The Federation of Associations of Owners of Vacation and Temporary Rentals (FAVAPAT) has requested an "emergency meeting" with the Ministry of Housing and the General Director of Legal Security and Public Faith of the Association of Registrars of Spain.
FAVAPAT wants to address with them "the unprecedented legal uncertainty generated by Royal Decree 1312/2024. The rule, which is applicable from this Tuesday, July 1, 2025, has unleashed a scenario of arbitrariness that seriously harms small owners and violates fundamental legal principles."
"The Government has created a legal monster that expels 90% of small landlords from the market while benefiting investment funds. We will not allow improvisation to drown thousands of families," they summarize in the Federation.
"Disparate criteria from registrars"
The Federation denounces that the property registrars "are applying divergent interpretations of the Royal Decree, exceeding their functions by analyzing urban and tourist aspects that are exclusively the responsibility of municipalities and autonomous communities."
They explain that "this practice expressly contradicts the technical report issued by the Association of Registrars itself, which limits its work to verifying circumstances that emanate from the Property Registry itself."
Therefore, they lament that "unjustified rejections of registrations based on subjective criteria are being generated, ignoring judicial rulings and current regional regulations."
In addition, they continue, "there are thousands of cases throughout Spain in which the exercise of the activity is being prevented when the property is not registered in the Property Registry
-unless you go through the checkout and pay between 3,000 and 6,000 euros that the registration costs, forgetting that in Spain registration in the Property Registry is not mandatory but voluntary."
Likewise, "a territorial chaos is being created, where owners from different regions of our country face contradictory requirements for the same procedure.
"Serious legal violations"
The Federation also denounces that "the obligation to request a registration number in the Property Registry (when they are already registered in the competent regional tourism registry) usurps the exclusive powers of the autonomous communities and has been denounced with judicial appeals by Andalusia, the Valencian Community, the Canary Islands and ASCAV.
FAVAPAT recalls that European Regulation 2024/1028 expressly prohibits subjecting a home to multiple registrations.
FAVAPAT demands the immediate suspension of the Royal Decree until the judicial appeals currently being processed before the Supreme Court are resolved and recalls that according to European Regulation 2024/1028 "the requirement of the Single Window does not enter into force until May 2026."
"Subsidiarily to the above, a binding protocol for registrars, aligned with their powers and that the verification is limited to what emanates from the Property Registry itself," they add.
They also request an urgent dialogue "with the autonomous communities to avoid the destruction of the family tourism fabric."
