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Articles 5 and 6 Decree 28/2016 · Decree 31/2024 · Procedure 6631

Maximum capacity and bathroom equipment in Andalusian VUT after Decree 31/2024

Decree 31/2024 has refined the capacity regime of holiday-let properties: places cap, convertible places in the living room and bathrooms required per occupancy. Applied guide based on consolidated Decree 28/2016 and the official FAQ.

Adding a sofa-bed or expanding places?

Capacity review

SALAMA LEGAL SLP calculates the admissible maximum capacity of your VUT and prepares the registration-bases modification before the Tourism Registry.

🛏️ Decree 28/2016 · Arts. 5 and 6 · Decree 31/2024 · Procedure 6631

Maximum capacity and bathroom equipment in Andalusian VUT after Decree 31/2024

⚠️ UPDATE · 21 May 2026
The Spanish Supreme Court has annulled the Single Rental Registry (NRA) for lack of State competence, by judgment STS 620/2026. The doctrine described here may have changed.
👉 Technical analysis of the judgment · Practical implications
⚖️ Claim damages and loss of profit →

Capacity and bathroom equipment are two of the parameters most monitored by the tourism inspection. Decree 31/2024 has refined the rules and the official FAQ of the Directorate-General for Tourism reminds the holder to verify them and, where appropriate, communicate the update. This article systematises the matter from three angles: the literal rule of the consolidated Decree 28/2016, its practical application (especially convertible places) and the administrative path to amend the registration.

Minimum surface

Article 6.1.b of Decree 28/2016 sets the basic rule: the dwelling must have a minimum built dimension of 14 m² per place, in line with the main-use built surface stated in the Electronic Cadastre site. In any case, the minimum main-use built surface will be 25 m² or, failing that, what urban planning determines.

ℹ️ The Cadastre is the reference
Useful or advertising surfaces are not accepted. The Cadastre's electronic site determines the computable m². Check the cadastral data before declaring capacity.

Maximum places: 15 and 6

Article 5.4 of Decree 28/2016 sets two caps by group:

GroupMaximum placesNotes
Full15Admits 2 convertible places in living room
Per-room6Resident and registered holder

These caps are strict: exceeding them does not turn the dwelling into a tourist apartment, it simply prevents VUT registration.

The two convertible living-room places (full group)

One of Decree 31/2024's novelties is the possibility of installing two convertible places in the living room of full-group dwellings. Typically sofa-beds or similar. Three important caveats:

Places per room and bed type

Although Article 5.4 focuses on overall caps, it also introduces a per-room limit: no more than 4 places per room, of which two must be beds other than bunk beds. The rule seeks to guarantee minimum comfort and differentiate VUT from other collective accommodation.

The Annex to the Decree adds the minimum bed dimensions: 80 × 190 cm single and 135 × 190 cm double. Mattresses must be at least 18 cm thick with homogeneous strength.

Mandatory bathroom equipment

Article 6.1.c sets the staged rule:

PlacesMinimum bathrooms
Up to 51
6 to 82
Over 83

Each bathroom must have, at least, toilet, basin, bath or shower, hand soap, gel, shampoo, towels, non-slip floors, washable bath mat, proper lighting, mirror, hangers, extra toilet paper, brush, plug next to the mirror, shelf, hair-dryer and hygiene bin. The toilet must be separated and enclosed, individually or with the other sanitary elements.

Communicating the modification

The official FAQ explains the path: use the responsible-declaration form of procedure 6631 of the Junta de Andalucía. Steps:

  1. Access the virtual office with digital certificate.
  2. Select modification of responsible declaration.
  3. In section 4, tick «modification of registration bases».
  4. Fill in the capacity in section 1 of the Annex of the holiday-let dwelling.
  5. Attach evidence of the surface (cadastral reference) if required.
⚠️ The responsible declaration is serious
Misrepresenting capacity or bathroom data activates Article 9.2 of Decree 28/2016: the Ministry may cancel the registration upon inaccuracy or falsehood. Before declaring 15 places, ensure compliance with the m² ratio and bathroom equipment.

Official sources

📚 Cited documentation

  • 📜 Articles 5, 6 and Annex of Decree 28/2016 (consolidated).
  • 📜 Decree 31/2024 of 29 January. BOJA No. 24.
  • 📑 Official FAQ – Directorate-General for Tourism.
  • 🔗 Procedure 6631.

Want to expand places or adjust your VUT capacity?

SALAMA LEGAL SLP checks feasibility (cadastral surface, ratio, available bathrooms) and prepares the responsible declaration so the modification is registered without observations.

Frequently asked questions

What is the minimum surface of a VUT?

25 m² of main-use built surface under Article 6.1.b (or what urban planning determines), with a ratio of 14 m² per place.

How many places can a VUT have?

15 places in the full group and 6 in the per-room group, max 4 per room of which 2 must be beds other than bunk beds.

Do convertible living-room places count toward capacity?

Yes. Article 5.4 of Decree 28/2016 expressly states it: up to two convertible places in the living room, counted toward the maximum.

How many bathrooms for 7 places?

Two complete bathrooms. Article 6.1.c requires two from more than 5 places and three from more than 8.

How do I communicate a capacity modification?

Through procedure 6631, ticking «modification of registration bases» (section 4) and filling in the new capacity in section 1 of the Annex. Electronic procedure with digital certificate.

Legal notice: this article is informative and does not constitute personalised legal advice. Application to your case depends on the cadastral surface, number and layout of rooms and existing bathrooms. Prior advice is recommended before amending declared capacity to avoid falsehood in the responsible declaration.