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This article forms part of the CostaLuz Lawyers blog and is published for general informational and educational purposes only. It was prepared with the assistance of artificial intelligence tools and, before publication, was substantively reviewed and editorially approved by Maria de Castro, a Spanish-qualified lawyer registered with the Cádiz Bar Association under number 2745, founder of CostaLuz Lawyers and the person responsible for the editorial review of the published content.
This article does not constitute legal, tax, immigration, employment, estate-planning or investment advice and does not replace an individual assessment and the professional work of the appropriate CostaLuz Lawyers specialist. No action or omission should be based solely on this information.
Update — June 2026: Spain’s Supreme Court (judgment no. 620/2026, 21 May 2026, reaffirmed in June 2026) has struck down the national “Registro Único” short-term rental registry (the NRUA) created by Royal Decree 1312/2024, as an unconstitutional intrusion on the autonomous regions’ competences. The national NRUA registration number and its annual declaration no longer apply; your regional tourist licence (VFT/ETV/VV) and the Ventanilla Única still do. Full analysis: Spain’s Supreme Court strikes down the national rental registry.
If you run a short-term let in Spain, the December 2025 Order didn’t add a new rule — it switched on enforcement of the one that already existed, and from 2026 non-compliance is now actionable.
Quick Answer: Spain’s December 2025 order did not create a new short-term-rental rule — it switched on enforcement of the one that already existed, so from 2026 non-compliance is actionable. If you run a short-term let, treat existing registration and licence requirements as now enforced.
The publication in the Spanish Official Gazette (BOE) on 31 December 2025 of Ministerial Order VAU/1560/2025 of 22 December has generated significant confusion in the short-term rental sector.
Many operators ask the same question:
If the law was already in force, what does this Order actually add?
This article explains the answer clearly and precisely.
Executive summary
Related: Before taking on a short-term let, run through a rental-property due-diligence checklist.
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- The obligation already existed under Royal Decree 1312/2024.
- The December 2025 Order does not create a new obligation.
- What it does is complete the system, by:
- approving the official reporting model,
- fixing how, when and where information must be filed,
- and making the obligation fully operational and enforceable from 2026.
In short:
the Order does not change the rules — it makes them executable.
This reporting framework forms part of Spain’s broader legal regime governing rental property ownership and operation. A structured overview of the applicable rules, risks and compliance duties can be found in our complete guide to rental property in Spain.
The European origin: Regulation (EU) 2024/1028
Regulation (EU) 2024/1028 of 11 April 2024 establishes harmonised rules across the EU for the collection and exchange of data on short-term accommodation rentals.
Its purpose is to allow public authorities to:
- access reliable and standardised data,
- assess the real impact of short-term rentals,
- and design proportionate and evidence-based regulation.
Importantly, the Regulation:
- applies only where Member States establish registration procedures, and
- requires the creation of a single digital entry point (a digital “single window”) at national level.
How Spain implemented the EU Regulation
Spain implemented Regulation 2024/1028 through Royal Decree 1312/2024 of 23 December, which:
- creates the Single Registry of Rentals (Registro Único de Arrendamientos),
- establishes the Digital Single Window for Rentals (Ventanilla Única Digital de Arrendamientos),
- and regulates the collection, verification and transmission of data on short-term rentals.
Two distinct systems
- Registration is carried out through the Land Registry or the Registry of Movable Property.
- Data aggregation and transmission is handled through the Digital Single Window, under the Ministry of Housing and Urban Agenda.
This is the only registration system applicable in Spain for the purposes of the EU Regulation.
The key obligation that already existed: annual reporting
Article 10.4 of Royal Decree 1312/2024 already required that:
- every twelve months, an informative model of short-term rentals must be filed,
- one model per property/unit,
- including at least:
- an anonymised list of the rentals carried out,
- and the declared purpose of the rental, different from permanent housing.
Correctly distinguishing between short-term tourist rentals and genuinely temporary rentals is essential, as misclassification directly affects registration validity, reporting obligations and sanction risk.
Accepted purposes include:
- tourist or holiday stays,
- work-related stays,
- studies,
- medical treatment,
- or any other genuinely temporary purpose.
However, until December 2025, one crucial element was missing.
The practical gap before December 2025
Although the obligation existed in law:
- there was no approved official model,
- no defined format,
- and no clear filing channel.
As a result, the obligation existed in abstract legal terms, but could not be uniformly applied, verified or enforced.
This is exactly the gap the December 2025 Order fills.
What the December 2025 Ministerial Order adds
1. Approval of the official reporting model
The Order formally approves the official informative model of short-term rentals, set out in its Annex.
This model:
- standardises the data to be declared,
- ensures consistency and comparability,
- and provides legal certainty to operators.
Without an approved model, compliance could not be legally demanded.
2. Filing method, timing and format
The Order establishes that:
- The model must be filed every February, with data from the previous year.
- For rentals carried out in 2025, the first filing must take place in February 2026.
- A separate model must be filed for each property/unit.
Format
- The model may be filed electronically or on paper.
- Electronic filing must be made through the electronic platform of the College of Property Registrars.
- The digital model must be submitted as a single XBRL file, using the official XBRL Arrendamientos 2025 taxonomy.
The taxonomy is:
- free to access,
- publicly available,
- and designed to allow scalable, automated reporting.
3. Verification powers and evidence retention
If the registrar has well-founded doubts about the declared rental purpose, they may request supporting documentation.
This means operators must:
- correctly document the temporary nature of rentals,
- and retain evidence available at the time of filing.
4. Consequences of misuse of the registration number
If the reporting model shows that a registration number has been used for a different category or purpose than the one for which it was granted:
- the registrar will withdraw the registration number,
- the registry note will be cancelled,
- and the unit will lose its registered status.
This is a critical compliance risk for misclassified rentals.
For operators managing multiple units or platforms, compliance is no longer a one-off registration exercise but an ongoing legal and reporting process that must be actively monitored.
Entry into force: why 2026 matters
The Ministerial Order enters into force on 2 January 2026.
From that date:
- the reporting obligation is fully operational,
- compliance can be verified,
- and sanctions may be imposed.
Registration alone is no longer sufficient.
Registration + reporting + evidence retention form the complete compliance framework.
Key takeaway
The December 2025 Order does not change the law.
It makes an existing obligation technically, legally and operationally enforceable.
For operators already registered, the focus in 2026 shifts from registration to structured reporting and compliance management.
How CostaLuz Lawyers can help
Our property law team advises owners and operators across Spain on the full lifecycle of rental property compliance, from registration and reporting to inspections, disputes and administrative defence.
CostaLuz Lawyers advises property owners, managers and operators on:
- correct classification of short-term and temporary rentals,
- national registration and compliance strategy,
- preparation and review of annual reporting models,
- evidence retention and risk prevention,
- administrative defence in case of inspections or disputes.
If you operate short-term or temporary rentals in Spain, 2026 is the year to professionalise compliance.
Call to action
If you operate short-term or temporary rentals in Spain, 2026 is the year to get compliance right — before an inspection, a platform restriction, or a registry issue forces your hand.
Send us:
- the property address (or portfolio locations),
- the intended rental type (tourist / temporary / housing),
- and any existing registration number or draft contract.
We’ll review your setup, confirm what applies to your case, and propose the safest compliance route.
Email: web@costaluzlawyers.es
Phone: +34 919 49 93 42
About CostaLuz Lawyers and María de Castro
You can read testimonials from hundreds of satisfied clients, going back to 2006, on our website, on Google Reviews and on EyeonSpain.
Reviewed by María de Castro, Abogado no. 2745, Ilustre Colegio de Abogados de Cádiz. CostaLuz Lawyers has supported international buyers since 2006 on EyeonSpain with guidance and advice on the legal aspects of life in Spain. Included in the lawyers lists of the UK and Ireland embassies. Updated 22 Nov 2025.
María Luisa de Castro’s work, founder of CostaLuz Lawyers, is backed by a strong presence in specialist media and professional directories. Her track record as a Property Law and Consumer Real Estate Law (Derecho de Consumo Inmobiliario) specialist can be seen in her guides for international audiences on Expatra, in her long-running blogs on Spanish off-plan protection and Ley 57/1968 on EyeOnSpain , in her legal analysis for Confilegal and Legal Today, and in her contributions for the Spanish Bar Council (Consejo General de la Abogacía Española) and the Centre for Consumer Studies at the University of Castilla-La Mancha.
Her work is also profiled on international retirement and expat platforms such as Retirement Abroad, and has been highlighted by expat media including The Olive Press News Spain and The Local Spain among other specialist expat and legal forums.
Her legal work has also been featured or referenced in respected international and Spanish media, including The Telegraph, The Times, the BBC, El País and El País English, The Local Spain, The Olive Press and other reputable outlets, particularly in connection with landmark court rulings on Ley 57/1968 and Spanish consumer protection.
CostaLuz Lawyers is also included in the official lists of English-speaking legal professionals for British and Irish nationals in Spain, as compiled by the UK government’s “Spain: list of lawyers” and by the Embassy of Ireland in Spain and its honorary consular network.
Related Rental & Property Law Guides
Disclaimer: This information is provided for general guidance purposes only and does not constitute personalised tax or legal advice. Each case must be assessed individually according to the client’s specific circumstances. It is essential to consult a qualified specialist before taking any action or making any decision.
Legal Notice: The content on this page is provided for general informational and educational purposes only. It does not constitute legal advice and should not be relied upon as such. No action should be taken based solely on this content without first seeking independent professional legal counsel. Each case requires individual assessment based on its specific circumstances. CostaLuz Lawyers accepts no liability for actions taken or not taken based on this content.
Thinking of Buying a Spanish Property to Rent Out?
The December 2025 ministerial order changes the registry layer of the four-level compliance stack. Before you commit to a purchase, verify the property is registrable AND permitted at the other three levels.
CostaLuz Lawyers’ QuickLease service is the Rental Compliance Pre-Purchase check that verifies the property across all four legal levels (community, municipality, regional and registry) before you sign. 1.000€ + IVA. Reviewed by María Luisa de Castro.
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CostaLuz Lawyers regularly advises short-term rental operators on Spain’s registration and reporting duties.
Reviewed by María Luisa de Castro, CEO at CostaLuz Lawyers — specialist in Spanish property & tourist-rental law — Updated 2026
This is general information, not definitive legal advice — every case requires individual analysis.