FAQ — written for non-resident owners

Frequently asked questions about Spain's guest registry

The questions below come up repeatedly from owners based in the United Kingdom, Ireland, the United States, Germany, France and elsewhere who own one or more rental properties in Spain. The answers reference Royal Decree 933/2021 and the surrounding administrative framework. None of this is legal advice; where your circumstances are unusual, consult a Spanish lawyer or a specialist gestoría.

1. I own a flat in Málaga and another in Barcelona. Do I file the same way for both?

No. The Málaga property is in Andalusia, which is covered by SES.Hospedajes at the Ministerio del Interior. The Barcelona property is in Catalonia, which is exempt from SES and uses the Mossos d'Esquadra portal instead. You must register each property separately in its respective platform, hold credentials accepted by each, and submit each stay through the correct channel. The data set is materially the same and the 24-hour deadline is the same, but the technical paths are different and they do not talk to each other.

2. I am a British owner with no Spanish NIE. How can I comply?

Without a NIE you cannot obtain an FNMT Digital Certificate or activate Cl@ve, and without one of those you cannot operate SES.Hospedajes directly. The legal route is to appoint an authorised representative (an apoderado): a Spanish gestoría, a property manager, a lawyer or a specialist compliance service that already has electronic credentials. The representation is registered in the Spanish electronic register of representations (REA) and limited to the guest-registry procedure. The representative submits on your behalf using their own credential. If you later obtain a NIE, you can apply for Cl@ve or an FNMT certificate and take over the direct submissions yourself.

3. Does Airbnb (or Booking) report my guests for me?

No. Intermediation platforms have their own duty to report each booking and each cancellation to SES within 24 hours of those events. That duty runs in parallel to yours; it does not replace it. The host's duty is to report the actual arrival of the guest at the property, which is a different event from the booking. The platform reports the contract; the host reports the check-in. Owners who assume the platform is doing everything generally discover this only when a cross-check shows bookings on Airbnb with no corresponding partes in SES.

4. Do I need to register my one-week-a-year rental?

Yes. The obligation is per stay, not annual. Even a single overnight stay in a calendar year creates the duty to communicate the data. What changes with volume is your status as professional or non-professional host, which determines whether you must keep the three-year documentary archive. A non-professional owner letting their flat two weekends a year still reports every guest; they are not, however, obliged to maintain the archive.

5. Are paper forms still accepted?

Not for submission to the authority. Since 2 December 2024 the data must be transmitted electronically. A handwritten paper parte can still serve as part of your local archive (it carries the guest signature, which can be useful as evidence in a dispute) but it is not what you submit. The platform expects either a manual web entry, an XML upload or an API call.

6. What is the “document support number” the system keeps asking about?

The número de soporte is a separate identifier printed on Spanish national ID cards (DNI) and on foreigner identity cards (TIE), beside the main document number. It exists to bind the data to that specific physical card issue, so a stolen or expired card can be distinguished from the active one. For passports it does not apply. If your guest has a Spanish DNI or a TIE, your pre-check-in form must capture the support number explicitly; submissions without it are rejected for Spanish documents.

7. Do I have to register children?

Yes, all of them, regardless of age, including infants. You record name, date of birth, sex and nationality for each minor. Children under 14 do not need to present an identity document and do not sign the parte; the accompanying adult signs on their behalf. When minors are present in a booking, an additional field — the relationship between the minor and the accompanying adult — becomes mandatory.

8. Can I take a photocopy of my guest's passport?

You should not. The Spanish data-protection authority (AEPD) treats blanket storage of identity documents as a breach of the GDPR's data-minimisation principle. The law requires you to capture the 17 fields, not the image of the document itself. Visual inspection at check-in is fine; storage of the photocopy is not. This applies equally to passports, DNIs, NIEs and TIEs. Hosts have been separately sanctioned by AEPD for this practice.

9. What if I submit late by a few hours?

It is a minor infraction. The fine band is €100 to €600, and isolated first-time incidents tend to be resolved at the bottom of the band with a regularisation order rather than a maximum fine. The exposure rises with repetition. If you have an isolated late submission, send the data as soon as you can — the late filing is much better than no filing — and tighten the operational process so it does not recur. Persistent lateness escalates to the serious tier.

10. How long do I have to keep the records?

Three years from the end of each stay, if you operate as a professional host. The archive must contain the data submitted, the signed parte and the receipt returned by the platform. Non-professional hosts are not obliged to keep the archive but should retain it voluntarily — it is the only practical defence if a question is raised later about a stay where the platform's own record is hard to retrieve. Either way, the archive should be structured per stay and searchable, not a flat pile of PDFs.

11. Where does the guest sign, and what happens to the signature?

Guests aged 14 or over sign. The signature can be electronic (captured on a tablet on arrival, or remotely through a pre-check-in flow with OTP confirmation) or handwritten on paper. The signature is not uploaded to SES. What goes to the platform is the data set; the signature stays in your local archive as proof that the guest was identified at the time. In an inspection, the signed record is the document you produce.

12. My property is in Catalonia. Do these rules still apply?

Yes, but through a different channel. The substantive duty is the same — 17 fields per traveller, 24-hour deadline, three-year retention — but the platform is the Mossos d'Esquadra's registreviatgers.mossos.gencat.cat, not SES. The credential infrastructure is the Generalitat's (idCAT, FNMT and others accepted by it), and at the time of writing the standard submission mode is file upload rather than a public API. You register the property with the Catalan portal and submit to it.

13. And if my property is in the Basque Country?

The same logic. The Ertzaintza runs the Basque equivalent of SES; the substantive rules track the national framework but the channel and the credential acceptance are Basque-specific. Owners in Álava, Bizkaia or Gipuzkoa register with the Ertzaintza's platform and submit there.

14. What payment information do I have to report?

Only the type: cash, card, bank transfer, platform, or other. No card numbers, no IBANs. The earliest drafts of RD 933/2021 included the full bank details, but that was removed before the regulation was approved in 2021. Hosts who include card numbers or bank account numbers are over-reporting and creating GDPR exposure for no benefit. A lot of misinformation circulated about this in 2022 and 2023, so the question still comes up routinely.

15. Can I refuse a guest who refuses to give their data?

Yes. The obligation is on you, the host. You cannot comply if the guest will not cooperate, and the law allows you to deny accommodation in that case. Practically, tell guests at booking — in the listing, the rental terms and the welcome email — that identification will be required. Surprises at the door create the worst possible outcome: a conflict on arrival and either a non-compliant submission or no submission at all.

16. Does the rule apply to long-term lets?

The decree applies to hospedaje — lodging — not to long-term residential rentals governed by Spain's Urban Lease Act. A flat let on a one-year residential contract to a tenant who lives there is not lodging and is outside RD 933/2021. The frontier between short-term hospedaje and a residential rental depends on regional rules and on how the activity is actually carried on; stays of more than two months without hospitality services typically fall outside, but the question can be grey and worth checking with a Spanish lawyer if the property switches between models.

17. I never registered the property and I have been renting for two years. What do I do?

Voluntary regularisation. Register the property as a provider in the relevant platform now; reconstruct the recent archive from your booking records and whatever guest data you still have; and put in place an operational process going forward. Regularisation does not erase past breaches — they remain technically committed — but the Spanish administration treats proactive regularisation as an attenuating factor and frequently closes files without sanctioning, particularly where the host shows a credible system for future compliance. Doing nothing and hoping is consistently the worst strategy.

18. How will the administration notify me if I live abroad?

Notifications are sent to the address on file with the administration. If you have appointed a representative, they go to the representative's electronic address (which is the standard, since most representatives operate through the Dirección Electrónica Habilitada system). If you have not, they go to the property's address — and they are valid even if there is no one there to read them. This is a real problem for non-resident owners and is one of the main practical reasons to appoint a representative even if you technically have a credential of your own: you want a Spanish electronic address that is actively monitored so the procedural clock does not run against you in your absence.

19. Do I have to file my tourist tax through SES too?

No. The tourist tax is a separate, regional obligation in the communities that levy it (Catalonia, the Balearic Islands and parts of the Valencian Community in 2024 onwards). It is filed with the regional tax agency, not with the police authority, and on a different schedule (monthly or quarterly rather than per stay). The guest registry and the tourist tax are independent regimes; complying with one does not satisfy the other. They are however linked indirectly: the regional tax agency may share data with the security authority for cross-check purposes.

20. Are property managers liable, or am I?

The legal addressee of the obligation is the host — the operator of the lodging activity, which is normally the property owner. A property manager who handles operations on your behalf does not become the obligated party simply by managing the property, but they can become your authorised representative by formal appointment, in which case they are responsible for the technical submission and for their share of any sanction arising from their failure to act. The substantive responsibility — being the obligated party — remains with you. Contractually you can allocate the risk through the management agreement, but vis-à-vis the Spanish administration the obligation tracks the activity, not the manager.

If your question is not here

These 20 questions are the ones that come up most often, but practice generates corner cases the FAQ format cannot anticipate: self-check-in with no host present at arrival, large family groups under a single booking holder, properties in villages with patchy connectivity, an owner with five properties spread across three autonomous communities, a manager looking after a portfolio of third-party properties, a guest who turns up with a national identity document not on the platform's list. Royal Decree 933/2021 leaves room for operational variation in each of those scenarios; the constants are the 24-hour deadline and the integrity of the 17 fields per traveller. Any working solution has to deliver both.

If your situation is one of these and you cannot find the right pattern, start with the How it works page to locate your operational case, then the Penalties page to size your exposure. If the question is still open, the safest course is to consult a Spanish lawyer or, if the choice is operational rather than legal, a specialist service that will take responsibility for the workflow.