Update 29 May: I understand that thanks to the work by Karl McLaughlin (referred to below), the situation is now regularized and corrected in the Playa de las Américas comisaría. As of yesterday, police officers dealing with the public have been informed personally by the comisario that Certificados de Registro do not need to be renewed. Enquirers should now no longer find that they are told renewal is required, and indeed, will be correctly advised that they can be renewed upon request, but that this is entirely optional since the original certificates are permanent in their own right.
Original post 17 May: As I’ve said previously, whilst it appeared that the southern comisaría in Playa de Las Américas was informing resident expats that their permanent Certificados de Registro had to be renewed every five years, they were not actually within their legal rights in doing this. I was only aware of one particular case, but reports were widespread that the police were telling people that they must renew certificates even if those certificates bore no expiry date. Now, it is clear: they have either been doing something they are not allowed to do, or their stance has been misunderstood by the public.
Regardless of where the confusion arose, the situation is now perfectly clear and simple: no-one has to renew their Certificado de Registro. The only legislative change in the last year or so has been for new applicants who, since March last year, have to prove they can afford to live in Spain and have cover for healthcare. Existing Certificados de Registro, however, are permanent once an EU-national holder has been in Spain for five years. Certificates bearing an expiry date will have been issued to applicants who had not been in Spain for five years at the point of application: these may be exchanged for ones that state they are permanent if the holder wishes, hence the police being prepared to issue renewals, but no-one is required to do so because EU nationals are automatically allowed permanent residence in another member state once they have legally resided there for five years.
I have been discussing the matter with investigative journalist Karl McLaughlin, who has recently been seeking formal clarification from the department of the Interior Ministry responsible for every extranjeria in Spain. Madrid confirms not only that there is no requirement to renew, but also that no instruction or communication in this respect has been sent to any comisaría in the country. Karl has now written an article for Island Connections (see pp2-3 of THIS edn), and tells me that the queries were addressed to the Ministry of the Interior, with the reply from the Comisaría General de Extranjería y Fronteras, i.e. the highest authority of the police stations that have Extranjería sections for issuing residence cards, registration certificates etc.
He has given me the original of the official response he has translated for the Island Connections article. It is HERE so if you would like Madrid’s confirmation in writing that you do not need to renew your Registro, please click to download and print it off to carry with your Registro. The only document that needs to be renewed every five years is a resident card of a non-EU national spouse of an EU-national resident, a status that very few British expats need to be concerned about. For the rest, whether your Registro says it is permanent or not, it does not need to be renewed.