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@rdavid2 sorry for taking super extra long, is this something you're interested in? We never found an issue (but maybe also no foreigner with an 8 char NIE used our service :p )
I have a question about the validation, an old nie with 8 numeric digits still be valid? because the validation says not.
Reference:
https://es.wikipedia.org/wiki/N%C3%BAmero_de_identidad_de_extranjero
The Law INT/2058/2008 reduces to 7 the numerioc characters but keeps vigent the old NIES with 8 numeric characters.
Your validation for nie says exactly 7 times for numeric digits
const NIE_REGEX = '#^(?['. self::NIE_TYPES .'])(?[0-9]{7})(?[A-Z])$#';
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