Accumulation of days due to particular issues to other permits or licenses, and in particular, to the license without pay.

The question raised is about the possibility of accumulating the days for particular matters to the leave without pay, as well as to other permits or licenses.

In the first place, the legal framework for implementation must be analysed. Royal Legislative Decree 5/2015, of 30 October, approving the consolidated text of the Law on the Basic Status of Public Employees, contains in its article 48.1 letter k) the regulation of days for particular matters of public officials, noting that they will have a number of six per year.

With regard to days for private affairs, the Resolution of 14 April 2026 of the State Secretariat for the Civil Service, which provides instructions on working hours and hours for staff serving the General Administration of the State and its public bodies, provides in its ninth paragraph, seventh paragraph, that:

“Days of leave for private reasons may not be accumulated for annual leave periods. The staff may distribute these days at their convenience, subject to the authorization of their superiors and always respecting the needs of the service. When for these reasons it is not possible to enjoy the aforementioned permit before the end of December, it may be granted until the following 31 January.

Without prejudice to the above, and provided that the needs of the service allow it, the days of leave for private reasons as well as, where appropriate, the days of leave provided in the following section, may be accumulated to the holiday days that are independently enjoyed.”

From the above it follows that workers may distribute the days of leave as they wish for particular matters, with respect to the needs of the service.

For its part, the leave for own affairs is regulated in article 73 of the Civil Servants Act of 1964, a provision still in force in accordance with the provisions of the Derogatory Provision and the 4th Final Provision of the TREBEP, which states that:

“Licenses may be granted on their own behalf. Such licences shall be granted without payment, and their cumulative duration may not exceed three months in two years.”

Taking into account the above, it can be concluded that, in principle, there seems to be no obstacle to be able to accumulate the days due to particular issues to other permits or licenses.

Paragraph 9.7 of the Working Time and Hours Instructions expressly establishes the impossibility of accumulating the days of leave for private reasons to the annual vacation periods, without prejudice to the exception collected in relation to the days of vacation of independent enjoyment. However, nothing specifies as to the accumulation to other permissions or licenses.

In the absence of concretion in the regulation, and according to a systematic and teleological interpretative exercise of the rule, it is difficult to deduce from the literal tenor of the precept the will to establish an additional restriction on the enjoyment of this permit.

The interpretation contrary to this point would imply introducing a restriction on the enjoyment of an unforeseen permit, taking into account that the aforementioned precept expressly includes limitations and conditions.

Therefore, in principle, days for private matters may be accumulated to other permits or licenses.

All of the foregoing is without prejudice to recalling that, according to the regime of competences of this management center, the answers to queries issued by this general directorate are merely informative and, consequently, are not of a binding criterion, nor do they give rise to rights or expectations of law, nor imply any link with the type of procedures to which they refer. Furthermore, in the absence of a mandatory or binding nature, the bodies receiving such replies may, where appropriate, finally take a decision that does not correspond to the opinion contained therein.

The responses to queries contained in this bulletin address the issues raised in the light of the regulations in force at the time of their issuance, so that such responses may be affected by subsequent legislative changes or judicial decisions.