How to claim damages for the annulled NRA
On 21 May 2026, the Spanish Supreme Court annulled the Single Rental Registry (NRA) by judgment STS 620/2026. Thousands of owners who suffered blocks, denials, suspensions, expenses or economic losses from the application of Royal Decree 1312/2024 now ask the same question: can I recover what I lost?
The short answer: it depends — heavily — on your case. The long answer is this guide.
1. Legal framework
The action allowing recovery of harm derived from an annulled rule is called State liability for application of a subsequently annulled rule, regulated in:
- Article 32.4 of Law 40/2015 on Legal Regime of the Public Sector.
- Articles 67 et seq. of Law 39/2015 on Common Administrative Procedure.
- Article 9.3 of the Spanish Constitution (principle of public-sector liability).
Three classic requirements must concur: effective, quantifiable and individualised harm; causal relationship between harm and application of the annulled rule; and unlawfulness (the injured party had no legal obligation to bear the harm).
2. Two claim tracks: individual and group collective
We have designed two parallel channels so that no one is left out, whatever the size of their harm:
Track A — Individual claim (from approx. €1,000)
For cases with quantifiable economic harm: prolonged blocks, lost sale, notary/lawyer expenses, loss of Superhost, property portfolio. Here the amount comfortably justifies the professional effort. The €32.73 NRA / NRUA fee and the lease deposit fee are included as accessory items within the larger package.
Track B — Group collective claim (fees only)
For those who only want to recover administrative fees (Single Rental Registry / Digital One-Stop-Shop and/or lease deposit form), we group several cases into a single coordinated action. This shares the professional cost and makes viable what individually would not be. Registration is free; when we gather enough interested parties, we will communicate to registered persons the actual viability and timeline.
3. When IS it worth claiming: six typical scenarios
3.1. Months-long block of Airbnb / Booking listing
The most frequent case. Platforms blocked listings for missing NRA, missing electronic community certificate, or incomplete verification of RD 1312/2024 documents. Every day without activity is demonstrable loss of profit, quantified with previous-year historicals and comparable market rates.
3.2. Lost sale or arras
Buyer backed out because of NRA uncertainty, or you had to reduce the sale price. Key documentation: arras contract, buyer communications, final reduced deed, market price comparison.
3.3. Lost Superhost / Top Host / Guest Favorite tags
Removing and reactivating a listing usually resets the rating history and premium tags. For a listing that earned significantly more thanks to Superhost, this loss has quantifiable mid-term economic impact.
3.4. Block due to lack of bare owner authorisation
If the NRA system blocked you for months waiting for consents (bare owner, vruchtgebruiker, co-heirs) that the procedure no longer requires after the judgment, that paralysis time is loss of profit attributable to the annulled rule.
3.5. Documented extraordinary expenses
The NRA generated a real "industry" of accessory costs: notarised powers, lawyer fees, sworn translations, community certificates with notarised signatures, judicial processes against denials, extraordinary tax advice. All this is consequential loss directly imputable to applying the NRA.
3.6. Portfolio of multiple properties
For a single owner with one dwelling, figures are modest. For companies with 10, 20, 50 holiday-let dwellings, multiplication changes the calculation: €32.73 × 20 = €654 just in NRA fees, plus €32 × 20 annual fees each February, plus blocks multiplied across units. In portfolio, the economic case is clear.
4. What can be claimed: five concepts
5. Evidence: the backbone of the claim
No evidence, no claim. Required documents typically include:
- Registry resolution (negative qualification or NRA suspension note).
- Fee payment receipt.
- Platform notifications (Airbnb, Booking, Vrbo) blocking or suspending.
- Screenshots of the blocked listing.
- Previous income histories (platform statements, IRPF Form 100, accounting).
- Invoices of extraordinary expenses (notary, lawyers, gestoría, translations).
- Documents of frustrated sale (arras contract, reduced deed).
- Market comparisons of similar properties in the same area during the block.
6. Procedure: administrative and judicial
6.1. Administrative claim
The claim is addressed to the competent Ministry (Justice / Housing). It includes: identification, chronology of facts, legal basis (arts. 32 et seq. Law 40/2015, citing STS 620/2026), quantification with documentary exhibits, and specific petitum with interest calculation. The Administration has 6 months to resolve; silence = denial.
6.2. Judicial review
Against denial (express or by silence), recourse before the Audiencia Nacional (Administrative Chamber). Time limit: 2 months (express denial) or 6 months (silence). Full process: 18-36 months.
7. Deadline: one year from the finality of the judgment
One year from the finality of STS 620/2026, under Article 67.1 Law 39/2015 + Article 32.4 Law 40/2015. It is a caducity deadline, not prescription: no interruption, no suspension.
8. Exception: when the denial also touched regional or community plane
There is one scenario where STS 620/2026 does not help as much: when the denial grounds also affected your regional registration (VFT/VUT, HUT) or your community of owners (Article 7.3 LPH authorisation after Organic Law 1/2025 reform). In those cases the problem persists even after the NRA falls. The proper action is not State liability for the annulled rule, but appeal against the regional denial, challenge of the community resolution, or actions against the community of owners.
9. Fees: how we work
Initial pre-evaluation is free via our interactive form. If we proceed, we work with success-based fees on most cases. Complex or portfolio cases may have mixed schemes (reduced retainer + success percentage). Everything documented in writing before engagement.
Does your case fit? Assess it now free
Our interactive 4-step form evaluates the viability of your claim in under 3 minutes. We reply within 48 hours.
Related reading
- Technical analysis of judgment STS 620/2026
- Practical implications of the NRA annulment
- Council of State opinion that anticipated the annulment
FAQ
Is it worth claiming only the €32.73 NRA or deposit fee?
We have a specific track for that: the group collective claim. We add several small cases into a single coordinated action and share the professional cost, making recovery viable. Registration is free and without commitment. When we gather enough interested parties, we will communicate the actual viability and you will decide whether to join. Salama Legal SLP cannot guarantee in advance that the collective action will be executed (depends on the number of adhesions), but registering your case has no cost.
When IS the damage claim viable?
Months-long block of Airbnb/Booking with lost bookings, lost sale or arras, forced price reduction, lost Superhost, documented extraordinary expenses, or portfolio of multiple properties.
What is the deadline?
One year from the finality of STS 620/2026 (caducity deadline; no interruption).
What evidence do I need?
Platform emails, blocked-listing screenshots, prior income histories, invoices of extraordinary expenses, frustrated-sale documents, Registry resolution, fee payment receipts.
Administrative or judicial?
Start administrative (Ministry, 6 months). If denied, judicial review before the Audiencia Nacional. Full process: 18-36 months.
What if my denial also stemmed from community or regional issues?
STS 620/2026 only helps when the denial was exclusively NRA-based. Otherwise, the problem persists and the proper action focuses on the regional or community plane, not State liability.