Property Registry and Tourist Rental: Cannot Reject Information Model Due to Guest Discrepancy

Key data

If you own a tourist accommodation and the Property Registry has rejected the filing of the information model for short-term rental because the number of guests does not match the one registered in the NRUA (Unique Rental Registration Number), this resolution directly affects you and supports your position.

The General Directorate of Legal Security and Public Faith (DGSJFP) has upheld the appeal against the negative rating issued by the property registrar of Seville No. 17, establishing a binding criterion: the discrepancy in the maximum number of guests is not a valid reason to reject the filing of the information model. The resolution was issued on April 30, 2026 and published in the BOE on August 8, 2026 (reference BOE-A-2026-17341).

What does this resolution establish?

The resolution addresses a specific conflict: a property owner attempted to file the information model for short-term rentals at the Property Registry of Seville No. 17, but the registrar denied it because the maximum number of guests listed in the model did not match the one registered in the NRUA (Unique Rental Registration Number).

The DGSJFP upholds the appeal and establishes the following criteria:

• Nature of the filing: The information model for short-term rentals has a merely informative and statistical character. It does not create or modify registered real rights.
• Limits of the rating function: The registrar can only rate aspects with actual legal significance. They cannot introduce requirements not provided for in RD 1312/2024 or Order VAU/1560/2025.
• The discrepancy in guests is not a valid cause for denial: A difference in the maximum number of guests does not alter the identification of the property, its ownership, or the registered real rights. Therefore, it cannot be grounds for a negative rating.
• Annual filing obligation: The resolution reminds that owners of tourist accommodations have the obligation to file the information model annually with the Property Registry.

Economic and operational impact

For owners of tourist accommodations, the impact of this resolution is primarily operational and legal certainty. No direct economic sanctions are established in the resolution, but failure to comply with the annual obligation to file the information model may result in administrative consequences according to applicable sectoral regulations.

What is relevant from a practical standpoint is that this resolution eliminates an unjustified bureaucratic barrier: if the Registry was rejecting your filing due to a difference in the number of guests, you now have legal support to appeal and obtain the correct filing.

For property registrars, the resolution represents an express limitation of their rating function in this area: they cannot go beyond what is established in RD 1312/2024 and Order VAU/1560/2025.

Who does it affect?

• Owners of tourist accommodations who must comply with the annual obligation to file the information model with the Property Registry.
• Owners who have received a negative rating due to discrepancy in the number of guests between the information model and the NRUA.
• Managers and administrators of tourist real estate assets who manage multiple properties and make periodic filings.
• Property registrars, who are bound by the established criterion: they cannot deny the filing for this reason.
• Legal and real estate advisors who advise owners of tourist accommodations on compliance with their registry obligations.

Practical example

An owner of a tourist apartment in Seville has their property registered in the NRUA with capacity for 4 guests. When filing the annual information model for short-term rental with the Property Registry of Seville No. 17, the model reflects a capacity of 6 guests (for example, after a renovation that increased the property's capacity).

The registrar issues a negative rating and denies the filing citing the discrepancy between both data.

Thanks to this DGSJFP resolution, the property owner can file an appeal and obtain acceptance of the filing, since:

• The discrepancy in the number of guests does not alter the identification of the property or its ownership.
• The information model has no constitutive effects on real rights.
• The registrar cannot introduce requirements not provided for in RD 1312/2024 or Order VAU/1560/2025.

What should property owners do now?

1. Verify if you have pending the annual filing of the information model for short-term rental with the Property Registry. It is an annual obligation established in RD 1312/2024 and Order VAU/1560/2025.
2. If you have received a negative rating due to discrepancy in the number of guests between your information model and the NRUA, file an appeal with the DGSJFP. This resolution supports your position.
3. Prepare the correct documentation: ensure that the information model correctly identifies the property (cadastral reference, address, ownership). The discrepancy in guests is not an obstacle, but other identification data must be correct.
4. Consult with your legal or real estate advisor if you manage several tourist accommodations, to ensure that the annual filing process is carried out correctly for all properties.
5. Update your internal procedures: if you are a manager of tourist assets, incorporate this resolution as a reference for future registry rejections for similar reasons.

Official source

Consult complete regulation in official source

Notice: This article is merely informative in nature and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-17341