The same document, two different tests
Two countries that share a land border, a broadly similar residence-visa architecture and a comparable public health system ask for almost opposite things when it comes to proof of health cover. Spain runs what is, on the evidence gathered for this research, the strictest admitted-insurer rule in Europe. Portugal runs the loosest test found on the continent for a national residence visa. The distance between them is about six hours by road.
That divergence is worth understanding properly, because it is not a difference of degree. It is a difference in what the rule is asking. Spain's requirement is an equivalence test: the policy must reproduce the scope of the public system. Portugal's requirement is a travel-medical test: the policy must be able to pay for necessary medical expenses and get you home. An equivalence test interrogates the architecture of the product. A travel-medical test interrogates only its purpose.
The practical consequence is that an internationally mobile person holding a perfectly good global plan will find it works for one application and is structurally incapable of working for the other. This is the clearest single illustration of the broader pattern set out in visa-stage versus residence-stage health cover: the question is rarely whether the cover is adequate, and almost always whether it is the right shape.
Spain: a certificate the international market cannot produce
The consular requirement for the non-lucrative visa is a health insurance certificate from a public or private insurer authorised to operate in Spain, covering all risks insured by the Spanish public health system. The instruction goes further and names what the policy must not contain: no waiting periods, no exclusions, no copayments and no coverage limits. Travel insurance is expressly stated not to be valid. An insurance card is not accepted as evidence; an original certificate is required.
Two of those conditions are the ones that matter commercially, and they are not the ones applicants usually focus on.
Why "no limits and no copayments" is fatal to the product structure
Annual maxima, deductibles and co-insurance are not incidental features of international private medical insurance. They are the pricing mechanism. An insurer writing cover across many jurisdictions with no realistic ability to control provider charges manages that exposure by capping the annual benefit and by making the member share the first slice and a percentage of the rest. Remove all three and you are no longer describing a rated insurance product; you are describing something closer to a public entitlement.
That is why the Spanish rule cannot be met by adjusting an existing international policy upward. The mechanics are set out in annual benefit limits and inner limits and in deductibles, excess, co-insurance and out-of-pocket maximums, and they run through every plan architecture on the market. A policy with a very high annual maximum still has an annual maximum. The requirement, read literally, is not a threshold to clear but a feature to eliminate.
Layered on top of that is the authorisation condition, which is the same admitted-insurer problem described in admitted versus non-admitted insurance. The insurer must be licensed in Spain. Most international carriers are not, and the ones that are typically write a separate Spanish domestic product to do it. In practice, Spanish applicants tend to end up with a Spanish policy — which means starting a new medical history with a new insurer, and losing whatever continuity had accrued elsewhere.
The teleworker route, and what is not yet confirmed about it
The international teleworker visa introduced under Ley 28/2022, generally referred to as the Startup Act, is often presented as a softer alternative. The information gathered for this research points the other way, but it must be labelled clearly as partly verified only: the relevant Spanish government page failed on a TLS certificate error and could not be read directly, so what follows rests on search summaries of it rather than the page itself.
On that basis, the route appears to require either registration with Spanish social security or private cover from an insurer authorised in Spain and registered with the Dirección General de Seguros, valid across the whole country, equivalent in scope to the national health system, with no copayments and no waiting periods, and not structured purely as expense reimbursement. Travel insurance is again invalid. If that reading is right, the teleworker route is the non-lucrative rule in different words. Confirm it against the current joint instruction before acting on it.
The convenio especial is a second-year answer
Spain does operate a buy-in to the national health system for economically inactive foreign residents. The convenio especial gives access to the basic service portfolio for a contribution, administered by INGESA, and it is genuinely useful — but not at the point of application.
The gate is residence history. An applicant must have completed one continuous year of effective residence in Spain, the EU, the EEA, Switzerland or the United Kingdom immediately preceding the application, and must have no other entitlement to public healthcare. Someone arriving on a fresh non-lucrative visa cannot satisfy that on day one. The scheme is therefore a way of moving off private cover in year two, not a way of avoiding it in year one.
Its second limitation is scope. The convenio especial excludes outpatient pharmaceuticals, orthopaedic devices, dietetic products and non-urgent transport, all of which sit at one hundred per cent patient cost. For someone with a long-term prescription, that exclusion is the whole decision. The interaction with the wider Spanish system, including the NIE and SIP card, is covered in healthcare for expats in Spain.
Portugal: a purpose test, not a structure test
Portugal's national residence visa instruction — the route usually described as the D7 for passive-income applicants and the D8 for remote workers — requires travel health insurance able to cover the necessary expenses for medical reasons, including urgent medical assistance and possible repatriation.
Read that again for what it does not say. It does not name an admitted insurer. It does not set a minimum sum insured. It does not prohibit copayments, deductibles or annual limits. It does not distinguish between a travel-medical policy and an annually renewable international plan, a distinction explored in travel insurance, travel medical and IPMI and in the older guide on travel insurance versus IPMI. It states a purpose and asks for a policy that serves it.
The requirement can also be waived outright under bilateral agreements. Brazil's PB4 certificate and the United Kingdom's S1 are both named on the visa portal, and both remove the insurance document from the file entirely rather than substituting a different one.
The part that is not confirmed
There is a widely repeated claim that the position tightens at the residency stage. Several broker and relocation sources state that at the AIMA appointment travel insurance is no longer accepted and a private health insurance policy valid in Portugal and covering repatriation is required instead, with registration in the national health service following the grant of residency.
No official page confirming that was located during this research. It is presented here as an unverified report and nothing more. It may well be accurate practice at particular offices, but practice at a particular office is not a published rule, and a guide that cannot cite the rule should not assert it. If your plan depends on it, ask AIMA directly and ask for the instruction in writing.
Why two neighbours diverge
The two rules were written to solve different problems.
Spain's requirement is drafted against the risk that a non-working, non-contributing resident falls back on the public system. The answer is to demand cover that is functionally indistinguishable from what the system itself provides, which is why the drafting attacks limits and copayments rather than setting a sum insured. Portugal's requirement is drafted against a narrower risk: that a visa holder needs urgent treatment or repatriation and cannot pay for it. A travel-medical policy answers that risk, so a travel-medical policy is what is asked for.
| Spain (non-lucrative) | Portugal (residence visa) | |
|---|---|---|
| Insurer must be locally authorised | Yes | Not stated |
| Minimum sum insured | Not stated; limits prohibited | Not stated |
| Copayments permitted | No | Not addressed |
| Waiting periods permitted | No | Not addressed |
| Travel insurance accepted | Expressly not valid | This is the stated basis |
| Bilateral waiver route | Not applicable at this stage | Yes — PB4, S1 named |
| Public-system buy-in | Convenio especial, after one year | SNS registration follows residency |
The comparison is a reminder that the strictness of a health insurance rule tells you nothing about the healthcare. Both countries run well-regarded public systems. The difference is entirely in how each government has chosen to guard access to it, a theme developed further in IPMI versus local health insurance abroad and, from the opposite direction, in the German position covered in health insurance for expats in Germany.
Before you commit to either
Confirm the current instruction with the consulate that will process your file, not with a relocation forum, and ask specifically whether the wording on limits and copayments has changed. Ask any prospective insurer whether it is authorised in Spain and whether it will issue an original certificate in the required terms — the answer to the second question is often the faster filter. If you are weighing the two countries against each other, price the Spanish route as a new policy with a new medical history rather than as an amendment to what you hold.
A note on currency. The rules described here reflect research carried out in July 2026. Immigration and insurance requirements in both countries change without much notice, and consular practice varies between posts even where the published rule does not. Nothing here is a substitute for confirming the position with the relevant consulate, AIMA, the Dirección General de Seguros or a locally qualified adviser before you submit anything.
Frequently asked questions
Can I use my existing international health insurance for a Spanish non-lucrative visa?
The consular requirement is a certificate from a public or private insurer authorised to operate in Spain, covering all risks insured by the Spanish public health system, with no waiting periods, exclusions, copayments or coverage limits. International plans are built on annual maxima, deductibles and co-insurance, so the structure of the product is the obstacle rather than the quality of the benefits. Travel insurance is stated to be invalid, and an original certificate is required rather than an insurance card. Check the current wording with the consulate handling your application.
Does Portugal really accept any travel health insurance for a residence visa?
The Portuguese visa portal requires travel health insurance covering necessary medical expenses, including urgent medical assistance and possible repatriation. No admitted-insurer requirement and no minimum sum insured appear in that instruction, which makes it the most permissive European residence-visa test found in this research. Bilateral agreements can waive the requirement entirely, with Brazil's PB4 and the United Kingdom's S1 both named. The absence of a stated minimum is unusual enough that you should confirm it directly with the consulate before relying on it.
What is the convenio especial and can it replace visa-stage insurance?
It is a buy-in to the Spanish national health system for foreign residents with no other public entitlement, administered by INGESA. It cannot serve at the visa stage, because applicants must first have completed one continuous year of effective residence in Spain, the EU, the EEA, Switzerland or the United Kingdom immediately before applying. It also gives the basic service portfolio only, excluding outpatient pharmaceuticals, orthopaedic devices, dietetic products and non-urgent transport, all of which fall entirely on the patient.
Why does Spain refuse copayments and coverage limits when other countries accept them?
Because the Spanish test is framed as equivalence to the public system rather than as a minimum sum insured. The national health system does not apply an annual ceiling to hospital treatment or charge a coinsurance percentage at the point of care, so a policy that does either is not equivalent to it. Countries that set a numerical floor instead, such as the Schengen short-stay rule, are asking a different question and can be satisfied by a policy with limits above that floor.
Is the Spanish digital nomad visa easier for international cover than the non-lucrative visa?
The evidence available points the same way rather than an easier way. The international teleworker route under the Startup Act appears to require either Spanish social security registration or private cover from an insurer authorised in Spain, valid across the whole country, equivalent in scope to the public system, with no copayments or waiting periods and not purely reimbursement-based. That reading rests on secondary sources, because the Spanish government page could not be read directly, so treat it as provisional and verify it.
Do I need Portuguese insurance once I have residency rather than a visa?
The visa-stage requirement is documented; the residency-stage position is not. Several broker sources report that at the AIMA residency appointment a private health insurance policy valid in Portugal and covering repatriation is required, and that travel insurance is no longer accepted, but no official page confirming that was located during this research. Treat it as unconfirmed. Registration with the national health service normally follows residency, which changes what private cover is doing for you.
If I am choosing between the two countries, does the insurance rule matter much?
It matters at the point of application and much less afterwards. Spain's rule forces a Spanish-authorised policy at the outset, which usually means buying a second policy rather than adapting the one you hold, and any continuity of cover built up on an existing plan does not travel with you. Portugal's rule can often be met with cover you already have. Neither position tells you anything about the quality of care in either country.
This guide is general information only and does not constitute financial, legal, medical or tax advice. Global Investments is not authorised by the Financial Conduct Authority. Insurance products, benefit schedules and premiums are revised regularly, and mandatory health insurance requirements change frequently — in several jurisdictions they are described differently even between official sources. Nothing here is a recommendation of any product or insurer. Confirm the legal position with the relevant regulator or a locally qualified adviser, and confirm cover terms with the insurer, before acting.