Guideline

Patrimonial liability claim for the NRA — deadline 8 June 2027

VUT owners and managers who incurred costs related to the NRA (registration fee of €32.73 per property, management expenses, blocked listings, lost bookings) may claim damages from the State through a patrimonial liability claim. The deadline to submit the claim is one year from the publication of STS 620/2026 in the BOE: until 8 June 2027. The claim is submitted to the Ministry of Finance.

State patrimonial liability claim procedure for damages arising from the NRA/NRUA declared null by STS 620/2026 — STS 620/2026, of 19 May (BOE 8 June 2026) Act 39/2015, of 1 October, on Common Administrative Procedure (art. 65-67 — patrimonial liability) Act 40/2015, of 1 October, on the Legal Regime of the Public Sector (art. 32-35) Deadline: 1 year from BOE publica
In force from 2026-06-08 to 2027-06-08
Official source →

The annulment of the NRA by STS 620/2026, published in the BOE on 8 June 2026, opens the avenue of State patrimonial liability for those who suffered economic damages arising from the application of Royal Decree 1312/2024.

Who may claim

Any VUT owner or manager who suffered any of the following damages as a direct consequence of the NRA may submit a claim:

Payment of the registration fee of €32.73 per property to obtain the NRA.
Management, advisory or translation costs incurred during the NRA application process.
Listings blocked or removed from platforms due to lack of NRA.
Lost bookings during the period the listing was blocked.
Any other economic damage directly attributable to the NRA requirement.

Deadline to claim

The deadline is one year from the publication of the judgment in the BOE. Since STS 620/2026 was published on 8 June 2026, the deadline is 8 June 2027. After that date, the claim is time-barred.

How to submit the claim

Gather documentation of the damages: invoices for fees paid, management firm invoices, screenshots of blocked listings, calculation of lost bookings with supporting evidence (platform calendars, cancellation emails, etc.).
Draft the claim: claimant identification, description of facts, causal link between the NRA and the damages suffered, economic quantification of the damages, request for compensation.
Submit to the Ministry of Finance (Ministerio de Hacienda): the patrimonial liability claim is addressed to the competent body of the Ministry of Finance, submitted through the Spanish Government electronic office or by in-person registration.
Await resolution: the Administration has 6 months to resolve the claim. If there is no express resolution, it is deemed rejected (deemed refusal), which opens the way for an administrative appeal before the courts.

Sector perspective

Several short-term rental industry associations have announced collective claims. From July 2025 to the date of the judgment, more than 400,000 NRA applications were submitted, of which approximately 80,000 were rejected (20% rejection rate). Each application cost €32.73. Industry estimates put the potential claim value at over €13 million in fees alone.

Recommendation

Given the complexity of the administrative procedure and the need to demonstrate a causal link between the NRA and the specific damages suffered, it is advisable to consult a lawyer specialising in administrative law before submitting the claim.

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