Goalposts do not move. The Spanish govt has issued Ley 5/19 dated 01 March and was rapid published by the Spanish government before dissolution by the King. I have all 36 pages in English translation...it covers all from TIE, Medical, Working, School and Driving Licences. BUT a caveat...its primary aim was to regulate for a no deal exit on the 29th March 2019
. But the regulations are prima facia good until repealed or replaced by a future majority working Spanish government...and that is unlikely until about mid 2020. The transition period remains December 2020 for these Spanish regulations Ley 5/19....therefore any extension by UK requires a new Ley by the Spanish govt.
You should read the following which is dissolved from those contingency laws...5/19
https://www.lamoncloa.gob.es/lang/en/br ... dence.aspx
Old chestnut the Padron...you should not apply for the Padron until you are " habitually resident in your electoral catchment".
…..therefore you should not apply for Cert of Reg EU until after 6 months. BUT...chicken before the egg. CNP require one for registration with them. Padron office will issue you one after 90 days...BUT the Padron office tells you it ( ..the Padron for CNP) is only valid for 3 months. You should return with the CNP issued Cert of Reg within the next 3 months...show them and they re-validate the Padron for 5 years (the standard validity period - less period changes of personal details, official body verification and census requirements). Therefore 3 months from estancia and 3 months to get Cert of Reg equals the minimum of 6 months for Padron habitual residence.
Note: A letter regarding pensions (uplifts etc), medical cover (SIP and EHIC) etc is on its way to all officially registered residents in Spain from DWP and DHSS.
Bottom line...if you have been living "under the radar" for many years without registration...you will have a buggers muddle proving settled status (domicile) for a TIE card with the CNP.