REGISTRADORES - Depósito de Arrendamientos

New requirement for all those who have applied for the NRA (NRUA), obliges them to submit the annual deposit of short-term rentals and derives directly from Article 10.4 of Royal Decree 1312/2024, of December 23. This regulation establishes that, every twelve months, an informative model must be submitted containing an anonymized list of the short-term rentals established, identifying a purpose other than permanent housing. This purpose can be vacation, tourism, work, studies, medical treatment or any other that does not imply a need for stable residence.

This report details the practical and procedural aspects for complying with this obligation in its first edition, corresponding to this year.

1. Obligated Parties
   All owners or managers of a property (CRU) who have been assigned one or several Unique Rental Registration Numbers (NRUA) during the year 2025 are obliged to make this deposit. The NRUA is the mandatory identifier for marketing short-term accommodations on digital platforms.

2. Nature of the Deposit
   The deposit consists of submitting the Short-Term Rental Informative Model, an official document that must reflect, for each property (CRU), all short-term rentals initiated in the declaration period (2025) for all NRUAs associated with said property.

3. Submission Deadlines (2025 Fiscal Year)
   The Ministerial Order that develops this procedure entered into force on January 2, 2026. It establishes an annual obligation with the following calendar:
   • General period: Each month of February, with the information from the previous annual fiscal year.
   • First submission (2025 fiscal year): It can be carried out from February 1 to March 2, 2026.

4. Consequences of Non-Compliance
   Article 10.5 of RD 1312/2024 is clear in its consequences:
   • Non-submission or late submission: Entails the revocation of the NRUA assigned to the unit.
   • This revocation is communicated to the Digital Single Window for Rentals of the Ministry of Housing.
   • Practical effect: The loss of the NRUA prevents the marketing of the property on online tourist or short-term rental platforms.

5. Mandatory Data to Declare
   The list is anonymized, so no personal data of guests is included. The information required per model and NRUA is:
   • Purpose: Tourist/Vacation, Work, Studies, Medical treatment, Others.
   • Occupancy: Number of guests.
   • Rental Period: Entry date and exit date. For ongoing reservations, the exit date will be left blank.
   • Identifiers: The assigned NRUA and the CRU (14-digit Unique Registration Code of the property).
   • Declaration of Inactivity: There is a specific box to indicate if an assigned NRUA has had no rental activity during the fiscal year.

6. Completing the Model (Application N2)
   The model is generated exclusively through the N2 application, provided by the Spanish Registrars.
   • Download and Installation: Free from the Electronic Office (Sede Electrónica) of the Registrars. It does not require a subscription or a digital certificate for its download or completion.
   • Data Loading Methods:
   o Manual: Recommended for a small number of properties or contracts.
   o Bulk Load (CSV): Allows importing data from a CSV file, as long as it adheres to the required format and columns.
   • File Generation: After validating the data, the application generates a file in XBRL format (encrypted .zip) that contains the declaration.
   • Compatibility: Currently, the N2 application is not compatible with iOS operating systems. The Registrars have announced a future adaptation without a specific date.

7. Submission Methods at the Registry
   There are three modalities, ordered by preference:

   1. Telematic Submission (Preferred Method):
      o Through the Electronic Office (Sede Electrónica - Registradores) of the Registrars.
      o Directly from the N2 application.
      o Requirement for both: To be registered in the Electronic Office and have a valid digital certificate.

   2. In-Person Submission:
      o Does not require a digital certificate.
      o One must go to the Property Registry where the property is registered.
      o Procedure:
      a. Complete the model in the N2 app and save it locally (it is not printed).
      b. When saving, an identification number (CRI) is automatically generated.
      c. Generate and print the submission form that includes the CRI. This is the only physical document delivered at the Registry, allowing the registrars to retrieve the associated digital information.

8. Support, Resources
   • Help Resources: The Spanish Registrars have enabled extensive support:
   o Documentation: Informative guides, user manuals, and video tutorials available on their Electronic Office starting January 31, 2026.
   § Link: https://sede.registradores.org/sede/sede-corpme-web/informacion-y-ayuda/documentacion-descargas/deposito-arrendamientos
   o Chatbot: An automated consultation tool already operational.
   § Link: https://chatbot.regia.registradores.org/es/arrendamientos

9. Cost and Document Retention
   • Cost of the Registrars' Service: The submission of the informative model has a cost of 27 euros + VAT for each NRUA declared in the model.
   • Document Retention: The regulation establishes the obligation to retain all documentation (contracts, reservations, etc.) that proves the declared purpose of the rentals, as the Registrar may request it for verification.

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