Short-term accommodation leases through digital platforms: regarding the Single Lease Registration procedure and its annulment by the Supreme Court

Abstract

On 23 December 2024, Royal Decree 1312/2024 was approved in Spain, implementing Regulation (EU) 2024/1028 and consequently establishing the Single Register of Short-Term accommodation leases and the Single Digital Entry Point for these tenancies for the purposes of data collection and exchange. The regulation of the single registration procedure has raised various issues and, in particular, led to the lodging of five administrative appeals with the Supreme Court seeking the annulment of the aforementioned Royal Decree, on the grounds that the State lacked the competence to enact this legislation, that it encroached upon the powers of the autonomous communities, and that it overlapped with regional tourist registers, thereby breaching the prohibition on duplicate registration laid down in the EU Regulation. The Supreme Court finally, in judgements handed down in May and June 2026, partially annulled Royal Decree 1312/2024, solely in respect of the single registration procedure for tenancies.

The analysis of this situation concerning the single tenancy register, its regulation and the Supreme Court’s arguments leading to its annulment will form the main focus of this paper, as will the most significant effects and consequences of that annulment, bearing in mind at all times the binding and directly applicable nature of Regulation (EU) 2024/1028 since 20 May 2026.