THE WAYPOINT SUR

You can walk away
The paper you actually signed
First ran on Thursday 4 June 2026. The piece was about finding a gestor administrativo — licensed administrative agent, a doctor or a lawyer who is actually any good, and its claim was that every real professional here sits on a public register.
That held. We checked again yesterday. The Consejo General's national register needs no login. Click Búsqueda Avanzada, pick Málaga under Colegio, type your town into Municipio, and set Estado profesional to Ejerciente. Fuengirola returned 27 practising firms with addresses and phone numbers, and it flags anyone listed as colegiado no ejerciente — registered but not currently practising. Confirmed August 2026. The title is regulated and the register is the credential. The word gestoría on the door is not: we could find no rule reserving it.
Two things we told you in June have not held. And one thing we never told you turns out to be the whole game.
What we got wrong about the money
In June we quoted ranges: €50 to €150 for a one-off procedure, €50 to €150 a month for ongoing work, €900 to €3,000 for a complex residency package.
We should have said where those came from, because the answer is us. Spain has had no official fee scale for these professions since December 2009, when the professional colleges act was amended to bar colegios from publishing guideline scales or any other guidance on what their members charge. The one surviving exception exists so that courts can tax costs after a case is over. Nothing exists to tell a client what a job should cost before it starts.
So every range you read, ours included, is somebody's anecdote. Here is the one properly published, dated price list we could verify on the Costa. Expat Agency, Calle Reina Doña Sofía 1, Local 1, Fuengirola: €35 to book a public-office appointment, €120 to €165 for NIE assistance, €350 for a long-term visa application including the non-lucrative, €350 to €400 for a residence permit. Valid from 1 January 2026, all before IVA, which adds 21%.
That visa figure sits well under the band we printed. We are not saying it is the right price. We are saying it is the only one anybody publishes. If you used our June range to judge a quote, you were checking it against a number we had no standing to give you, and my read is that the missing reference price is the real problem here, not the price itself.
While we are marking our own homework: in June we also told you Navigator was €49 a month with no lock-in. It is not, and has not been since early August. It is prepaid blocks at €30 an hour with an estimate before anything starts, or a free pointer to someone better placed if that is what you need. No subscription.
The document that isn't there
In July we came back to report that the official route for delegating access barely works: four separate registers that do not talk to each other, and not one firm we spoke to on the Costa doing it by the book. That piece ended without an answer. This is the nearest thing to one. If the state's machinery will not hold the relationship together, the paper has to.
Most of us signed something. It is almost always a mandato — mandate, the Consejo General's standard form, and it does one job. It authorises your gestor to act for you before the Administration, and names the matter. What it does not say is what will be done, by when, or for how much.
The document that would say those things is a hoja de encargo — engagement letter. Under the profession's own code of conduct, approved by its national council in 2020, signing one is conveniente, advisable, a reciprocal guarantee for both sides. Advisable, and not required.
So the standard arrangement grants your gestor authority and grants you no terms. Nobody is hiding that. It is the shape of the thing, and most people never look at it until something has gone wrong.
Two obligations in the same code do bite. Your gestor must give you a written quote whenever you ask for one, which makes the asking the part that works. And they cannot hold your papers over an unpaid bill: the code says plainly that a gestor may not retain documents the client gave them on the pretext that fees are outstanding.
If you decide to leave
We raised switching in January and left it at timing, which was the easy half. Here is the sequence, and the order matters more than any step in it.
Secure the incoming filer first, in writing, with a quote, before you touch anything else. Revoking a fortnight out from a filing date buys you an unfiled return and a surcharge.
Then look at what is on file. On the tax office's Sede Electrónica — electronic office, Mis datos censales carries a Mis Representantes panel listing every representative they hold for you. Most people have never opened it.
Then revoke, under Registro de apoderamientos, at Consulta, prórroga y revocación. You identify yourself with your certificate or Cl@ve, there is no waiting period, and the tax office does not require you to tell the firm first. One trap sits in there. Revocación masiva revokes every power granted to one apoderado — authorised representative, and a firm usually appears twice, once under the company tax number and once under an individual gestor's. Run it against each name, then reload the list and read it again.
Revoking is still not the end of it. The separate authorisation letting them file electronically for you sits in their office, and as far as we can establish no register stands behind it and nothing on the tax office's side withdraws it. Withdraw that one in writing and keep the proof. The Código Civil lets you revoke a mandate whenever you like and demand the document back, and treats a new appointment as cancelling the old one only from the day the old gestor is told. After the Nerja case in July we covered the notarial version, a different instrument at €60 to €100.
Then ask for your file, and do not ask for five years, which is the number that gets quoted. The tax office generally has four years to assess you, so four is the floor, six if you trade, ten if you are carrying losses forward.
We can find no law imposing a notice period. Whether you owe anyone 30 days is a question about your engagement letter rather than about Spanish law, which brings it back round to whether you have one. Our guide to choosing an English-speaking gestoría carries the vetting questions; the paperwork above is what it does not cover, and we are adding it this week.
The date that decides your timing
If you are registered as autónomo, or a non-resident owner filing each quarter's rent separately, the third-quarter window is the next hard edge. You file by Tuesday 20 October. If your filings are paid by direct debit, which is how most gestor-managed filings work, your real deadline is Thursday 15 October. Confirmed August 2026 against the tax office's own calendar.
One local wrinkle worth carrying: 15 October is itself a local holiday in Mijas, Fuengirola loses 7 October, and Marbella loses 19 October, one of only three working days between the two dates. If your gestor sits in one of those towns, the window is thinner than the national calendar suggests.
Which is the argument for doing this in September. The middle of a filing window is the worst possible moment to find out that nobody can locate your file.
One ask before you go. In July we said we were looking for a firm on the Costa handling delegation properly, and nobody came forward. Narrower question this time: does anyone reading this actually hold a signed hoja de encargo from their gestor? Hit reply and tell us what it covers, or tell us you looked and there was not one. Both answers are useful. The second is the one we expect.
Spanish-lite
Hoja de encargo — engagement letter. The one with the terms in it. Ask: "¿Me puede preparar una hoja de encargo?"
Mandato — mandate. The one you probably signed instead. It grants the authority and sets none of the terms.
Neither is the hoja de reclamaciones — complaint form we covered a fortnight ago, which is for after things have already gone wrong.
The bottom line
In June we told you how to find a gestor. We never told you how to leave one, and that is the part that makes the choosing real, because an arrangement you cannot exit was never really chosen. The register still does most of the vetting in about two minutes. Everything after that lives in a document nobody is obliged to hand you and almost nobody asks for. Ask in September, while nothing is due.
Look up whoever files for you on the national register of gestores administrativos and check they are listed as ejerciente. Then ask for the engagement letter.
Onwards — A. and the WaypointSur team, who have finally read their own small print.


