Of all the insurance gaps we see among British expats in Spain, this is the one that catches the most people out. You become a Spanish resident, you keep renewing the annual travel policy you’ve held in the UK for years, and you assume it still works. It almost certainly doesn’t. And the moment of discovery — usually at the worst possible time, after a fall in Portugal or a hospitalisation in Thailand — comes far too late to fix.
2026 has brought this into sharper focus. Several large UK travel insurers tightened their residency declarations during 2025, the FCDO updated its travel advice pages to flag the issue explicitly, and Spain’s insurance regulator (the DGSFP) has been more vocal about the local market’s obligations to residents. Here’s where things stand and what British residents in Spain need to do about it.
The residency clause in plain English
Every mainstream UK travel insurance policy contains a clause — usually under “eligibility” or “who can buy this policy” — that requires the policyholder to be a permanent resident of the United Kingdom and registered with a UK GP. Some insurers add the further condition that you must have lived in the UK for at least six months of the preceding twelve.
If you’re a Spanish resident — meaning you hold a TIE, are registered on the padrón, and are tax-resident in Spain — you do not meet that definition, regardless of how long you’ve held the policy or how many premiums you’ve paid. The policy is, in insurance terms, voidable from inception. The insurer can decline a claim and, in some cases, refund the premium and walk away.
This isn’t a technicality. It’s the basis on which the policy was priced, underwritten and reinsured. UK travel insurance assumes the NHS will pick up your repatriation triage, that any pre-existing conditions sit on UK medical records, and that the policyholder is geographically and contractually rooted in the UK. None of that holds once you’ve moved your life to Spain.
What the FCDO and DGSFP actually say
The FCDO’s Spain travel advice page now carries an unambiguous note for British nationals living in Spain: “If you live in Spain, your travel insurance should be bought from an insurer authorised to sell to Spanish residents.” That sentence didn’t exist in the 2023 version. It was added after a run of consular cases involving residents whose UK policies refused to pay.
On the Spanish side, the DGSFP (Dirección General de Seguros y Fondos de Pensiones) regulates the insurers and intermediaries that can sell cover to people domiciled in Spain. A travel policy bought from a UK-only insurer that doesn’t hold passporting or local authorisation isn’t a regulated Spanish product, which also means you have no recourse to the Spanish ombudsman or compensation scheme if something goes wrong.
The repatriation gap that catches people out
The most expensive single line in any travel claim is medical repatriation. An air ambulance from Southeast Asia or the Americas back to Europe routinely costs €80,000–€150,000; from further afield, more. UK policies typically repatriate to the UK because that’s where your home, your GP and your continuing care are assumed to be. For a Spanish resident, that’s the wrong destination — you need to come back to Spain, where your healthcare, your home and your family are.
Even when a UK insurer pays a Spanish resident’s claim as a goodwill gesture, the repatriation is almost always organised back to a UK airport, with onward travel to Spain at your own cost and arranged without medical escort. For a stable patient that’s manageable. For someone who needs a stretcher transfer, it isn’t.
A travel policy sold to Spanish residents is built around repatriation to Spain. That single design choice is worth more than any premium difference.
What about the EHIC or GHIC?
The UK’s GHIC card is not valid for British nationals who are Spanish-resident. Once you’re registered in the Spanish healthcare system, you use the Spanish TSE (Tarjeta Sanitaria Europea) for travel within the EU/EEA, which gives you state-equivalent care in the country you’re visiting on the same terms as a local. The TSE is not travel insurance — it doesn’t cover private treatment, repatriation, cancellation, baggage or any of the things people actually claim for — but it’s the document you carry alongside a Spanish-issued travel policy.
The Spain-based travel insurance market in 2026
The local market has changed noticeably over the past eighteen months. Three trends are worth flagging:
- Annual multi-trip policies for residents have become mainstream. Two years ago, most Spanish travel cover was sold trip-by-trip. Insurers serving the expat market now offer annual policies with worldwide cover and per-trip limits of 60, 90 or 120 days — useful for residents who travel to family in the UK several times a year.
- Pre-existing condition declarations are handled properly. The better Spain-based policies now ask the same medical screening questions you’d expect from a UK specialist insurer, and price accordingly. This was a weak spot in the local market a few years ago.
- Repatriation limits have risen. Standard medical and repatriation cover on resident policies now typically sits at €500,000 or unlimited, in line with the actual cost of long-haul air ambulance work.
The result is that the gap in cover and quality between “a UK policy I’ve always had” and “a proper Spanish resident policy” has narrowed to the point where there’s no good reason to stay on the wrong side of it.
What to do this week if you’ve been renewing the UK policy
If you’re Spanish-resident and you have a UK travel policy currently in force, do three things. Read the eligibility clause — you’ll find the residency requirement quickly. Don’t book any further travel relying on it. And replace it with a Spanish-issued resident policy before your next trip, including any UK visits, because cover works in both directions.
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This article is general information based on UK and Spanish insurance market practice and regulatory guidance current at the date of publication. It is not legal or financial advice. Policy terms vary by insurer and individual circumstances; always read the policy wording and eligibility clauses in full before relying on cover. Insurance products are subject to the insurer’s terms and conditions and to authorisation by the relevant regulator.