Spanish Supreme Court annuls the Single Register of Short-Term Rental Agreements (NRUA) procedure: one fewer requirement for tourist accommodation
Less than one year after the Single Register of Short-Term Rental Agreements procedure took full effect, established under Royal Decree 1312/2024 of 23 December, the Supreme Court, in Judgment 620/2026 of 19 May 2026, has annulled the Single Register of Short-Term Rental Agreements.
This ruling is of particular significance for owners of tourist apartments, managers of holiday rental properties, short-term rental operators, and real estate investors, as the Single Register of Short-Term Rental Agreements introduced a system whereby the ability to advertise properties on digital platforms was conditional upon obtaining a State registration number, making such number an operational requirement for the marketing of short-term accommodation.
What exactly has the Supreme Court annulled?
Judgment 620/2026 of 19 May 2026 examines the scope of Royal Decree 1312/2024, which established two principal instruments affecting short-term rental arrangements: the Single Register of Short-Term Rental Agreements procedure and the Digital Single Window for Short-Term Rentals.
The former required the obtaining of a registration number in order to market units intended for short-term rental via digital platforms, while the latter was designed to channel the collection, transmission, and exchange of data relating to the Single Register of Short-Term Rental Agreements.
It should be noted that the concept of short-term accommodation rentals is not limited to short tourist stays. Its definition is broader and also includes rentals not intended for tourism purposes, irrespective of whether they are carried out on a professional or non-professional basis, and whether on a habitual or occasional basis, such as those intended for work-related, academic, medical, or other temporary purposes. It also includes vessel rentals subject to Regulation (EU) 2024/1028 of the European Parliament and of the Council of 11 April 2024.
The Single Register of Short-Term Rental Agreements (NRUA) and the regional competence dispute
The Generalitat Valenciana challenged the regulation, arguing that the State had encroached upon devolved competences in matters of tourism and housing.
The Supreme Court partially upheld the claim and annulled the provisions of the Royal Decree relating to the registration procedure. It held that the procedure “exceeds State competence and overlaps with existing regional registers concerning the registration of properties intended for tourist rentals”
In particular, the Court found that the regulation established “a nationwide registration procedure requiring a marginal entry in the Land Register and the Register of Movable Property for properties, or parts thereof, intended for short-term rental activity advertised on online platforms”.
However, the judgment does not entail the complete annulment of the regulatory framework. The Court upheld the Digital Single Window for Short-Term Rentals and the system for data transmission and exchange insofar as it does not depend on the annulled registration procedure. The transmission of information for statistical purposes is also maintained.
The Court held that this regulatory framework complies with Article 10 of Regulation (EU) 2024/1028 on the collection and exchange of data relating to short-term rental accommodation services. It further considered that it falls within the State’s coordinating powers, without exceeding what may be regarded as coordination and information-exchange competence.
Impact of the ruling on tourist apartment owners
The main practical consequence of the annulment of the Single Register of Short-Term Rental Agreements is that registration with the Land Register or the Register of Movable Property is no longer required in order to obtain the State registration number that previously enabled short-term accommodation to be advertised on digital platforms.
However, this does not mean that owners may freely market such accommodation without complying with regulatory requirements. The judgment removes a State-level administrative burden but does not eliminate the existing regulatory obligations applicable to tourist accommodation.
Accordingly, the regional and municipal regulatory framework remains fully in force. Where regional legislation requires registration in a tourist accommodation register, a licence, a responsible declaration, a tourist registration number, or any other authorisation, such requirements continue to apply.
The situation may differ in certain short-term rentals not intended for tourism, such as stays for work or academic purposes, where the removal of the State registration number may result in a more significant reduction in administrative burdens.
Obligations that remain in force following annulment of the NRUA
The annulment of the Single Register procedure represents a relief for many owners and operators of tourist accommodation, as well as for individuals who previously rented out student accommodation via platforms and were required to comply with additional administrative procedures, incur costs, or face operational constraints.
Furthermore, the ruling corrects a situation of regulatory duplication, removing the requirement for properties already subject to regional or municipal registration systems to be additionally included in a State register. This duplication had imposed an additional burden not only on tourist accommodation operators, but also on owners who did not directly exploit the property but were nevertheless affected by the registration entry in the Land Register.
Nevertheless, the operation of short-term rental accommodation for tourist purposes requires compliance with the applicable regional and municipal legislation in each case, including licensing procedures, responsible declarations, tourist registrations, planning requirements, and possible local restrictions.
Conclusion: fewer State-level burdens, but not less regulatory control
It should also be noted that the Horizontal Property Act (Ley de Propiedad Horizontal) remains applicable. Building regulations, by-laws adopted by the owners’ association, or registered restrictions may affect the feasibility of tourist use. Accordingly, before operating or acquiring a tourist apartment, a comprehensive legal review of the property is advisable, from administrative, civil, and property law perspectives.
FAQ on the Single Register of Short-Term Rental Agreements
What is the Single Register of Short-Term Rental Agreements?What is the Single Register of Short-Term Rental Agreements?
It was the State procedure established under Royal Decree 1312/2024 for obtaining a registration number enabling the marketing of short-term accommodation on digital platforms
What has the Supreme Court annulled?
The Supreme Court has annulled the provisions relating to the Single Register procedure, holding that it exceeded State competence and overlapped with existing regional registers.
Does the ruling annul the entire Royal Decree 1312/2024?
No. The ruling does not annul the entire regulation. It maintains the Digital Single Window for Short-Term Rentals and the system of data transmission and exchange insofar as it does not depend on the annulled procedure.
Is a State registration number still required to advertise tourist apartments?
No. The main practical consequence is that registration with the Land Register or Register of Movable Property is no longer required to obtain the State registration number previously used for advertising short-term accommodation.
Can owners freely operate tourist accommodation after this ruling?
No. The annulment removes a State-level requirement but does not remove regional or municipal regulatory obligations.
What requirements remain in force for tourist apartments?
All requirements under applicable regional and municipal legislation remain in force, including tourist registration, licensing, responsible declarations, registration numbers, and other authorisations.
Does the ruling apply equally to all short-term rentals?
Not necessarily. It may differ for non-tourist short-term rentals, such as stays for work, academic, or medical purposes.
What role does the Horizontal Property Act play?
The Horizontal Property Act, together with building by-laws, owners’ association resolutions, or registered restrictions, may limit or condition tourist use.
What should owners check before operating a tourist apartment?
They should review applicable regional and municipal regulations, planning requirements, licences or declarations, and any restrictions arising from the owners’ association.
Do you need advice? Access our related area on the Single Register of Short-Term Rental Agreements (NRUA):
