NRUA and tourist licence after Law 1/2025: the DGSJyFP requires community agreement
The Resolution of the Directorate-General for Legal Security and Public Faith (DGSJyFP) of 25 September 2025, published as BOE-A-2026-298, consolidates the doctrine on the Single Rental Registration Number (NRUA) when the tourist licence was obtained after the entry into force of Law 1/2025 (3 April 2025). The Resolution is categorical: without express agreement of the homeowners' community under Article 17.12 of the Horizontal Property Act (LPH), the NRUA is not assigned.
The factual situation
An owner of a dwelling in horizontal property filed an application for NRUA following entry into force of Law 1/2025. The tourist licence had been obtained after 3 April 2025. The owner did not provide a community agreement under the new Article 17.12 LPH, on the basis that no statutory prohibition existed in the deeds. The Registrar suspended assignment of the NRUA and the DGSJyFP confirmed the suspension.
The new filter introduced by Law 1/2025
Law 1/2025 introduced Article 17.12 into the LPH, requiring express authorisation of the homeowners' community by a 3/5 quorum (of owners and quotas) for the tourist use of dwellings in horizontal property. Two new ideas:
- Temporal scope: applies to tourist licences obtained after 3 April 2025. Pre-existing licences are not subject to this filter, although the statutory-prohibition rule continues to apply.
- Express agreement: tacit consent is not enough. A community meeting record with the favourable agreement and the qualified quorum is required.
What the Resolution adds
The Resolution clarifies three pivotal points:
- It is not enough for the deeds to be silent: silence requires the affirmative agreement, not just the absence of prohibition.
- The Registrar must verify the licence date and, if it is after 3 April 2025, demand the agreement.
- The agreement is a requirement for assignment of the NRUA, not a mere accessory.
If you have obtained a tourist licence after 3 April 2025, anticipate: convene the meeting, obtain the agreement and file it with the NRUA application. Otherwise, expect suspension.
Strategy for affected owners
- Verify the licence date: before or after 3 April 2025.
- Review the deeds: presence or absence of a statutory prohibition.
- Convene the community if the licence is post-Law: agenda, 3/5 quorum.
- Document the agreement with the meeting record and notify objectors.
- Refile the NRUA application attaching the agreement.
Official sources
- 📜 Resolution DGSJyFP of 25 September 2025 – BOE-A-2026-298.
- 📜 Law 1/2025 of 3 April amending the Horizontal Property Act, Article 17.12.
- 📜 Law 49/1960 (consolidated).
Post-Law 1/2025 licence and registration suspended?
SALAMA LEGAL SLP convenes the meeting, drafts the agreement and resubmits the NRUA application.
Frequently asked questions
Does the rule apply to licences obtained before 3 April 2025?
No. Article 17.12 LPH applies only to licences obtained after entry into force of Law 1/2025. Pre-existing licences are not subject to this filter.
What quorum is required?
3/5 of owners and 3/5 of quotas (the qualified quorum of Article 17.12 LPH).
Does silence mean assent?
No. The Resolution makes it clear that, post-Law 1/2025, an express agreement is needed; the mere absence of prohibition is not enough.