Posted: Sat Jan 18, 2020 2:17pm
Hi Jillbow,
This link to Spain's DGT website:
https://sede.dgt.gob.es/es/permisos-de-conducir/canje-permisos/canje-permisos-extranjeros/canje-renovacion-sustitucion-uk/canje-permisos-uk/index.shtml#
states that you need to submit your application for exchange by 31 January 2020 and in the list of "What do you need", it includes the requirement, "For EU citizens: certificate of registration of foreigners" (i.e. Residencia), in which case, the answer to your question is "No".
However, it also refers to a 9 months 'grace' period, but isn't explicit whether that 9 months starts counting down from 1 February 2020 (ending 31 October 2020), or the end of the Brexit transition period, i.e. from 31 December 2020 (ending 30 September 2021). Then, in the section "What means have to apply", point 2. states "Any request made after the 30/01/2020 will be processed" - this may refer to applications made on the final deadline day of 31 January 2020, but this is Spain, so.......?
I may be clutching at straws here, but Spanish bureaucracy has a habit of being anything other than clear cut. Also, I changed the language on the web page to English, so the translation is literal; there may be slightly different nuances when read in Spanish. In your situation, I'd ask for definitive advice from a Spanish lawyer.
Kind regards,
Kim