption:
• “We did not specifically intend to go the autónomo route, but decided to try it after discussing it with our lawyers.
• My spouse and I have our young children with us, who will be starting school in the fall here in Spain, and we have a long-term rental contract that started last month. We just got our empadronamiento from town hall this week as well.
• So we're ready for the next step: getting our TIE cards. That sounds like it might be the end of summer though, so we'll likely need to get return authorization letters from the Federal Police for a few trips we have planned. I can post more about that if there's interest! Thanks for the well wishes! I'll try to respond to people as much as I can!”

Takeaways

• My application and documentation is categorically identical to Case2 and represents an autonomo-path, previously assumed inapplicable to candidates for DNV who are employed (not contractor)

Explore signed affidavit stating commitment to Spanish Social Security as autónomo once approved?

CASE #3

Approved DNV Testimonial (Reference)

• Filipino student applied in BLS Spain with law firm

• Employed (not contractor) working remotely

• Denied on grounds that income does not meet DNV requirements

• Approved following appeal

Highlights

• Explicit advice with regards to social security (autonomo affidavit) and to submit membership certificate (not certificate of coverage)
• “I just sent a letter promising that I will continue to pay for my SSS coverage in my home country. I wouldn’t really recommend that you follow what I did because I think I just got lucky. If you are a Filipino, then best to just submit a certificate of membership coverage for the social security requirement.”

• Autonomo affidavit deviates from applicant type and he acknowledges and validates the insecurity of the system in its early stages of adoption
• “For now, my answer is yes because I will keep on being covered by the SSS in the Philippines. But I will have to do more digging about this.”

SUMMARY

• Get private health insurance?

• Explore signed affidavit stating commitment to Spanish Social Security as autónomo once approved?

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