ZEC: the registration window closes on 31 December 2026 — the real timeline to file in time from Fuerteventura

Every founder who reads about the 4 % rate arrives at the same three questions: what exactly has to happen before 31 December 2026, how many weeks the file really needs, and whether the date will move. This piece answers the three from the texts — Ley 19/1994, its regulation (Real Decreto 1758/2007), the European regulation the date is anchored to and the ZEC Consortium's own procedure pages — and then counts the calendar backwards from December for a company that will sit in Fuerteventura, where the thresholds are the low ones. Quotations are in Spanish with the reading in English. Our August piece explains the regime itself; this one is about the clock.

What the law says must happen by 31 December 2026

The date is not written in the Spanish law as a number. Article 29.2 of Ley 19/1994 says that La autorización de la inscripción en el Registro Oficial de Entidades de la Zona Especial Canaria tendrá como límite la fecha establecida en el artículo 59 del citado Reglamento (UE) 651/2014 — the authorisation of the entry in the official register of ZEC entities has as its limit the date fixed in article 59 of Regulation (EU) 651/2014, the general block-exemption regulation for State aid. Article 59 of that regulation, in the wording Regulation (EU) 2023/1315 gave it, reads Será aplicable hasta el 31 de diciembre de 2026 — it applies until 31 December 2026. Put the two together and the rule is precise: what must exist by 31 December 2026 is the Consortium's authorisation, not the company and not the entry in the register.

The other half of the same article is the reason the date matters. Article 29.1 lets the ZEC tax incentives be enjoyed durante los seis años inmediatos posteriores a la finalización de la vigencia del Reglamento (UE) 651/2014 — during the six years immediately following the end of the Regulation's validity. Six years after 31 December 2026 is the end of 2032: an entity authorised in time keeps the 4 % rate through 2032 whatever happens to the regime afterwards, and that guarantee is what the whole calendar is about. Article 29.3 adds the standing caveat: the zone's continuation is condicionado en todo caso al resultado de las revisiones periódicas que deba realizar la Comisión Europea — conditional in any case on the outcome of the Commission's periodic reviews.

Will the date move? The honest answer in September 2026

Every autumn someone says the window will be extended, and the wording of the law is why the rumour never dies. Article 29.2 ties the limit to the Regulation's expiry o la de la norma que lo sustituya — or to that of the rule that replaces it. The Commission is indeed preparing a successor: it held a public consultation on a draft new block-exemption regulation from 25 February to 23 April 2026, and the law firms that summarised the draft expect adoption at the end of 2026 and application from 1 January 2027. If that happens, the Spanish text would follow the new regulation's own expiry date without a new Spanish law.

That is a chain of three conditions, none of them met as we write: the new regulation has to be adopted, the ZEC scheme has to fit its conditions for operating aid in the outermost regions, and Spain has to keep the scheme inside it. The Consortium has published no extension and the Commission has adopted nothing. The way to read it is the way the Consortium's own pages read it: 31 December 2026 is the date, an extension would be a bonus, and a project that only works if the bonus arrives is not a plan. Nobody who files in October loses anything if the window is later extended; whoever waits for the extension can lose six years at 4 %.

Authorised means what: the two-stage procedure

Entry into the ZEC has two stages, and only the first is date-bound. Article 41.1 makes the entry in the register condicionada a la autorización previa del Consorcio de la Zona Especial Canaria — conditional on the prior authorisation of the ZEC Consortium. The application carries the descriptive report of the activities (the memoria of article 31.2.f) and a deposit or bank guarantee for the application fee; the Consortium's Technical Committee checks the file and reports — a report binding on solvency, viability and international competitiveness — en un plazo no superior a un mes — within no more than one month, extendable by fifteen days at most (article 35.3); the governing board, the Consejo Rector, then decides.

The clock the law gives the board is two months: La autorización por parte del Consejo Rector deberá otorgarse, de forma expresa, en el plazo de dos meses — the board's authorisation must be granted expressly within two months from the day the Consortium receives the application. Two things about that clock. It can be suspended when the file is incomplete and the Consortium asks for more, which is the usual way an application loses weeks. And silence is not consent: Transcurrido el plazo indicado sin resolución expresa, se entenderá desestimada la solicitud de autorización — once the period has run without an express decision, the application is deemed refused. A file that reaches 31 December still waiting for an answer has not been authorised.

The second stage has no December date. Once authorised, the promoters have eighteen months to ask for the entry — the regulation's article 47.3: se concederá un plazo de dieciocho meses para solicitar la inscripción — presenting the company's tax number and the incorporation deed as filed with the Registro Mercantil; the register's office then has ten days to register or to ask for corrections, and article 41.2 of the law says the same: La inscripción deberá practicarse en el plazo de diez días. The Consortium's own guidance adds that the eighteen months can be extended by nine on request. The regime applies from the entry, not from the authorisation (regulation, article 49), and the Consortium's procedure page is blunt that the company may not start operating until it is registered.

The calendar, counted backwards from 31 December

Read the table from the bottom. A complete application in the Consortium's registry by the middle of October gives the board its full two months before 31 December, with a margin for one request to complete the file. A November filing depends on the board's own meeting calendar, which the law does not fix and the Consortium does not publish as a deadline. A December filing is a wager on a decision the law allows to take two months. The two months are the law's maximum, not a promise of speed; a file that draws a request for documents loses the weeks the request takes.

What the table does not show is that the company itself can be prepared in parallel. The regulation's article 41 treats an entity incorporated before the authorisation as still de nueva creación — newly created — provided the incorporation no vaya acompañada de actividad económica alguna hasta tanto se produzca la inscripción — is not accompanied by any economic activity until the entry is made. Incorporating a Fuerteventura SL is a two-to-four-week job at the notary and the Registro Mercantil, and our sister firm explains it step by step; it can be done while the Consortium reads the memoria. What the company may not do is invoice.

Fuerteventura's thresholds, and the substance behind them

Article 31.2 lists what an entity must be. Its registered office and its place of effective management in the Canaries; at least one director — for a branch, its legal representative — resident in the islands; a corporate object made of activities in the law's annex; and a report on the activities cuyo contenido será vinculante para la entidad — whose content is binding on the entity, so that changing the activity later needs the board's authorisation. Then the two numbers. Investment in fixed assets located and used in the Canaries within the first two years of the entry: €100,000 in Gran Canaria and Tenerife, €50,000 in El Hierro, Fuerteventura, La Gomera, Lanzarote and La Palma. Jobs within six months of the entry, kept as the annual average headcount for as long as the regime is enjoyed: five in the two capital islands, three in Fuerteventura and the other four; where the same activity was already carried on under any ownership, the three must be net new jobs.

Three details decide whether Fuerteventura's easy thresholds are yours. The regulation's article 42 applies the capital-island figures cuando la entidad disponga de establecimiento en el territorio de cualquiera de estas — when the entity has an establishment in the territory of either of them: a Fuerteventura company with an office in Las Palmas is a €100,000, five-job company. The investment clock runs from the day after the entry is notified, and assets bought once the application is filed already count (regulation, article 43); hires made after filing count too when they were needed to prepare the start (article 44). And the investment can be waived: the law lets the board authorise entry or permanence siempre que el número de puestos de trabajo a crear y el promedio anual de plantilla superen el mínimo — provided the jobs to be created and the annual average headcount exceed the minimum; the law sets no figure, and the board decides project by project.

An existing business does not move into the ZEC; it creates a new vehicle for the qualifying activity — a company or a branch, each with its own trade-offs — and the memoria must declare the previous headcount when the activity was already carried on (regulation, article 47.2).

The activities list: what a Fuerteventura project can register

The annex is a list of NACE codes, and the words prevail over the code: En aquellos supuestos en que la denominación de la actividad no coincida íntegramente con la del correspondiente código NACE prevalecerá aquella — where the activity's name does not fully match the NACE code, the name prevails. For the projects we see on the island, the useful entries are software and IT services (62), head offices and management consultancy (70, with the annex's own exclusion: Los centros de coordinación y servicios intragrupo se encuentran excluidos — coordination centres and intra-group services are excluded), advertising and market research (73), other professional, scientific and technical activities (74), R&D (72), publishing (58), audiovisual production (59, not cinemas), telecommunications (61), wholesale trade and trade intermediaries (46), land, sea and air transport and logistics (49 to 52), travel agencies and tour operators (79), employment activities (78), post-secondary and other education (85.4, 85.5), other health activities (86.9), sports facilities and other sports activities (93.11, 93.19), fitness (96.04), building rehabilitation and renovation (41.20), most manufacturing industries (10 to 33, though refining, motor vehicles and weapons are out), electricity from renewables (35.1) and desalination powered by renewables (36).

What is not there matters as much: retail, hotels and restaurants, real-estate activities, new-build construction, and finance and insurance are absent, and the rehabilitation entry does not cover building new. A company may run a non-ZEC activity too, but through a separate branch with separate accounts (article 31.2.c), and the 4 % never touches it.

What you get, and what it costs

The rate is 4 % (article 43) on the part of the taxable base that comes from operations carried out material y efectivamente — materially and effectively — in the Canaries, measured by the fraction of article 44. Article 44.6 caps the base that enjoys it: 1.800.000 euros for an entity that creates the minimum jobs, plus 500.000 euros adicionales por cada puesto de trabajo que exceda del mínimo señalado, hasta alcanzar 50 puestos de trabajo — €500,000 more for each job above the minimum, up to 50 jobs — and, whatever the headcount, the tax saved against the general rate no podrá ser superior al 30 por ciento del importe neto de la cifra de negocios — may not exceed 30 % of the entity's net turnover. A three-job Fuerteventura company therefore has €1,800,000 of base a year at 4 %; six jobs raise it to €3,300,000.

The comparison in 2026 is not always with 25 %. The general rate is 25 % (Ley 27/2014, article 29.1), but a company with turnover under €1,000,000 pays 19 % on its first €50,000 of base and 21 % on the rest in 2026, a small company under €10,000,000 pays 23 %, and a newly created company pays 15 % in its first two profitable years (article 29.1 and transitional provision 44). On €200,000 of profit a micro-company pays €41,000 in 2026 and a ZEC entity €8,000: €33,000 a year, every year through 2032 — and the 30 % ceiling only bites if turnover were under €140,000. Alongside the rate come the exemptions from transfer tax and stamp duty on the assets and corporate operations of the activity (article 46), from IGIC on supplies between ZEC entities and on imports (article 47), and, for dividends and interest paid to non-EU shareholders, the exemptions of article 45, closed to non-cooperative jurisdictions. The regime coexists with the RIC and the DIC within the EU aid limits (article 42.2).

The costs are the fees of article 50. The application fee is €1,500 from 2025 on, deposited or guaranteed with the application, and No procederá la devolución de la tasa en los supuestos de denegación — it is not refunded if the application is refused, though an identical re-application pays no second fee. The annual permanence fee is €1,300 for an entity established on an island other than Tenerife and Gran Canaria (€1,500 there), accrued on 31 December from the year after the entry and settled by 20 February under the regulation's self-assessment rule (article 52.3). Both are updated by the budget law's fee rule when there is one.

The mistakes that cost the window

• A memoria that is a brochure. Article 45 of the regulation wants a three-year projected profit-and-loss account and balance sheet, the financing of the investment, bank certificates — referidos a la entidad o, en caso de no haberse constituido ésta, a sus promotores — of the entity or, if it is not yet incorporated, of its promoters — and the team's professional profiles. A file missing them stops the two-month clock.
• An activity described in words the annex does not use. The name prevails over the code; write the corporate object with the annex open.
• An office in Las Palmas or Santa Cruz. Article 42 of the regulation moves you to €100,000 and five jobs.
• Trading before the entry. The regime applies from the entry (regulation, article 49), and a pre-incorporated company that starts invoicing stops being de nueva creación.
• Investment that does not count. Assets leased to or from related parties, second-hand assets already used for the same purpose, or assets sold within the period without reinvestment within a year (article 31.2.d).
• A director resident on the mainland. The Consortium's requirements page asks for a director who is residente for tax purposes in the Canaries.
• Planning on the extension. See above.

Starting this month from Fuerteventura

Our business advisory desk runs the file end to end: the eligibility check against the annex and the thresholds, the memoria in the form the Consortium's instructions ask for, the deposit and the filing at the electronic office, the incorporation in parallel at the notary and the Registro Mercantil, the entry in the register, and afterwards the compliance the regime lives on — the three hires by month six, the €50,000 by year two, separate accounts, the annual fee. If you want to know this week whether your project fits and whether October is still reachable, book a consultation; our business advisory page explains how we work with founders arriving on the island.

Common questions

Do I need to incorporate the company before applying?

No. The application can be filed by the promoters before the entity exists; the bank solvency certificates may refer to the promoters, and once the authorisation arrives there are eighteen months to file the incorporation deed and the tax number for the entry. Incorporating early is allowed as long as the company carries on no economic activity until it is registered.

If the authorisation arrives in December 2026 and the entry is made in 2027, am I inside the window?

By the text of article 29.2 the limit falls on the authorisation, and the eighteen months to request the entry run from it. We would still not plan on it: aim for the entry in 2026 as well, and confirm the Consortium's reading of a straddling file before you rely on it.

Can my existing Fuerteventura business use the ZEC?

Not as it is. The regime is for newly created entities and branches; the usual route is a new company or branch for the qualifying activity, and when the same activity was already carried on, the three Fuerteventura jobs must be net new ones and the memoria must declare the previous headcount.

What happens if I miss the three jobs or the €50,000?

The Consortium supervises the entities (articles 37 and 38) and can revoke the authorisation; the regime is then lost and the tax saved is at stake. The investment requirement can be waived by the board when the jobs created exceed the minimum, and the jobs are measured as an annual average, so a replacement gap is not a breach — but a plan that cannot fund three salaries by month six should not file.

Facts verified in September 2026 (Ley 19/1994, articles 28, 29, 31, 35, 37, 38, 41 to 47 and 50 and the annex, in the BOE's consolidated text; Real Decreto 1758/2007, articles 41 to 45, 47, 49 and 52; Regulation (EU) 651/2014, article 59 as amended by Regulation (EU) 2023/1315; Ley 27/2014, article 29.1 and transitional provision 44; the ZEC Consortium's requirements, procedure, fees and electronic-office pages; the European Commission's 2026 consultation page on the new block-exemption regulation). The date is the European Commission's and the Consortium's to move, and the board's calendar is its own; check both the week you file.