Guides

Does my rental advert need an energy rating?

Who is liable — the owner or the agency?

The agency, as well as the owner. RD 390/2021 art. 17.3 binds "toda persona física o jurídica que publique o permita la publicación" and names agencias inmobiliarias and portales inmobiliarios explicitly. RDLeg 7/2015 DA 12ª.6 then makes them liable "aún a título de simple inobservancia" — simple failure to observe, with no need to show intent.

That is the practical reason this matters to an agency rather than to a landlord: you publish the advert, so the missing rating is on your file, not theirs.

Is the holiday-let exemption still available?

No. It existed — RD 235/2013 art. 2.2 exempted dwellings "cuyo uso sea inferior a cuatro meses al año", on a responsible declaration by the owner. RD 390/2021 repealed RD 235/2013 outright and did not carry the exemption forward: the list in art. 3.2 does not contain it. So a flat let for eight weeks a summer needs a certificate exactly as a twelve-month let does.

Worth being precise about, because the exemption is still widely quoted: it was killed by the 2021 decree, not by the 2013 one that contained it.

Ten years, or five?

Ten years is the general maximum, but a certificate rated G runs for five (RD 390/2021, art. 13.1). The five-year clock applies to a G in either indicator — consumption or emissions — and only to certificates registered from 3 June 2021; anything registered before that keeps its ten years whatever the letter. The first five-year cohort began expiring in June 2026.

There are two ratings, not one: primary non-renewable energy consumption in kWh/m² year, and CO₂e emissions in kgCO₂e/m² year, each with its own A–G letter. A record carrying a single letter is incomplete, and an expiry date cannot be worked out at all without a registration date.

What happens if the advert shows the wrong rating?

Advertising a rating that no registered, in-force certificate backs is a very serious infringement under RDLeg 7/2015 DA 12ª.3.d — a worse position than showing no rating at all. Showing the label without its required minimum format and content is a minor infringement under 5.f.

This is why we fill a rating column only where a certificate is registered against that exact dwelling and is still in force. A certificate covering the whole building, an expired one, or two records that disagree are written into a note for a person to read — never offered as the flat's rating.

How do I do a whole portfolio in one pass?

Paste your list — your own property reference beside each cadastral reference — and we look every one of them up against the regional registers we mirror. You get one dated file by email, with a column per fact so it maps straight into a CRM or a portal feed.

No account and no subscription. One payment covers a few hundred references; past that allowance each further property is billed as its own line on the invoice, so the bill says which part is the report and which part is the size of the portfolio. Past a second, larger limit we decline the one-off and point you at the subscription instead, because at that size a dated snapshot is the wrong product. The report page carries the current price and both limits.

• Your reference and the cadastral reference, as you sent them
• Match level and status, so you can see what was actually found
• Both letters and both values — consumption and emissions
• Certificate reference, expiry date, and the basis that expiry rests on
• Region, municipality, register snapshot date and the date we checked
• A note, wherever the answer needed a person rather than a column

What happens to my list afterwards?

It is personal data belonging to someone with no account, so it is kept only as long as delivering it needs: erased the moment the report is sent, after a week for a checkout that was never paid, and after a month for a delivery that failed — long enough to resend it by hand.

Is a snapshot enough?

It depends what you need. A snapshot fixes a portfolio that has never carried energy data at all, which is the common case, and one pass over the whole list is what fixes it. It does not keep the answer true afterwards: certificates expire, properties come and go, and the register changes under you. Keeping it true is the energy plan's job — the report sends nothing after the file.

What we do not decide

We record and date; we never certify. Nothing here decides that a property may be let, only what the paperwork says and when it runs out. Where the register publishes no expiry date we work one out from the certificate date and the rating, say so, and tell you to confirm it against the certificate itself. A figure the register published that we judge implausible is withheld rather than passed on — the letter still goes in the file, the number does not.

Sources

• Real Decreto 390/2021, energy performance certification of buildings
• Real Decreto Legislativo 7/2015, Ley de Suelo y Rehabilitación Urbana (DA 12ª)
• Real Decreto 235/2013 (repealed), the four-month exemption it removed

Verified against the sources above on 2026-09-20. LicenceDesk is operational guidance, not legal advice.

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