Registration gap exposure, 2026 rules

EUR 31,344 is what three unregistered Italian holiday lets are worth in fines and lost nights right now - EUR 24,000 at the top of the CIN band plus EUR 7,344 of delisted bookings at EUR 120 a night and 68% occupancy. That is one host, one country, one month of a listing sitting removed.

Since 20 May 2026 Regulation (EU) 2024/1028 has required the platforms to carry your registration number and to act on the listings that do not have one. One rule, twenty-seven sets of numbers: each member state kept its own register and its own penalty, and they are not the same size.

Ask a chatbot and you get one country's figure, usually from a page written before the 2025 and 2026 changes, as if it were the EU rule. It also skips the part that decides the amount: the bands are per structure, so the total depends on how many units you let, what you charge and how long the listing stays down.

Here is the same tool, three portfolios, three genuinely different answers.

Italy, three units, no CIN yet, EUR 120 a night, 68% occupancy, 30 days delisted. DL 145/2023 art. 13-ter sets EUR 800 to EUR 8,000 per structure for operating without a CIN, and EUR 500 to EUR 5,000 for having one but not showing it in the advert. Floor EUR 2,400, ceiling EUR 24,000, delisting loss EUR 7,344, worst case EUR 31,344, which is EUR 10,448 per unit.

Greece, two units, EUR 180 a night, 70% occupancy, 45 days delisted. Most summaries quote the EUR 5,000 figure and stop. The Greek penalty for staying out of the short-term residence property registry is 50% of the gross receipts of the year, with EUR 5,000 only as a floor. At EUR 180 and 70% that is EUR 45,990 a year per unit, so the ceiling is EUR 45,990, the delisting loss EUR 11,340 and the worst case EUR 57,330 - nearly double the Italian portfolio from fewer units.

Spain, five units, EUR 95 a night, 60% occupancy, 60 days, number missing from the advert. Real Decreto 1312/2024 built a single registry and told the platforms not to display a listing without a number. No national fine is attached; regional tourism law is where fines live. So the band is EUR 0 and the whole exposure, EUR 17,100, sits in nights you cannot sell.

France sits between them: the loi Le Meur (n. 2024-1039 of 19 November 2024) allows a civil fine up to EUR 10,000 for failing to register and up to EUR 20,000 for a false or misused number. Portugal's DL 128/2014 art. 30 puts an individual operator at EUR 2,500 to EUR 4,000.

The extension is that arithmetic with the per-country band written in. You pick country, units, registration status, nightly rate, occupancy, days removed and your next re-declaration date. It returns the fine floor and ceiling, the delisting loss, the portfolio total, the per-unit figure, the days to renewal and the rule the band came from, so you can check it against the register yourself.

All of that is free: all 5 countries, 7 outputs, no key, no limit, no watermark, no locked answer. Nothing you type leaves the browser; the only outbound call is the licence check when you buy.

The paid layer sits on a different axis - keeping the run and repeating it. For $60 once, the priced result writes out as a .csv row you file with the property, and the extension sets 30/14/1-day reminders before the re-declaration date. One licence key per person or team seat. A hospitality compliance lawyer in the EU bills EUR 150-300 an hour for the same audit.

Bands change. Check the figure against the national register before you file - the tool tells you which rule it used precisely so you can.