Energy performance certificates for hotels and holiday rentals: do you need one and must it be in your listings? (2026)

Updated: 10 November 2026

The A-to-G label shows up more and more on booking sites. Is it mandatory for your hotel or holiday rental? We read Spain's Royal Decree 390/2021 and the Ministry's (MITECO) official page, official documents on Portugal's SCE scheme, Italy's Legislative Decree 192/2005, Greece's Law 4122/2013 and Directive (EU) 2024/1275 (links at the end). Where we could not confirm something, we say so. This is not legal advice: check with your adviser or a certified energy assessor.

Short answer

Spain: a holiday rental (vivienda de uso turístico) that is let out must have a certificate, and every sale or rental listing must include the energy rating.
Spain: hotels, hostels and tourist apartments over 500 m² of usable floor area must have a certificate and display the label where the public can see it.
Italy and Greece: the law requires a certificate when letting and the energy class in listings; we have not confirmed how this applies to short tourist stays.
Portugal: a certificate is required to sell or let; we have not confirmed what the law says about listings or Alojamento Local.

Spain: who needs a certificate

Royal Decree 390/2021, art. 3 (consolidated text, last updated 23-7-2025):

Buildings or parts of buildings that are sold or «let to a new tenant».
Buildings over 500 m² of usable area in «public residential» use: «hotels, hostels, residences, guesthouses, tourist apartments and similar».
There is no exemption for homes used less than four months a year: the Ministry explains that this exclusion was removed and that holiday rentals that are let out must be certified since 3 June 2021.
Exemptions that do exist: protected buildings (in some cases), temporary buildings of up to two years, stand-alone buildings under 50 m² and some industrial or farm buildings.
The certificate is valid for up to ten years; five if the rating is G (art. 13).

Spain: listings and visible label

Art. 17.3: anyone who publishes, or allows the publication of, information on the sale or rental of a building or part of it, in any medium, must include the energy rating.
According to the Ministry, on websites and brochures the label can be resized if format and proportions are kept and it stays legible; in the press the consumption and emissions letters are enough.
Art. 16: buildings over 500 m² in the uses above (hotels, tourist apartments…) must display the label «in a prominent place, clearly visible to the public».
The rule does not name Booking, Airbnb or your own website. We found no official clarification for each holiday-stay listing; the safe course is to show the rating everywhere.
For a hotel of 500 m² or less that is not sold or let as a building, we have not confirmed any duty to have a certificate.

Spain: penalties and 2025-2026 changes

Art. 21 refers to the penalty rules of the Land Act and the General Consumer Protection Act. We have not read the amounts, so we give no figures.
Royal Decree 659/2025 changes who may sign certificates and creates registers; it enters into force twelve months after its publication in the BOE (23-7-2025). It does not change the listing or display duties.
Certificates are registered by each region: check your region's register.

Portugal: SCE

Decree-Law 101-D/2020 (we could not open the official consolidated text) and official ADENE and DGEG documents:

A certificate is required on sale, lease, dação em cumprimento and trespasse, and for large commerce and services buildings in operation (ADENE, 2025).
The SCE Manual (Despacho 6476-H/2021) lists «alojamentos locais» and «hostels» among commerce and services building types.
The law has an article 22 on display and advertising and fines in articles 35 to 38. We have not read their text or the amounts.
We have not confirmed whether an Alojamento Local or a hotel needs a certificate just to operate, or what its listings must show.

Italy: APE

Legislative Decree 192/2005 (coordinated text published by the Region of Tuscany, in force as of 5-8-2019):

Art. 6: the APE (attestato di prestazione energetica) is mandatory on sale or a new lease, and the contract must include a clause on it.
Art. 6.8: sale and rental listings must state the energy performance index and class; leases of residential buildings «used less than four months a year» are excluded.
Art. 6.7: buildings open to the public over 500 m² must display the APE at the entrance or in a visible place.
Art. 15: a listing without energy data, €500 to €3,000; a new lease without an APE, €300 to €1,800.
We have not confirmed whether short tourist lets (affitti brevi) or hotels fall under these rules, or any changes after 2019.

Greece: PEA

Law 4122/2013 (codified text up to 20-10-2021, Ministry of Environment and Energy):

Art. 12: the certificate (ΠΕΑ) is required on sale and when letting to a new tenant, including «βραχυχρόνια» (short-term) leases.
Art. 12.4: since 1 January 2021 the energy class must appear in all commercial advertisements and listings for sale or rent.
Art. 13.6: buildings over 500 m² frequently visited by the public must display the certificate in a visible place.
Art. 20: fines of €200 to €10,000 for breaching these duties. The certificate is valid for up to ten years.
The law does not define «short-term» or refer to the holiday-rental regime. We have not confirmed how it applies to such rentals or to hotels.

Europe: what is coming

Directive (EU) 2024/1275 on the energy performance of buildings:

A scale using only letters A to G (art. 19) and a maximum validity of ten years.
A certificate on sale, on letting to a new tenant or on renewing the lease (art. 20.1).
Energy performance indicator and class in advertisements, online or offline (art. 20.4).
Each country must transpose it into national law. We have not confirmed the status in Spain, Portugal, Italy or Greece.

What to do

Check that you have a registered, valid certificate.
If you run a holiday rental in Spain, get the certificate and show the rating in your listings.
If your hotel or tourist apartment exceeds 500 m² of usable area, display the label in a visible place.
Show the same letter on every channel: website, booking sites and AI assistants.
In Portugal, Italy and Greece, check with a local assessor how the rules apply to your type of property.

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Frequently asked questions

Does my holiday rental need an energy certificate?

In Spain, yes: the Ministry explains that holiday rentals that are let out must be certified since 3 June 2021, and the old exemption for use under four months a year no longer exists (RD 390/2021).

Do I have to show the energy letter on Booking or Airbnb?

Art. 17.3 of RD 390/2021 requires the rating in any sale or rental publication, in any medium. It does not name specific platforms and we found no official clarification; the safe course is to include it.

Must my hotel display the label?

In Spain, if it exceeds 500 m² of usable area, yes: it must have a certificate and display the label in a clearly visible place (arts. 3 and 16 of RD 390/2021).

Sources

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