VAU/1560/2025: What's Left of Spain's Annual Rental Report

For anyone letting property short term in Spain, getting the Número de Registro Único de Arrendamiento (NRUA) looked like the end of the paperwork. It was not: Order VAU/1560/2025 hung an obligation on that number that came back every February, the depósito de arrendamientos de corta duración.

The report carried no fine. The consequence the royal decree provided for was withdrawal of the registration number, and without an active number the platforms could not keep the listing published¹.

That scaffolding no longer stands. The consolidated text of Royal Decree 1312/2024 marks articles 5, 8, 9 and 10 as annulled, which are the ones that created the registry, governed inscription and required the number to be verified². The number platforms verify today is your regional tourist registry number. And the fallen Article 10 is the same one that ordered the deposit, in its paragraph 4.

That leaves two questions: what a February 2026 filing is now worth, and what happens in February 2027.

What the short-term rental deposit is

It was an annual informative declaration created by Royal Decree 1312/2024 and implemented through Order VAU/1560/2025, published in the Official State Gazette on 31 December 2025 under reference BOE-A-2025-27116³. It was filed with the Property Registry or the Registry of Movable Property, through the electronic office of the Colegio de Registradores (Spain’s property registrars’ body), using the N2 application.

The whole obligation fitted into one paragraph of the royal decree:

“Every twelve months the information model for short-term rentals approved by order of the head of the Ministry of Housing and Urban Agenda for each category and type of rental must be filed, and it shall contain, at a minimum, an anonymised list of the rentals entered into, together with the identification of one of the purposes described in Article 4.2.a) that has justified the type of rental.”

It was not a tax and had nothing to do with the Spanish Tax Agency. Its purpose was registral: building a historical record of short-term rental activity linked to the property, in line with the EU transparency framework for short-term accommodation (EU Regulation 2024/1028)⁴.

Why the annulment of Article 10 hollows out Order VAU/1560/2025

The Order had no life of its own. It says where it came from, in its preamble and again in its first final provision:

“This order is issued in exercise of the enabling provision contained in Article 10.4 of Royal Decree 1312/2024, of 23 December.”

The Supreme Court annulled that article without reservation or carve-out, and with it most of the single registry:

“Specifically, the following provisions are annulled: Article 1 (insofar as it refers to the development of the single rental registration procedure) Article 2 paragraphs f), i) and j) (the latter as regards the registration procedures), Article 5, Article 6 (as regards the single registration procedure), Article 8, Article 9, Article 10, Article 12.b) and c), second additional provision, first final provision (in relation to the titles supporting the competence to regulate the single registration procedure), and any other provisions or references relating to the single registry contained in other paragraphs of this royal decree.”

The ruling dismisses the appeal “as to all else”, so what survives in the royal decree is everything that does not touch the single registry²:

• Article 7, which creates the digital single window for rentals.
• Article 11, on official statistics.
• Paragraphs a) and d) of Article 12, which split competence between the Ministry of Housing and the regions. None of the three asks anything of the landlord: the activity data reaching the single window is transmitted by the platforms, not by you.

Two facts now sit side by side in the Gazette and are best read together. Article 10.4 is marked as annulled in the consolidated text of the royal decree. Order VAU/1560/2025, by contrast, is still published with its last update dated 31 December 2025, carrying no annulment or repeal note⁶. Our reading is that a model with no enabling provision and no registration number to declare against cannot be enforced. The status of each rule is stated on its own Gazette record.

Who had to file the short-term rental deposit

Any owner or manager of a unit with an active NRUA was covered, even with no activity during the year. If the accommodation was closed, you still filed, just marking the “no activity” option.

The royal decree never spelled out a consequence for filing nothing. It ordered withdrawal of the number “for failure to comply with the requirements for access to the Registry” and, this time expressly, where the model showed the number had been used for a purpose other than the one declared¹. Our reading is that an unfiled deposit fell under the first of those.

The filing could be done by the registered property owner or by whoever could demonstrate management of the property. And one model was filed per property, not one per portfolio.

What data the annual deposit declared

The model was structured in three blocks:

• Filer identification: details of the person submitting the report.
• Property data: the property’s registry reference (CRU).
• Activity detail: one line per stay during the previous calendar year.

For each stay you had to report³:

Data was entered manually or imported via a CSV file in the exact format N2 required.

When the deposit was filed: the February window

The Order set a single window each year, and closed it with a detail that matters to anyone running several flats:

“The information model for short-term rentals shall be filed during the month of February each year, with the information on the rentals entered into in the previous year. One information model shall be filed per property, ship, vessel or floating structure.”

In 2026, the only year the deposit was ever filed, 28 February fell on a Saturday. The last day to file was therefore Monday 2 March, because a deadline ending on a non-working day rolls over to the next working day⁷.

The calendar the Order laid out was this:

Only the first row ever happened. That one was set by the Order’s single transitional provision, which reserved February 2026 for the 2025 information³. The 2027 and 2028 filing years lost the paragraph that held them up.

Filing through the Property Registry’s N2 application

The official tool was the N2 application, available as a free download from the Electronic Office of the Registradores. The procedure had four steps:

1. Download and install N2 (Windows; Mac/Linux versions released from February 2026).
2. Create the deposit record with the year, the NRUA, the filer’s details and the property’s CRU reference.
3. Load the data, stay by stay or by importing the CSV.
4. Generate the XBRL file and submit it with a digital certificate, or on paper at the Registry.

The CSV format was strict: semicolon-separated, dates in DD/MM/YYYY, fixed column order. Any deviation triggered a validation error in N2.

Amending a late filing: if the 2 March 2026 deadline already passed

If you missed the deadline, the stated consequence was losing your NRUA. Now that the articles creating that registry were annulled in June 2026², the withdrawal has lost almost all practical effect: the number platforms verify is the regional one. It is still worth leaving your file in order.

• Ask your local Property Registry whether the withdrawal of your number was ever processed.
• Check the status of your NRUA where the number actually lives, which is your Property Registry or the registrars’ electronic office. Your region’s tourist registry is a separate procedure and holds no information about the NRUA.
• Keep the decision, if one was issued: it is the basis for any future claim over the fees paid.

On those fees, it is worth being precise about what was charged and what was not. Filing the deposit carried no fee of its own, because Order VAU/1560/2025 approves the form and sets no tariff at all³. What was paid, once per unit, was the 27 euros per number requested, taxes and withholdings not included, that the Colegio de Registradores published as the price of obtaining the NRUA⁸.

Deposit, Modelo 238 and guest registration are not the same

Hosts managing tourist accommodation in Spain faced three data obligations that overlapped in the calendar and were entirely independent of one another:

Only two of the three are still alive. The third row lost its legal basis with the annulment of Article 10, and the other two stand exactly as they did before the ruling.

One clarification about the first row, because it is nearly always told by halves: the guest-report deadline does not have one starting moment, it has two, and each opens its own 24 hours.

“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.”

On a booking taken months ahead the first moment falls long before check-in, so counting only from the guest’s arrival puts the file out of time from the day the booking was made. A cancellation starts the clock too.

One clarification about that middle row, because it changed and is still reported wrongly: Modelo 179 no longer exists. The Spanish Tax Agency removed the obligation from the 2024 tax year and replaced it with Modelo 238, filed by platform operators (Airbnb, Booking) rather than by hosts. Anyone telling you to file the 179 is describing a repealed return.

The short-term rental deposit itself did not include personal guest data. It reported aggregate activity: dates, purpose, number of occupants. It never replaced the SES.HOSPEDAJES guest submissions.

Which RegistroViajero data covered the deposit

Every booking you manage through RegistroViajero already captures check-in and check-out dates and the number of guests, which are the same fields the annual deposit required. If the obligation returns in some form, the full year’s stay history would be in your account, with no reconstructing it from emails or calendar exports.

The NRUA and purpose code (1–5) were the only fields to add by hand, since they depend on the nature of each booking rather than the guest registration form. Most tourist accommodation operators declared purpose 1 (tourist/holiday) for all stays.

What to keep each year after the NRUA annulment

The deposit was designed as a recurring obligation and lasted a single February. Bringing it back takes a new rule, with its own enabling provision and its own registry behind it, and nothing of the sort is published in the Gazette as things stand.

Until then, the useful work is the same one your RD 933/2021 digital check-in already asks for: keeping a clean booking record all year, with precise check-in and check-out dates and accurate guest counts. With that covered, any future stay declaration is a matter of exporting and formatting, not of rebuilding the year by hand.