Selling a holiday apartment: the registration number is part of the deal

The seller walks into the office with a folder full of guest reviews. His two-bedroom flat is in central Athens, in the first municipal district. For the past few years it has been booked almost continuously on Airbnb, and that is exactly how he wants to sell it. The agent flicks through the folder, then asks the question that changes the conversation: what happens to the AMA number when the flat changes hands? He doesn't know. The answer is not one he will like.

Agents are now having conversations like this well beyond Greece. Since 20 May 2026, Regulation (EU) 2024/1028 has applied to short-term rentals offered through online platforms. In Germany, according to the Federal Network Agency (Bundesnetzagentur), Frechen, Munich, Nuremberg, Regensburg and Tübingen launched a registration procedure as of 1 October 2026. Whether an agency is marketing apartments in Sunny Beach or an investment flat in Regensburg, registration is now part of taking on a listing.

What Brussels has regulated, and what it hasn't

The regulation does not introduce a Europe-wide rental licence, nor does it ban short-term rentals. Law firm Wolf Theiss describes it as a common framework. Where a country or municipality requires registration, the number must appear in the listing, and the authorities receive data.

The platforms are hit hardest. They must verify and display registration numbers, carry out spot checks and remove or deactivate listings without a valid number. Large providers report standardised data monthly, smaller ones quarterly, to national single digital entry points, including the address, registration number, listing URL, number of nights and number of guests. Where registration is mandatory, a property without a valid number will therefore disappear from booking platforms sooner or later.

For property sales portals, the situation is less clear-cut. According to a guide from mein-Monteurzimmer, the obligation under the regulation applies only to platforms with a direct booking function, not to pure listing portals. Local rules may still apply. And for prospective buyers, the number is one of the most important details in any case.

When the sale costs the right to rent

A buyer who purchases an apartment on the Costa Blanca as an investment is counting on guests. If the regional licence is missing, or it is unclear whether it will survive the change of ownership, the buyer's numbers rest on shaky ground. If something goes wrong later, they will remember the brochure that said "ideal for letting". And the agent who wrote it.

The risk is most apparent in Greece. There, every short-term rental requires an AMA number from the AADE tax authority, which must be displayed in every listing. In Athens municipal districts 1 to 3, new registrations are suspended until 31 December 2026, and in the 1st Municipal Community of Thessaloniki since 1 July 2026. According to service provider MyStaySite, a property in these zones is deleted from the register when it is transferred and cannot be re-registered while the suspension remains in force. So the Athens flat from the opening loses precisely what the buyer wants to pay for the moment it is sold.

With holiday properties, the agent is not just selling square metres but a status. And sometimes that status is tied to the owner, not the property.

Whether the suspensions will be extended beyond the stated date must be checked afresh before every sale in these districts. For renting without an AMA number or without a visible number, MyStaySite cites penalties of 50 per cent of the previous year's gross income, with a minimum of 5,000 euros.

Country comparison

Germany has implemented the regulation through the Short-Term Rental Data Exchange Act (Kurzzeitvermietung-Datenaustausch-Gesetz, KVDG), passed by the Bundestag on 23 April 2026. The Federal Network Agency acts as the central single digital entry point. However, a number only becomes mandatory once the relevant municipality introduces a procedure. Whether every municipality is allowed to do so is decided by the federal states. In Bavaria, according to the Saxony Tourism Network, only municipalities with a bylaw prohibiting the misuse of residential housing may do so. Before taking on any listing, it is worth checking the Federal Network Agency's current overview, as the list keeps growing.

According to the Ministry of Economic Affairs, Austria is implementing the regulation on an opt-in basis, i.e. not as a mandatory requirement. The municipality will know what applies to a specific property.

Bulgaria already had its own system. The Tourism Act requires guest rooms and guest apartments to be registered, and the number must appear in online listings. For an apartment in a holiday complex on the Black Sea coast, information from the building management is therefore not enough.

In Cyprus, registration with the Deputy Ministry of Tourism is mandatory, and the number must appear in every advertisement. According to a report by the DOM portal, the Deputy Minister of Tourism has made clear that renting without registration is a criminal offence, punishable by a fine of up to 5,000 euros, up to one year in prison, or both.

In Spain, ruling STS 620/2026 of 21 May 2026 annulled the national NRUA registration. The regional tourism code is once again what counts, for example HUT in Catalonia and VT in Valencia. Property brochures that only state an NRUA number need to be revised.

Questions for the first meeting

With a holiday property, a few points need to be added to the usual documents, and it's best to clarify them at the very first appointment:

• Ask for the registration or licence number
• Request written confirmation from the competent authority
• Check with the owner and the authority whether the status remains in place after a change of ownership
• Review the house rules, the declaration of division or owners' association rules, and municipal regulations
• For Greek properties, check whether the property is in a restricted zone

The most common mistake in practice is the convenient one. The seller says "The flat is registered", the building manager nods, and the sentence ends up in the brochure. A year later it turns out the number belonged to the previous owner or expired long ago. Note who gave you which information, and keep the supporting documents in the property file.

Property brochure and listing

Only include information in the brochure that you can back up. A phrase such as "Registered as a guest apartment, registration number available, documentation on request" tells prospective buyers exactly where they stand. For a Spanish property, state the regional code; for a Cypriot one, the registration with the Deputy Ministry of Tourism.

Avoid anything that sounds like a promise. Yield figures, "guaranteed rental income" or "ideal for Airbnb" without any supporting evidence raise expectations that are out of your hands. Even the seller's past occupancy figures mean little if it is unclear whether the new owner will be allowed to rent at all.

If a property is located in a Greek restricted zone or transferability is uncertain, this should be stated factually in the brochure. For example: "Under current regulations, short-term rental is unlikely to be possible following the change of ownership." That will cost you some prospective buyers. But it will spare you disputes.

A reason to pick up the phone

Owners of holiday apartments you sold in the past are often unaware of the changes. That's a good reason to get in touch without immediately trying to sell something. A short message to a client in Munich might read: "Since 1 October, the City of Munich has been issuing registration numbers for holiday apartments. If you're still letting your flat through platforms, it's worth looking into the procedure. If you have any questions about a valuation or a future sale, I'm happy to help." For an owner in Sunny Beach, the same idea works with a reference to registration under the Bulgarian Tourism Act.

What you can do this week

Go through your current portfolio of holiday and investment properties and flag every property whose registration status is not documented in writing. For these properties, request the supporting documents before the next brochure goes out. Whether a licence is transferable, what obligations the buyer will have, or how rental income should be treated for tax purposes are matters for a lawyer, a tax adviser or the competent municipality. These questions don't belong in your answer; they fall within their remit. If you work with ImotDesk, you can track registration status as a dedicated field in your property management, so you have it to hand for every enquiry.