By Emma Reyes · Guide To Holiday Renting
The grey market in European holiday rentals did not end gradually. It ended on 20 May 2026, when EU Regulation 2024/1028 came into force and gave national authorities the data infrastructure to see, for the first time, precisely which properties are operating as short-term rentals, how often, under what registration status, and who owns them. For owners who have been operating without a licence — or with a lapsed one — the implications are immediate and serious.
This is not a regulatory warning shot. Spain has already processed 86,275 delisting requests in the largest STR enforcement action in European history. Italy has had its national CIN code system in force since September 2024 and is now actively enforcing it. France's national register is live and feeding data upstream. Portugal is restricting new registrations in its most commercially attractive urban neighbourhoods. Greece's data flows have begun even where visible enforcement has not yet arrived. The platforms — Airbnb, Booking.com, VRBO — are now legally obligated to share listing-level data with national authorities on a monthly or quarterly basis and to remove listings that fail registration checks.
If you own a holiday home anywhere in the EU and rent it out, even occasionally, this regulation affects you directly. The question is not whether compliance matters — it is where you stand right now, and what you need to do in the next 30 to 90 days to protect the commercial viability of your property. What follows is a market-by-market guide written for owners who are seriously considering their options, not casual observers.
What the Law Actually Requires
EU Regulation 2024/1028 targets the information asymmetry that allowed the short-term rental market to expand largely beyond regulatory oversight for over a decade. Platforms could, and did, plead ignorance of local licensing requirements. Municipalities and regional authorities could see that holiday rentals were proliferating but had no systematic way to match listings to registered properties at scale. The regulation closes both gaps simultaneously, by imposing interlocking obligations on member states and on the platforms themselves.
Member states were required to have digital registration frameworks operational by 20 May 2026. Each country must maintain a national single digital entry point through which holiday rental properties can be registered and assigned a unique registration number. That number must appear on every platform listing for the property. Without it — or with an invalid number — the listing is non-compliant under EU law, regardless of any local tolerance that may previously have existed.
EU Regulation 2024/1028, in force 20 May 2026, requires Airbnb, Booking.com, and all rental platforms to transmit listing-level data — addresses, URLs, nights rented, host identity, registration number — to national authorities monthly or quarterly. Unlicensed listings face mandatory removal, not warnings.
Platform obligations are the mechanism that gives the law its teeth. Airbnb, Booking.com, VRBO, and all other platforms operating within the EU must now share listing-level activity data with national authorities on a regular cycle. The data transmitted is specific: the property address, the listing URL, the number of nights rented in the reporting period, the host's identity, and the registration number (or its absence). This is not aggregate or anonymised market data. It is property-by-property disclosure that allows a municipal housing officer to cross-reference a specific address against a national licensing database in real time.
The consequence for non-compliant listings is mandatory removal from platforms — not suspension, not a warning, removal. Platforms that fail to delist non-compliant properties face enforcement action from their own national regulators. Airbnb's €64 million fine in Spain in March 2026, imposed for 65,122 non-compliant listings, was the first significant demonstration of what that platform-level enforcement looks like. It establishes a cost calculus that platforms cannot ignore: the fine per non-compliant listing (approximately €980 per property) far exceeds any commercial benefit from retaining those listings. The platforms are now structurally incentivised to enforce compliance before regulators ask them to.
What the regulation deliberately does not do is harmonise the substantive rules about who can obtain a licence and on what terms. That remains entirely a matter for each member state and, in federal or quasi-federal systems, for regional or municipal authorities. The result is a patchwork of national regimes, each with its own rules, restrictions, inspection requirements, and enforcement intensity — but all now feeding into the same shared data infrastructure. Understanding your specific market is therefore not optional.
Country by Country: Where the Lines Are Drawn
The regulation may be EU-wide, but the practical impact on your property depends heavily on which country — and in many cases which region or municipality — it is located in. Here is the current status across the five major European holiday home markets.
Spain is the market where enforcement has moved furthest and fastest. Spain's national STR registration system, built around the HUT (Habitual Tourist Use) licence framework administered at the regional level, is fully operational. The Spanish enforcement action — the removal of 86,275 listings from Airbnb and Booking.com — was not a gradual process. It followed a court ruling in March 2026 that imposed a €64 million fine on Airbnb for hosting 65,122 non-compliant listings, and it created a 12.4% year-on-year reduction in holiday rental supply on the major platforms overnight. The Spanish government has simultaneously proposed a 21% VAT surcharge on all short-term tourist rentals as part of a July 2026 legislative package targeting fraudulent tenancy agreements and the tax treatment of tourist-use properties.
Barcelona deserves separate treatment because its policy trajectory goes further than any other city in the EU. The city has confirmed it will not renew any of its 10,101 existing HUT licences when they expire in November 2028. This is not a cap on new licences or a freeze on the market — it is a hard phase-out citing the displacement of long-term residents. Owners currently holding valid Barcelona HUT licences should treat November 2028 as a definitive legal end date for short-term rental operations within the city limits, and plan their exit strategy accordingly.
Portugal's position is more nuanced, and materially different depending on which part of the country you are buying in. The Lisbon municipality, under Decree-Law No. 76/2024, has closed its historic centre to new Alojamento Local registrations. Existing licences remain valid in most cases, but they cannot be transferred on property sale — a fact that has already affected resale values for historic-centre apartments marketed as income-generating holiday lets. Outside Lisbon, the picture is broadly positive: the Algarve, the Silver Coast, Madeira, and the Azores continue to accept new AL registrations, and enforcement intensity is considerably lower than in Spain or Italy.
Italy's national CIN (Codice Identificativo Nazionale) system came into force in September 2024, giving it a significant head start on the rest of the EU. As of May 2026, enforcement is active. The STR tax rate on second and subsequent properties has been raised to 26% — a meaningful uplift. The threshold for commercial reclassification, which changes your tax and regulatory treatment substantially, is being moved from four properties to two. Any owner with more than one Italian holiday rental must immediately assess whether their portfolio now crosses the commercial threshold, because the obligations at that classification level are categorically different from those applying to a private individual with a single let property.
France's national STR register is operational and has been integrated into the EU data-sharing framework. French municipalities have long had the power to restrict STR activity — Paris, Lyon, and Bordeaux have had registration and quota systems in place for years. The national register now creates a systematic enforcement layer across all communes, including smaller tourist markets that previously lacked the data infrastructure to police their own markets effectively. Rural and coastal communes that have never actively enforced STR rules should not be assumed to be safe havens; the data now flows regardless of local enforcement capacity.
Greece's digital entry point is operational and platform data is flowing. Visible on-the-ground enforcement has not yet reached the intensity seen in Spain or Italy, but owners in Greece who are operating without registration should treat the current period as a window in which to regularise their position — not as continued tolerance. The data exists; it is a matter of when authorities act on it, not whether.
The Spain Enforcement Shock: What It Tells Every European Owner
The scale and speed of the Spanish enforcement action is worth dwelling on, because it establishes the operational template that other member states are likely to follow. The removal of 86,275 listings did not happen through a slow-building administrative process. It was triggered by a court ruling, executed through platform compliance, and completed within weeks. The entire sequence — ruling, fine, bulk delistings — compressed into a matter of months what would previously have taken years of individual enforcement actions.
Spain's enforcement wave — 86,275 listings removed, holiday rental supply down 12.4% year-on-year — was preceded by a €64 million court fine against Airbnb in March 2026 for 65,122 non-compliant listings. The implied fine (~€980 per listing) has reset platform incentives: it is now cheaper for platforms to delist than to host non-compliant properties.
What triggers a delisting rather than a warning notice? In the Spanish framework, the decisive variable is whether a licence number is on file with the platform at all. An owner with a valid HUT licence — even one that is under review or facing a local challenge — is not at immediate risk of removal. An owner with no licence number on their listing, or whose listed number does not appear in the relevant regional database, is now fully visible to national authorities via the monthly data feeds and should expect either a removal notice from the platform or direct correspondence from their regional tourism authority.
The proposed 21% VAT surcharge adds a financial dimension to the compliance calculation that owners must factor into their return projections. For a property generating €30,000 per year in short-term rental income, the surcharge would represent an additional tax liability of approximately €6,300 annually. Combined with Spain's existing treatment of rental income under personal income tax — a flat 19% rate for EU non-residents on the lower bands, rising steeply for higher earners, and 24% flat for non-EU non-residents — the economics of unlicensed or poorly structured Spanish holiday rental portfolios are deteriorating materially and quickly.
The Barcelona phase-out is a harder signal still. When a major European city commits in writing to cancelling every single one of its 10,101 tourist licences on a fixed date, it is not posturing. It is a policy statement about the direction of travel — one that investors buying in other densely touristed European cities should weight carefully when assessing medium-term rental income assumptions.
What You Need to Do Right Now
There is a correct sequence of actions for owners who are uncertain about their compliance status. The starting point is not legal advice — it is a direct audit of your current platform listings.
Log in to every platform on which your property is listed and navigate to the host dashboard or listing detail view. In every country with an operational registration system, platforms are now required to surface whether a valid registration number is on file for the property, and in several markets, whether that number has been verified against the national register. If your listing shows no registration number, or if the platform is displaying a compliance status flag or warning, you are at immediate risk of removal. Do not assume that a listing that has been running without a number for months is safe — the data flows are new, and enforcement actions can be triggered against previously grandfathered listings.
Registration is regional, not national, in Spain and Italy. A Malaga property registers with the Junta de Andalucía; a Valencian Coast property registers with the Generalitat Valenciana; a Tuscany property registers with the Regione Toscana before obtaining its national CIN code from the Ministero del Turismo. The EU national digital entry points route you to the correct authority — but application forms, required documents, and inspection standards differ by region.
The second step is identifying precisely which registration system applies to your property. In Spain, registration is administered at the regional level: Andalusia, Catalonia, Valencia, the Balearic Islands, and the Canary Islands each operate their own tourism registration system. The EU's national single digital entry point routes you to the correct authority, but the application process, document requirements, inspection obligations, and timelines all vary. A Malaga beach apartment and a Barcelona flat face different regulatory processes even though both are in Spain.
The third step is ensuring your valid registration number appears on every active listing, on every platform. This sounds obvious, but it is a step many owners — particularly those using multiple distribution channels — get wrong. A registration number correctly entered on your Airbnb account but missing from your Booking.com listing means you are non-compliant on the latter platform regardless of your legal standing under national law. Platform-by-platform verification is not optional; it is the basic maintenance task that prevents a compliant property from being swept up in a bulk enforcement action.
Owners who are not yet registered and want to continue renting should treat the application process as genuinely urgent. Processing times in high-demand markets have extended significantly as authorities work through application backlogs prompted by the regulation's implementation. In parts of the Algarve and the Amalfi Coast, applicants are reporting waits of three to five months for inspections to be scheduled. That is three to five months of potential delisting exposure during which your listing may be flagged as unregistered in the platform data.
Getting Licensed and Staying Licensed
Obtaining a short-term rental licence in the EU is now, in most markets, a formal administrative process requiring a specific set of documents. The exact requirements vary by jurisdiction, but the following are almost universally required: proof of property ownership (certified title deeds), a certificate of habitability or occupancy confirming the property meets residential use standards, proof of compliance with local tourism safety regulations (which typically requires a formal inspection by a licenced technical officer), and in some jurisdictions, evidence that planning permission for tourist use has been granted or is not required under local zoning rules.
In Spain, the HUT registration process requires submission to the relevant regional authority, a pre-registration inspection in most regions, and ongoing compliance with safety and habitability standards that differ by region. Catalonia's process is more documentation-intensive than Andalusia's; the Balearic Islands impose additional requirements related to the property's zoning category and can impose moratoriums on new registrations in oversupplied tourist zones. Owners should obtain legal advice from a gestora or abogado who specialises in tourist licensing in the specific municipality where their property is located, not rely on generic national guidance.
In Italy, obtaining a compliant registration requires two separate codes: a regional CIR code (Codice Identificativo di Riferimento) issued by the relevant region, and a national CIN code issued by the Ministero del Turismo's digital portal. Both codes must appear on every platform listing. Displaying only the regional code is insufficient for EU 2024/1028 compliance. Owners who completed the regional registration step but have not yet obtained their national CIN code should prioritise this immediately.
In Italy, two codes are required: a regional CIR code and a national CIN code from the Ministero del Turismo. Both must appear on every platform listing. Displaying only the CIR is insufficient for EU 2024/1028 compliance. Owners with more than one Italian rental property must also assess whether the new two-property commercial reclassification threshold applies — the tax and compliance obligations at that level are substantially higher.
Staying licensed is an active process, not a one-time achievement. Registration numbers can lapse when annual renewal fees are not paid on time, when property details change without notification to the authority, or when local rules change and your property no longer meets updated standards. Build renewal reminders into your property management calendar for each jurisdiction's renewal cycle. If you are working with a property management company, obtain written confirmation that monitoring licence validity is part of their contracted obligations — and verify that confirmation against the actual renewal documentation each year. The compliance responsibility ultimately rests with the property owner, not the manager.
What Holiday Rental Managers Must Now Do
If you engage a holiday rental management company or a professional co-hosting service, the compliance burden does not transfer entirely to them — but their obligations under EU 2024/1028 are real and material, and you should understand them clearly before signing any management agreement.
Management companies that list properties on platforms on behalf of owners are treated as "hosts" for the purposes of the platform data-sharing obligations. This means that the data transmitted to national authorities will name the management company as the responsible party in many reported cases. This does not insulate the property owner from liability under national licensing law. If your property is not licensed, the fact that data is reported under a management company's account changes nothing about the underlying offence. The licence must exist; the management company can administer it but cannot create it by proxy.
When reviewing or renewing management agreements, owners should seek three explicit representations from their manager: first, that the property's registration number is valid and current as of the date of agreement; second, that the manager will notify the owner within 48 hours of receiving any compliance warning or delisting notice from any platform; and third, that any new platform listings created for the property will include the correct registration number before going live. These are reasonable, standard protections that any reputable management company should accept without negotiation. If a prospective manager resists any of these clauses, that is significant information about how they manage compliance risk across their wider portfolio.
Our View
The transition to a regulated, licensed short-term rental market across the EU was never a question of whether — it was a question of when and how fast. EU Regulation 2024/1028 has answered that question as clearly as any regulation can. The data infrastructure is operational. The platform obligations are live. Enforcement in the most active markets has already demonstrated that delistings happen at scale, at speed, and with limited warning. The timeline from non-compliant listing to removed listing is now measured in weeks, not the years it once took through individual enforcement actions.
The owners who will navigate this environment well are those who treat compliance as a standing operational requirement — like insurance, like maintenance — rather than a one-time administrative hurdle. A valid licence is not a permanent permission; it is a renewable credential that must be tracked, updated, and verified across every distribution channel where the property appears. A registration number on your listing is not an optional field or a best-practice recommendation; it is the single data point that determines whether your property continues to earn or disappears from the platforms that drive the majority of direct holiday rental bookings.
For investors evaluating new acquisitions in Europe with holiday rental income as part of the return thesis, the compliance picture has changed the fundamental risk assessment. Markets with clear, stable, achievable licensing frameworks — coastal Portugal outside Lisbon, most of southern France, much of rural Italy — still offer viable paths. Markets where the licensing framework is tightening materially — central Barcelona, historic-centre Lisbon, many Spanish coastal municipalities approaching saturation — require a much more honest appraisal of medium-term income sustainability. The cost of getting this wrong is no longer a fine or a warning. It is the loss of the listing entirely.
The grey market in European holiday rentals is over. The only meaningful question now is whether you act on that fact before the platform data does.