The European Union
Three of the twenty-seven are covered here, and the thing worth knowing about both is which half of the answer the Union decides. Whether you need a visa to visit is not Spanish or Portuguese law at all - it is one regulation with two annexes, applied the same way by every member of the Schengen area, and neither country can add a nationality to either list. The same is true of what your household goods pay at the border and of your right to open a basic bank account. Everything that follows arrival is national: how long you must live there before you can naturalise, what a work permit asks for, whether your family may join you, how your pension is taxed. The two countries covered here answer those differently, and they do it inside the same Union.
Decided for every member
One instrument, the same answer in each member state. The quotations are on the country records; these rows say which instrument and where to read it.
The two annexes decide the visa question for every Schengen state. Recorded on each member's entry record and held once as two origin groups.
Spain
Portugal
ItalyRelief from import duty on personal property when you transfer your normal residence: six months' ownership, twelve months lived outside the customs territory, twelve months to bring the goods in.
The right to a basic payment account for consumers legally resident in the Union, and in terms for people with no fixed address, asylum seekers and people whose expulsion is impossible. A directive binds the State, so what a customer enforces is each country's transposition.
Left to each member
Where the bloc stops. These are the questions a reader has to ask country by country, and the note says what the records here show about the spread.
Entirely national, and the three covered members disagree about who gets the short route. Spain: ten years, two for Ibero-American nationals. Portugal: ten years, seven for Portuguese-speaking countries and EU citizens. Italy: ten years, four for a citizen of another member state, two for someone with an Italian parent or grandparent.
National. Spain consults the labour market before considering the applicant; Portugal does not, and lets a permit holder change employer by notifying the agency.
National, and expressed differently. Spain names a figure as a multiple of the IPREM; Portugal names no figure at all and defers it to a ministerial order.
National, and both covered members reach people without papers - Spain by article 3 ter of Ley 16/2003, Portugal by Base 21 of its Lei de Bases da Saúde.
National, and the three do not even share a test. Spain counts 183 days in the calendar year; Portugal counts them in any twelve-month period starting or ending in it; Italy asks for the greater part of the tax period and counts mere presence.
National, and this is where members of one Union diverge furthest. Portugal lets the holder of a licence from a named list go on driving after becoming resident; Spain gives every foreign licence six months; Italy converts without a test only where a bilateral understanding exists.
One regulation decides the border for every member
Regulation (EU) 2018/1806 carries two annexes: nationalities that must hold a visa to cross the external border, and nationalities exempt for ninety days in any 180-day period. It is directly applicable, so it is not transposed, interpreted or narrowed by a member state. Twenty-four of this corpus's thirty-three Latin American and Caribbean states are on the exempt list and nine are not, and the split follows no bloc the region itself built - Jamaica is outside it while Barbados is inside, Ecuador and Bolivia are outside while Peru and Colombia are inside.
The same law, recorded twice, is the reason this page exists
Before this page the entry rule lived on the Spanish record and on the Portuguese record as two separate texts, and a reader comparing them had no way to know they were one instrument. The lists themselves are held once, as two origin groups, so a country moving between annexes is one file to change and every European destination sees it.
Where the Union stops, the difference is sharp
Naturalisation shows it best. Spain asks ten years of legal residence and two from nationals of Ibero-American countries. Portugal asks ten and seven, and its seven-year class is Portuguese-speaking countries and EU citizens. Both lines are drawn by language and history rather than by treaty, both were written by one parliament alone, and they do not agree with each other. A Brazilian is in Portugal's short class and not in Spain's; an Argentine is in Spain's and not in Portugal's.
The nationality lists it produces
A bloc is a group of destinations; these are the groups of nationalities it creates, and they are not the same thing.
- Annex II to Regulation (EU) 2018/1806 - no visa for a short stay · 24 nationalities
- Annex I to Regulation (EU) 2018/1806 - a visa is required · 9 nationalities