ES-LEG-D-L1.1

Refrendo: who needs the legislation test

ES-LEG-D-M1 · The test and who needs it · ES-LEG-D-M1-A Refrendo eligibility, nationality rules and how the DGMM runs the 30-question test.

The test is not a qualification in itself: it is the price of a **management-level refrendo** on a Spanish-flag ship. Get the eligibility rules straight before you open a law book.

Where candidates go wrong

Most foreign officers arrive thinking the legislation test is a route to a Spanish ticket. It is not. It is one condition of the refrendo (endorsement recognising a foreign CoC) at nivel de gestión (management level). Pass it with an ineligible CoC and you have a certificate you cannot use. The second trap is nationality: the test does not cure it.

The chain of recognition

Under RD 269/2022, anyone serving as master, officer or GMDSS operator on a Spanish ship on a foreign título de competencia (certificate of competency) needs DGMM recognition (art. 65.2). Recognition is issued as a tarjeta profesional (professional card) that expires with the original CoC (art. 68.2; ministry page).

Where your CoC was issued Route
EU/EEA State Reconocimiento directo (direct recognition), whatever your nationality (art. 69)
Third country Only if on the EU Commission list and Spain has a DGMM agreement (art. 70)
Endorsed by a State other than the issuer Never recognised (art. 67.4)

The 2026 convocatoria names the agreement States: Argentina, Chile, Peru, Cuba, Ecuador, Uruguay, Ghana, Egypt, Georgia, Philippines, Cabo Verde, Jordan, Ukraine, Turkey and Indonesia. The UK, USA and Marshall Islands are not there. An MCA Master (Yacht) cannot currently be refrended for a Spanish-flag yacht.

Where the test comes in

Art. 67.3 adds the prueba sobre conocimiento de la legislación marítima española (Spanish maritime legislation test), or an equivalent course, for master, chief mate, chief engineer, second engineer and any other management-level post. This is Spain applying STCW reg. I/10.2. Ratings' certificates of proficiency need no recognition at all.

Nationality

LNM art. 162 and TRLPEMM art. 253.2: the capitán (master) and primer oficial de puente y cubierta (chief mate) of Spanish ships must be nationals of an EEA State; third-country family members of EU citizens are assimilated. On merchant ships at least 50 % of the rest of the crew must be Spanish or EEA. The convocatoria repeats the rule: a non-EEA national may not even sit the deck test for those posts.

WARNING — Swiss candidates The convocatoria lets Swiss citizens sit the test and lists Switzerland among the EU/EEA issuers. Switzerland is not EEA. Treat the list as indicative and ask the DGMM before relying on it.

While you wait

Art. 68.3 allows a documento justificativo (provisional document) for up to 3 months, issued within 10 days, if the file is complete and the case genuinely urgent. The shipowner must show civil-liability cover for your functions (art. 68.4). Without the legislation test, the ministry says the document records only the operational-level post. The DGMM has 3 months to decide; silence means refusal (art. 68.5).

Yachts

RD 269/2022 excludes only buques de recreo no dedicados al comercio, sin tripulación profesional (art. 2.1.b). But RD 804/2014 art. 7.1 requires professional crew on every buque de recreo over 24 m, private or commercial. In practice the refrendo rules reach Spanish-flag superyachts.

What the examiner wants to see

Nothing from this lesson is examined directly, but the tribunal will not admit you without a valid, refrended management-level CoC from an eligible State. Check eligibility first.

Vocabulario del examen

Español English
refrendo endorsement (recognition)
título de competencia certificate of competency
nivel de gestión management level
tarjeta profesional professional card
documento justificativo provisional document

Independent study. xplor is not affiliated with the Dirección General de la Marina Mercante, any Spanish regional government or the Govern de les Illes Balears, and awards no title, certificate or endorsement. Only the DGMM test, or a DGMM-approved course, satisfies RD 269/2022 art. 67.3; this course is neither. AI-drafted content pending subject-matter-expert review.