Appendix · sources and what remains unconfirmed

Sources

What this investigation was written from, what could not be confirmed, and where each source stands. The five preceding parts rest on what is recorded here, and go no further than this inventory does.

Author's note

This account rests on official texts — Law 20/2022, the instruction issued by the Directorate-General for Legal Security and Public Trust (DGSJFP), the rulings of the Central Electoral Board, and the published portion of the Supreme Court order — on coverage by the Spanish and foreign press, and on public statements by those litigating the case and those defending it from government. Every verifiable claim carries its numbered reference at the foot of the page where it appears.

The standard of attribution is the same across all five parts. What is corroborated is stated as fact; what one side argues is written with that side's name inside the sentence. Where figures diverge, a range is given, with its date and its source, rather than a single settled number.

What could not be confirmed is set out below, case by case, rather than left out.

What could not be confirmed

The text of the Supreme Court order

Of the two orders, only the operative section of one has been published: the General Council of the Judiciary (CGPJ) links, from its press note, to pages 26 and 27 of the order issued in the precautionary-measures proceeding of appeal 1013/2026. These are two scanned pages, difficult to read, and nothing from them is quoted verbatim here. This is the source that supports the claim that the Supreme Court strikes down two specific passages of the instruction — Guideline Seven, section II.1 and section IV.3.5(d) — and not the instruction as a whole.

The rest of the order could not be consulted in full: the background and legal grounds do not appear in the published document, and no other way of consulting them was found. The reasoning quoted in these pages — the "well-founded, real and serious danger," the "extraordinary increase" — comes from the CGPJ's press note, from EL PAÍS and from Newtral: it is a second-hand quotation. Nor has the second order been located, the one in Vox's appeal 1015/2026, to which the Council refers under the identifier ECLI:ES:TS:2026:7773A, nor the dissenting opinion that, according to Newtral, accompanies the ruling.

Three dates coexist for this order, and two of them are correct. The General Council of the Judiciary announces the ruling on 8 September. The Central Electoral Board dates the orders to the 10th and says it received them that same day, which is also the day the legal reasoning is published. El Mundo uses the 9th, the least supported of the three. See Part 2.

The rapporteur judge

This does not appear in any of the sources consulted. The chamber and section are known — the Fourth Section of the Administrative Litigation Chamber — not who drafted the ruling. The decision closes with the formula "so it is agreed, ordered and signed by the Honourable Madam Justice and the Honourable Justices noted in the margin," and that margin does not appear in the published pages.

Authorship of the Electoral Board's dissenting opinion

The attribution to Carlos Vidal Prado, and the other three members' endorsement of it, comes from the Central Electoral Board's record of the ruling, and has not been checked against the primary source. The content of the dissent is quoted verbatim; the list of signatories is not.

The State Legal Service's "600,000 → 1 million"

This progression is attributed to Luis María Pardo, who gave it in one of his public statements, and has not been confirmed against the State Legal Service's original brief, which is not available. What is established through other channels is that, as of 1 August, the State Legal Service was working with roughly 370,000 nationalities already granted, 230,000 pending registration and 640,000 unresolved applications — as reported by El Mundo — and that it put at around 170,000 the naturalised citizens the injunction would leave unable to vote. The full series appears in Part 2.

The election decree

Neither the Royal Decree nor the 6 October edition of the official gazette (BOE) could exist at the time this edition closed, on 5 October: the next day's table of contents had not yet been published. The gap is one of timing, not of sourcing.

Ciudadanos's 2022 amendment

According to lawyer Lupe Sánchez, during the passage of Law 20/2022 Ciudadanos tabled an amendment to remove the requirement of proving exile, so that descendants of Spaniards abroad could claim nationality without proving they descended from exiles, and the amendment was voted down with the PSOE voting against it. If accurate, this carries real weight: it would mean that the instruction issued that same year introduced by administrative means what Parliament had just expressly rejected, and it is the argument behind the claim that the legislature's intent was unambiguous. The amendment has not been located in Congress's register of bills, and for that reason it is marked here as unverified.

The 2026 manoeuvre is a different matter. The amendment tabled by Sumar inside an education bill, passed with PSOE's vote in favour and against the advice of Congress's own legal staff, is documented, by El Español, The Objective, ABC, Vozpópuli, Libertad Digital, El Confidencial and Maldita.es. See Part 4.

The 7 September hearing

It is recorded as having been scheduled — ABC reported it on 28 July — but no documentary record that it took place has been located. The support for it is indirect and threefold: Luis María Pardo, in a statement the day before, announces "a hearing at 10 in the morning, tomorrow, 7 September"; in another statement, on the day of the ruling, he says "at the hearing I argued some very technical points"; and The Objective's 5 October piece states that "last Monday there were two hearings" and that "on Tuesday we learn the Supreme Court has ruled." These are partisan or press sources, none of them documentary. The distinction between a public hearing and deliberation — EL PAÍS mentions "four hours of deliberation" — remains unresolved.

The precautionary challenges before the National Court

The Objective ran the headline, on 13 September 2026, "The National Court considers striking down Sofía Puente's instruction." Of that article, only the headline is on record: the body could not be read, and a headline alone is not enough to assert anything about the substance.

The preliminary reference to the CJEU

This is a statement of intent by Iustitia Europa, from 22 September 2026, and there is no record that it was ever filed. It is included here because it is the first time anyone has framed the case's EU dimension, not because the reference exists.

Óscar Puente's remark

The quotation reproduced in Part 3 — translated here as "in fifty years of democracy it has had zero impact" — comes from Newtral's fact-check, which places it at minute 20:30 of Las Mañanas de RNE (translated from the original Spanish). The linked RTVE Play page is from 10 September, is mostly about Ceuta, and does not contain that remark in writing. What it does record verbatim is a different one: "what the court did, suspending the voting rights of a number of Spaniards whose nationality it does not dispute, is inexplicable" (translated from the original Spanish). The quotation is kept on the fact-checker's authority; it has not been checked against the audio.

The UCO report's "leading role"

The phrase reproduced in Part 5 — a "leading role" (translated from the original Spanish) in a network of influence and contracts — does not appear in either of the two pieces cited there, from EL PAÍS and LaSexta, and the UCO report itself could not be read: the phrase comes from coverage of the case, without it being possible to pin down which outlet first published it. The same applies to the name of the person under investigation, the dates of his tenure at Correos, the investigating body, and his earlier post as chief of staff, none of which appear in the headlines of those two pieces either. This is the gravest claim these pages make about a named individual, and the one with the least direct backing, which is why it is attributed in the body of the text to the press reporting on the report, and not to the report itself. See Part 5.

The 2023 postal-vote figures

The 2023 all-time high — 2.6 million applications and 94.2% of applicants who went on to vote — comes from two Maldita.es pieces that attribute both figures to Correos, the postal operator. No original publication by the postal operator itself has been located, so the figures stand on the fact-checker's word rather than on the source it says it drew them from. From those two pieces, and from the same outlet's fact-check debunking that summer's "rigged vote" accusations, the headline and the attribution are on record, not the link. See Part 5.

Primary sources

National press

La Razón · El Mundo · Confilegal · Infobae · EL PAÍS · ABC · Vozpópuli · RTVE · El Confidencial · elDiario.es · Cadena SER · Telemadrid · Diario de Navarra · El Debate · moncloa.com · Noticias de Gipuzkoa · 20Minutos · El Economista · Libertad Digital · El Independiente · Newtral · The Objective · UOC

International press

Financial Times · Reuters · BBC · The Guardian · Politico · CNN and CNN en Español · Euronews · EPC · EL PAÍS English · Le Monde · elDiarioAR · Perfil · El Cronista · La Voz del Interior · Sud Ouest · Ouest-France · Atlantico · DIARIO DE CUBA · gaceta.es

Interviews and public appearances

AppearanceContributes
Teresa Freixes
interview · Fuera de Guion Directo, 63 min
The thesis that the instruction is void from the outset, on grounds of normative hierarchy. The most extensive legal analysis.
Jorge Buxadé
statement, 34 min
The three documents the plaintiff side's case rests on: the instruction, the eighth additional provision, and the order.
Pedro Sánchez
institutional address, 9 min
Primary source for the announcement of the 29 November election.
Luis María Pardo
Iustitia Europa · three statements: 1 · 2 · 3
The reaction to the order, the State Legal Service's appeal, and the announcement of the CJEU route.
The Objective
video analysis, 9 min
The figure of 62 towns and the mechanics of consular assignment.
Judge Villegas
interview · ESdiario TV, 12 min
The "loophole" framing, and the distinction between the legal and the political planes.
ESdiario TV · Soto Ivars · El Gen Martínez
interview and panel discussions: ESdiario TV · Soto Ivars
The opinion material this investigation grew out of.

What the investigation concludes

What holds up against every source is this:

The electoral roll, once votes are cast, cannot be reversed. And the administration admits it cannot determine whom the injunction actually reaches.

Everything else is contested, and an effort has been made to mark it as such:

The case remains open. What is set down here is what is known, what is claimed, and where the line between the two runs.

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