Spain’s New Short-Term Rental Register: Who Is Actually Required to Register?

A recurring question we continue to receive at Bravo Legal is: Must every owner who lets a property on a short-term basis register, or only those advertising on platforms such as Airbnb or Booking?

The answer requires a careful reading of the Decree.

1. What the Decree Regulates

The Royal Decree established:

• A mandatory registration number for certain short-term rental units.

• A centralised digital system for data transmission between online platforms and the Spanish authorities.

• Obligations for both hosts and online rental platforms.

The purpose of the regulation was — and remains — primarily to control and standardise information relating to short-term rentals offered through digital platforms.

2. What Is Considered a “Short-Term Rental”?

The Decree applies to rentals:

• For a temporary purpose (holiday, work placement, studies, medical treatment, etc.).

• For remuneration.

• Whether tourist or non-tourist in nature.

• Whether covering an entire property or part of it (where legally permitted).

3. The Key Point: When Is Registration Mandatory?

The crucial provision is found in Article 5 of the Decree, as it states that landlords must obtain a registration number (NRUA) in order to offer their property through online platforms.

Furthermore, Article 10.6 makes it clear that: Properties may not be marketed through online platforms without the corresponding registration number.

The wording is precise. The obligation is expressly linked to commercialisation via online short-term rental platforms.

4. Does This Apply to All Short-Term Rentals?

Based on a systematic reading of the Decree:

• The scope of regulation is centred on platform-based intermediation.

• The registration number is a prerequisite for listing on online platforms.

• The compliance mechanisms (data transmission, suspension of listings, removal orders) operate exclusively through digital platforms.

There is no provision imposing a general obligation to register solely because a property is used for short-term letting.

5. Practical Distinction

A. Owners advertising on Airbnb, Booking, Vrbo, etc.

They are required to:

• Obtain a registration number from the Land Registry.

• Display that number on the platform.

• Keep their information updated.

• Submit annual reporting as required.

Failure to do so results in removal of the listing.

B. Owners renting without using online platforms

For example:

• Direct private contracts.

• Lettings arranged through traditional estate agents.

• Repeat tenants.

• Corporate or relocation rentals without platform advertising.

Under the wording of Royal Decree 1312/2024, there is no express obligation to obtain the national registration number, provided the property is not advertised via an online platform.Therefore, only those rentals should be declared in the Informative Return on Short-Term Lettings. If you have obtained an NRUA but do not advertise your property on online platforms, you are not, in principle, required to submit the new informative return. However, you should be aware that the NRUA may be revoked if it is not being used in accordance with its registered purpose.

6. Important Caveat

This does not mean that such rentals are unregulated.

Owners must still comply with:

• Regional tourist licence requirements (where applicable).

• Urban planning regulations.

• Community of Owners’ restrictions.

• Tax obligations.

• Any local or autonomous community sanctioning regimes.

The national register operates as a digital control mechanism linked specifically to platform listings.

7. Conclusion

Under Royal Decree 1312/2024, registration is mandatory only for short-term rentals that are offered through online platforms. Therefore, only those rentals should be declared in the Informative Return on Short-Term Lettings. There is no blanket obligation requiring all short-term rental owners to register if they operate entirely outside digital platforms.

However, the regulatory landscape continues to evolve. Property owners should therefore review their specific letting model carefully and seek professional advice where appropriate.

If you require assistance assessing how this regulation affects your property or your letting structure in Spain, our team at Bravo Legal will be pleased to advise.