EU Blue Card salary threshold 2026: how to hire a Highly Qualified Professional in Spain (Law 14/2013)

If your company hires international talent, review the salary in your offer today

The EU Blue Card salary threshold 2026 has changed and directly impacts companies hiring a Highly Qualified Professional in Spain under Law 14/2013 through this route. In practice, the threshold is assessed against the gross annual salary stated in the employment contract or binding job offer—so an incorrectly structured package can lead to requests for additional documentation, delays, or even refusals.

This update is especially relevant for tech companies (software, engineering, telecommunications, cybersecurity, AI, data) and for the Málaga TechPark / Parque Tecnológico de Andalucía ecosystem, where access to specialized talent is a competitive advantage.

➡️ If you want end-to-end support, see our service to hire a Highly Qualified Professional in Spain.

Executive summary (for HR and management)

R&D and innovation are common scenarios where the EU Blue Card helps companies access global talent.

1) EU Blue Card salary threshold 2026: what changed (BOE)

Order PJC/44/2026, dated 27 January (BOE 30/01/2026) sets the reference salary threshold for the residence authorization of Highly Qualified Professionals holding an EU Blue Card.

General rule:

• The gross annual salary must be equal to or higher than 1.4× the average gross annual earnings per worker published by Spain’s National Statistics Institute (INE) in the Annual Earnings Structure Survey (EAES).

2) Who does the new threshold apply to? EU Blue Card vs national Highly Qualified Professional authorization

Spain’s Law 14/2013 allows two routes for a Highly Qualified Professional:

1. Highly Qualified Professional holding an EU Blue Card (EU route).
2. National Highly Qualified Professional authorization (national route).

Order PJC/44/2026 is specifically issued for the EU Blue Card, so the BOE salary threshold applies to that route.

Practical takeaway for employers:

• If your business objective is the EU Blue Card (EU-level framework, mobility aspects), the salary threshold is a core admissibility requirement.
• If your case fits better under the national route, the focus shifts to role fit, qualification, and employment conditions—while still maintaining internal consistency in the salary package.

3) How to calculate the EU Blue Card salary threshold 2026 (illustrative figures)

INE reported €28,049.94 as the average annual earnings in 2023 (EAES 2023). Applying the 1.4× rule:

• General threshold (illustrative): €28,049.94 × 1.4 = €39,269.92 gross/year (≈ €39,270).

Operational recommendation (HR):

• Build in a safety margin (e.g., €39,500–€40,000) to avoid issues related to rounding, payroll structuring, or interpretation of pay components.

Common mistake: mixing up “gross monthly” with “gross annual” or relying on variable pay to meet the threshold. For clarity, see: gross salary vs net salary.

4) Reduced threshold (80%): when it may apply and how to document it for EU Blue Card salary threshold 2026

The Order allows a reduced threshold (0.8×) in two limited scenarios.

4.1. Shortage occupations (groups 1 and 2)

It may apply if the role is listed in Spain’s Shortage Occupations Catalogue and fits within groups 1 and 2 of the CNO-2011 classification.

4.2. Qualification obtained within the last 3 years

It may apply if the professional obtained the relevant qualification for the EU Blue Card no more than three years before the application.

Illustrative figure (EAES 2023):

• €39,269.92 × 0.8 = €31,415.93 gross/year (≈ €31,416).

5) Practical examples (tech company and SME) for EU Blue Card salary threshold 2026

Example 1 — IT company in Málaga TechPark: senior engineer

• Offer: €42,000 gross/year (fixed) + variable.
• Outcome: exceeds the illustrative threshold.
• Recommendation: document the guaranteed fixed annual salary clearly; variable pay should be additional.

Example 2 — Startup (Málaga/Nerja): data analyst with a constrained salary band

• Offer: €36,000 gross/year.
• Outcome: below the general threshold.
• Typical options:
  1. increase the fixed annual salary;
  2. assess whether the 0.8× reduction can apply (shortage occupation / recent qualification);
  3. evaluate the national Highly Qualified Professional authorization if it fits the business objective and profile.

Example 3 — Recently qualified profile: applying the 80% threshold

• Offer: €32,000 gross/year.
• Outcome: may fit under the reduced threshold if the scenario is properly evidenced.

6) Employer compliance checklist (before filing) considering EU Blue Card salary threshold 2026

1. Choose the route: EU Blue Card or national Highly Qualified Professional authorization.
2. Review the offer/contract: gross annual salary (guaranteed) and duration.
3. Confirm employment consistency: collective bargaining agreement, professional group, and job duties.
4. Prepare qualification evidence: degree/experience (and recognition if the profession is regulated).
5. Review payroll/SS alignment: Social Security contribution groups for Highly Qualified Professionals.
6. Plan internal timelines: onboarding, relocation, and documentation collection.
7. Anticipate risks: variable-only compliance, non-guaranteed allowances, or ambiguous offers.

For the broader framework, see: requirements to hire Highly Qualified Professionals.

Tech companies in Málaga TechPark: international hiring of Highly Qualified Professionals.

7) Málaga TechPark and tech companies: why this change matters for EU Blue Card salary threshold 2026

Málaga’s tech ecosystem (Málaga TechPark (PTA)) continues to grow, and demand for specialized roles remains high. In this environment, international hiring becomes a competitive advantage—provided it is structured with legal certainty.

If your company struggles to fill IT roles, see our analysis on the shortage of highly skilled IT profiles.

8) How we work at Pérez Parras Economistas y Abogados (Málaga and Nerja)

We advise companies on hiring Highly Qualified Professionals, both under the EU Blue Card route and under the national route, with a preventive approach (strategy, offer/contract review, and filing).

Our edge for tech companies: our team includes professionals with a dual background in Telecommunications Engineering and Law, which helps translate technical roles (IT/telecom) into a legally robust immigration file.

✅ If you need a service proposal for your company: Contact our firm (Málaga and Nerja).

9) FAQ

What is the EU Blue Card salary threshold 2026?

The EU Blue Card salary threshold 2026 follows the BOE rule: the gross annual salary in the offer/contract must be ≥ 1.4× the INE average annual earnings (EAES). Using EAES 2023 as a reference, the illustrative threshold is around €39,270 gross/year, but employers should confirm the updated amount published via UGE-CE.

Which salary figure is used: gross annual, monthly, or including extra payments?

The assessment is based on the gross annual salary stated in the contract or binding offer. To avoid issues, HR should state the guaranteed gross annual amount explicitly, regardless of whether extra payments are prorated.

Can the threshold be met with bonuses, variable pay, or benefits in kind?

Variable pay or benefits may exist, but the safest practice is for the guaranteed fixed annual salary to meet the threshold by itself. When compliance depends on bonuses, stock options, or hard-to-quantify benefits, the risk of requests for clarification increases.

When can the 80% reduced threshold apply?

The Order provides an 0.8× reduction in limited cases, mainly: (i) shortage occupations (groups 1 and 2 CNO-2011) listed in the Shortage Occupations Catalogue, and (ii) professionals who obtained the relevant qualification within the last 3 years. Each case must be documented.

How do I check whether a role is in the Shortage Occupations Catalogue?

You must review the catalogue published for the relevant territory (and its quarterly validity) on the SEPE website, and confirm that the occupation fits groups 1 and 2 CNO-2011.

Does the new threshold affect the national Highly Qualified Professional authorization?

Not directly: the BOE threshold is regulated for the EU Blue Card route. However, salary consistency with duties and qualification is advisable in any Highly Qualified Professional hire to reduce requests and strengthen the file.

What happens if the application is filed with a salary below the threshold?

The main risk is a request for clarification or a refusal for failing the salary requirement. In practice, employers often need to correct the offer/contract and, where appropriate, reassess the route (EU Blue Card vs national authorization) before proceeding.

What documents should HR prepare to minimize requests for clarification?

Beyond the contract/offer with a clear gross annual salary, it is usually helpful to prepare a job description, organizational fit, evidence of qualification/experience, and standard corporate documentation. If using the 80% reduction, prepare proof of the shortage catalogue entry or recent qualification.

At Pérez Parras Economists and Lawyers we are experts in Immigration Law, and we have extensive experience in the recruitment of Highly Qualified Workers for companies in general, and for technology companies in Málaga and Spain in particular, providing a solution to the shortage of highly qualified IT profiles faced by technology companies in Malaga and Andalusia, as well as in Spain in general. We know in detail the procedure and requirements for the fast and effective recruitment of Highly Qualified Professionals, and the obtaining of their residence permits in Spain. We have professionals with double degrees in Immigration Law and Engineering who know the details of the job profiles of Highly Qualified Professionals, and professionals with double degrees in Law and Economics who are experts in international taxation in Malaga, for the tax declaration of residents, non-residents tax return in Málaga and workers to whom the Beckham Law in Spain applies. Do not hesitate to contact Pérez Parras Economists and Lawyers, with offices in the centre of Málaga and Nerja, if you wish to incorporate Highly Qualified Foreign Professionals in the staff in Spain of your company.