— Essay Nº4, on certain common questions

On certain common questions

Ten enquiries that recur, in correspondence and in conversation, among the non–resident owners and small operators to whom these essays are principally addressed.

What follows is a sequence of ten questions and their answers, written in the conversational mode but maintaining the citational discipline appropriate to a regulatory subject. The order is approximately that of frequency.

— Does the obligation apply if I let my property only a few weekends each year?

It does. The regulation draws no de minimis exception for occasional letting: a single paid stay engages the duty to communicate the traveller’s data within twenty–four hours of arrival.¹ What changes with frequency is the qualification of the host as professional or non–professional — the former adding the three–year retention duty — but not the communication obligation itself.

— I am a British owner with a flat in Malaga; do I need a Spanish digital certificate?

In practical terms, yes — or, alternatively, you must designate an authorised representative who holds one. The Sede Electrónica del Ministerio del Interior, through which SES.Hospedajes is accessed, admits only two forms of identification: the digital certificate of the Fábrica Nacional de Moneda y Timbre, and activated Cl@ve credentials. Both presuppose an active NIE and the personal presentation that an active NIE in turn requires.² The standard practical remedy is the appointment of a property manager or specialised service.

— Is the signature on the parte truly required for every guest?

For every traveller of fourteen years or older, yes. The form of the signature is flexible — wet signature on paper, recognised digital signature, or OTP–confirmed pre–arrival check–in flow — but the signed parte itself must exist and must be retained by the professional host for the three–year period.³ Children under fourteen do not sign, though their data are still recorded.

— What happens if I am late in transmitting a booking?

Lateness, partial communication, or errors in the transmitted data are characterised as infracciones leves under articles 36 to 38 of the Ley Orgánica 4/2015, attracting fines of one hundred to six hundred euros. Repeated lateness, or the absence of any communication, escalates the qualification to grave, with fines from six hundred and one to thirty thousand euros. The matter is taken up at greater length in the fifth essay.

— My property is in Barcelona. Do I use SES.Hospedajes?

No. Hosts in Catalonia submit to the Registre de viatgers of the Mossos d’Esquadra, the autonomous police force of the Generalitat. The procedural texture is somewhat different from the central system: the Catalan portal requires manual file upload rather than the API integration available on SES.Hospedajes. Hosts in the Basque Country, analogously, submit to the procedure of the Ertzaintza.⁴

— Does the platform — Airbnb, Booking, Vrbo — not handle this on my behalf?

It does not, in the relevant sense. The intermediary platform bears its own obligation to communicate confirmations and cancellations at the moment they occur, but the host’s duty to communicate the actual arrival of the traveller is independent and additive. A booking communicated by the platform is not a check–in communicated by the host. The two events are recorded separately on the central system, and an inspecting authority will identify a missing check–in communication notwithstanding a properly communicated booking.

— How long must I keep the records?

For three years from the close of each stay, if you qualify as a professional host. The conservation obligation extends to the signed parte and to the transmission acknowledgement; the format may be paper or electronic, provided the documents are legible, complete, and retrievable upon inspection. The non–professional host is bound to communicate and to obtain the signature but is not subject to the three–year retention.

— What is the número de soporte, and why does it matter?

The número de soporte is a six–character identifier printed on the Spanish national identity document (DNI), distinct from the document number itself and present on the rear of the card. The regulation requires its capture for Spanish travellers, and the platform validates it. It is the most frequent point of error among hosts new to the procedure, who tend to capture the número de DNI in its place; the resulting communication is rejected by the platform.⁵

— Is the obligation independent of my tax duties?

Yes. The duty of registration before SES.Hospedajes or its regional equivalents is wholly distinct from your tax duties under personal–income tax (IRPF or, for non–residents, IRNR), value–added tax (IVA, or IGIC in the Canary Islands), and the tourist–tax regimes of those autonomous communities that levy them. Compliance under one regime does not imply compliance under another; the authorities, the deadlines, and the penalties are separate in each case.

— If I close the property, do I still need to do anything?

If the establishment ceases to be operated as lodging, the baja — deregistration as prestador — should be communicated through the same platform. The three–year retention obligation, however, persists for the records of stays that occurred during the period of activity, and the inspecting authority may, within the limitation period applicable, examine those records.

1. Real Decreto 933/2021, de 26 de octubre. Boletín Oficial del Estado, núm. 258, 28 October 2021. The communication obligation attaches to each stay irrespective of the frequency with which the property is let. ↩
2. Sede Electrónica del Ministerio del Interior, conditions of use. The admitted credentials for access to SES.Hospedajes are the digital certificate of the FNMT and activated Cl@ve credentials; non–resident owners without an active NIE must accordingly delegate. ↩
3. The signature requirement for travellers of fourteen years or older, and its admitted forms (wet, digital, or OTP–confirmed), are set out in the regulation and in the operational guidance of the Ministerio del Interior. ↩
4. The Catalan Registre de viatgers of the Mossos d’Esquadra and the Basque procedure of the Ertzaintza are the operative channels in their respective autonomous communities, in substitution of (not in addition to) the central SES.Hospedajes system. ↩
5. On the número de soporte as a datum distinct from the número de DNI, see the operational guidance of the Ministerio del Interior accompanying the publication of SES.Hospedajes. ↩