Rayo Vallecano, Levante and Elche have all made direct enquiries about the 26-year-old's situation, according to journalist Matteo Moretto. All three clubs are exploring the financial terms of a potential transfer and looking to gain an advantage in talks with the player's camp.
Kumbulla has already spent the past two seasons on loan in Spain, making 36 appearances for Espanyol and a further 10 for Mallorca, and is now seeking regular minutes and a prominent role heading into the new campaign.
AS Roma have made clear that Kumbulla does not figure in Gian Piero Gasperini's plans for the season ahead, leaving the defender training away from the rest of the squad at Trigoria while the club works to find him a new home. His contract in the Italian capital runs until 2027, giving Roma some leverage in negotiations even as they look to move him on.
The defender's familiarity with Spanish football, built up across two loan spells, appears to be a significant factor behind the interest from all three suitors.
Rayo, fresh off reaching last season's Conference League final, are exploring options to strengthen their defence, while Levante are looking to add a centre-back with top-flight experience to increase competition at the back. Elche, too, see Kumbulla as a player who fits the profile they are targeting this summer.
No official figures have yet emerged over a potential fee, with the coming weeks expected to prove decisive in determining which of the three clubs, if any, is able to advance the operation and bring Kumbulla back to Spain for a third spell.
Kumbulla arrived at Roma from Hellas Verona and has spent much of the past three seasons away from the Italian capital on loan, first in Serie A and then in LaLiga, without ever fully establishing himself back at Trigoria.
His displacement from Gasperini's squad plans mirrors a wider reshuffle at Roma this summer, with the club working through a list of players considered surplus to requirements as it looks to reshape the squad for the season ahead.