Licence, NRUA and Guest Report in Spain: Which Is Which

The trouble starts with the word. In Spain your autonomous community, the Housing Ministry and the Interior Ministry all say “registration” for three things that have nothing to do with each other. And each one comes through a different door: a regional tourist office, the Property Registry, and an Interior Ministry platform.

Which is why a single headline about the NRUA reads like a general amnesty. Owners who take it that way stop filing their parte de viajeros, keep listing without a valid regional number, or start a procedure that no longer exists. The first two are sanctionable; the third leads nowhere, because the procedure has been annulled.

The short answer is that two of the three bind you today. The licence, meaning registration in your autonomous community’s tourist registry, without which you can neither list nor operate. And the guest report, filed with every guest. The NRUA is annulled and there is nothing to apply for. If what you want is the whole path, from municipal planning to your first guest report, do I need a licence for my tourist flat in Spain? walks it.

Licence, NRUA and guest report: who requires each one

The tourist registry is regulated by each autonomous community; the NRUA was created by Royal Decree 1312/2024¹ and the guest report by Royal Decree 933/2021. The amounts in the table are not in that decree: they come from Article 39.1 of Organic Law 4/2015, which sets minor infringements at €100 to €600 and serious ones at €601 to €30,000².

None of them replaces another, and none of them enrols you in the others. The licence does not open a SES.HOSPEDAJES account, and filing guest reports does not authorise your property for tourist letting.

Does a headline mean the NRUA, the licence or the guest report?

Three clues are almost always enough, and they sit in the first paragraph of any news story:

1. The ministry named. Housing means the NRUA. Interior means the guest report. If no ministry appears and an autonomous community does, it is the licence.
2. Where the filing happens. Property Registry, NRUA. SES.HOSPEDAJES, guest report. Regional electronic office, licence.
3. How often it comes back. Once per property, licence or NRUA. With every guest, the guest report.

The NRUA case proves the point. One of the three registries fell, the Housing Ministry’s, and neither the regional licence nor the guest report moved an inch.

What ruling 620/2026 annulled and what it left standing

The single rental registration number was created by Royal Decree 1312/2024 and processed through the Property Registry. Supreme Court ruling 620/2026 of 19 May 2026 annulled it because the State had encroached on regional powers. The operative part, published in the BOE on 8 June, draws the line in one sentence:

“To annul the provisions of the challenged Royal Decree relating to the single rental registration procedure and to the obligation to register with the Property Registry or the Movable Property Registry in order to obtain a registration number allowing short-term accommodation rental services to be offered through online platforms.”

The judgment then lists the provisions, and the list matters because not all of them fall whole:

• Annulled in full: Articles 5 (the landlord’s obligations), 8 (the single registry), 9 (the inscription procedure) and 10 (verification of the number), letters f) and i) of Article 2, letters b) and c) of Article 12, and the second additional provision.
• Annulled only in part: Article 1, in so far as it develops the single registration procedure; Article 2 j), as regards registration procedures; Article 6, as regards the single registration procedure; and the first final provision, in the competence titles that supported that procedure.
• And any other mention of the registry: the ruling also reaches “any other provisions or references to the single registry contained in other paragraphs of this royal decree”.

The appeal was dismissed in all other respects, so rather more stands than the headline suggested:

• The digital single window for rentals, created by Article 7, which the ruling does not mention.
• Official statistics under Article 11, and the Housing Ministry as the competent authority for the single window, Article 12.a).
• The regional tourist registries and their numbers, which is what Airbnb and Booking verify on the listing. It goes up exactly as your community issued it; which number belongs in which field, and in what format, is set out in which registration number goes on Airbnb and Booking.
• The guest report, which belongs to a different ministry and was never part of the case.

The single window causes the most confusion, because it was born in the same decree as the annulled registry:

“In order to comply with the obligations laid down in Regulation (EU) 2024/1028 […] the Digital Single Window for Rentals of Spain is created, as the single national digital gateway for the electronic transmission of data between short-term rental online platforms and for the other functions established by the rules.”

Nothing changes for you: it is a channel between the platforms and the authorities, not a window where you file anything.

If the Property Registry granted you the state number before the annulment, it no longer authorises you or obliges you to anything. Keep the file and the fee receipts.

Guest registration is untouched by ruling 620/2026

Royal Decree 933/2021 requires you to collect every guest’s data and report it to the Interior Ministry through SES.HOSPEDAJES, or to the Mossos d’Esquadra and Ertzaintza in Catalonia and the Basque Country. The deadline is set by Article 6.3, and there are two of them, not one:

“This communication shall be made immediately, and in any event within no more than 24 hours, respectively, from the following moments: a) On making the reservation or formalising the contract or, where applicable, its cancellation. b) At the start of the contracted services.”

The two moments open two 24-hour clocks, and they trigger two different communications worth keeping apart. The booking, or its cancellation, triggers the reserva de hospedaje, which carries the contract and the payment. The start of the stay triggers the parte de viajeros, which carries each guest’s identity. On a direct sale both are yours; when the booking comes through Booking or Airbnb, the first falls to the platform, which article 2.1.d) counts among the obliged subjects for intermediating in lodging activity in Spain⁶, and the report stays yours. The difference between the two, with their data and their deadlines, is in reserva de hospedaje or parte de viajeros.

So unlike the licence, this is not one-time paperwork. It is daily operations. Every check-in generates a report, every report has a deadline, and every omission is sanctionable.

Article 8 of the decree contains not a single amount. What it does is decide which conduct is serious and which is minor, and refer the figure to Chapter V of Organic Law 4/2015: omitting a mandatory communication is serious, and filing it late is minor⁷. The fines that follow run from €100 to €600 for minor infringements and from €601 to €30,000 for serious ones².

And the decree does not stop at the filing. Article 5 also requires a computerised register holding that data, kept “for a period of three years counted from the end of the contracted service or provision”, so the retention clock starts when the guest leaves, not when you filed the report. Anyone running lodging activity non-professionally is exempt from that register and that retention, and remains bound only by the reporting duties of article 6⁸. The licence has no equivalent: you obtain it and keep it current, but it generates no per-guest archive.

This obligation rests on Organic Law 4/2015 and the Interior Ministry. Neither the Supreme Court ruling nor any change to the tourist registries touches it.

FAQ

Is guest registration still mandatory in Spain in 2026? Yes, guest registration is still mandatory in Spain in 2026. RD 933/2021 and SES.HOSPEDAJES remain fully in force. The Supreme Court annulled the single property registry (NRUA), a different system run by the Housing Ministry.

Do I still need an NRUA number to list my property? No, you no longer need an NRUA number to list your property: ruling 620/2026 removed that obligation by annulling the articles that created the registry and required inscription. What you do need, today as before, is the tourist registration number from your autonomous community.

Which number does Airbnb or Booking check on my listing? The number Airbnb and Booking check on your listing is your regional tourist registration number. Publish it exactly as your community issued it; platforms remove listings without a valid number.

How long must guest report data be kept in Spain? Guest report data must be kept for three years, counted from the end of the contracted service rather than from the filing date: article 5.3 of RD 933/2021 sets that period for the computerised register the same article requires. Anyone running lodging activity non-professionally is exempt from that register and that retention under article 5.4, and stays bound only by the duty to report.

Did the digital single window disappear with the NRUA? The digital single window did not disappear with the NRUA. It is created by Article 7 of RD 1312/2024, which is not among the annulled provisions, and the ruling dismissed the appeal in all other respects. It remains a channel between the platforms and the authorities, not a filing of yours.

Automating guest registration for every booking

Of the two obligations still alive, the licence is settled with one-off paperwork. The other, guest registration, returns with every booking: collect complete data, validate it, submit on time. That is the part RegistroViajero automates: digital check-in for your guests in nine languages, validation of the mandatory fields, and automatic submission to SES.HOSPEDAJES with nothing copied by hand.