Bikes, kayaks, surfing or walking routes for your guests: when it counts as «active tourism» and what you need (Andalusia, Portugal, Italy and Greece, 2026)

Updated: 10 November 2026

On the Costa de la Luz and in the Algarve many guests ask about surfing, kitesurfing, kayaking or bike routes. If you organise them yourself, you may be providing a tourism service with its own rules. We read the Andalusian active tourism decree and its reform, the Andalusian Tourism Act, the Turismo de Portugal pages and the rules we found in Italy and Greece (links at the end). Where we could not confirm something we say so. This is not legal advice: check with the regional tourism office or your adviser.

What active tourism means in Andalusia

Decree 20/2002 on rural and active tourism, and Tourism Act 13/2011:

Sports activities that mainly use natural resources and involve some risk, physical effort or skill (art. 4 of the decree).
Organising them is a tourism service (art. 21 of the decree and art. 28.1 d of the Act).
Annex V of the decree lists them, including mountain biking, diving, canyoning, canoeing and kayaking, hiking, climbing, surfing and windsurfing.
Kitesurfing is not named in the list; we have not confirmed how the regional government classifies it.
We found no later decree replacing 20/2002; we describe the version amended by Decree 80/2010.

What you need to organise them

Art. 23 of the decree (as amended by Decree 80/2010) and arts. 38 and 39 of the Act:

Liability insurance suited to the risk, covering users and third parties. It is mandatory and must be in place before registration (art. 39 of the Act, the one cited in our insurance guide).
A responsible declaration to the Andalusian Tourism Register: once filed you can start, and registration is made ex officio (art. 38).
Qualified staff for each activity.
Any navigation or environmental permits the activity needs.
The decree no longer sets a minimum insured amount: the old EUR 600,000 minimum was repealed in 2010.

Instructors and safety

Arts. 26 and 29 of the decree (as amended by Decree 80/2010):

Show that staff have lifesaving or first-aid knowledge.
Have emergency and evacuation plans and check the equipment.
Stop anyone for whom the activity could be dangerous.
Inform, advise and accompany users.
Before starting, record in writing that the guest was told about the route, risks, equipment included and extra, maximum group size, ages and insurance cover.
Minimum safety equipment is always included in the price.
The list of instructor qualifications (Annex VI) was repealed: the rule now asks for «qualified staff», with no closed list.

Surf or kite schools

Decree 80/2010 added art. 22.3: activities whose sole purpose is teaching the listed activities are outside the decree. We have not confirmed how that exclusion applies after the 2011 Act. If the lesson includes an outing or route, ask the regional government.

What if I only lend or rent bikes or kayaks?

No rule or regional government text we read says whether lending or renting equipment to guests, without a guide or organised activity, is active tourism. We do not assume it either way. If in doubt, ask the provincial tourism office and your insurer.

The simple option: work with a registered company

If you do not want to become an active tourism company, recommend one registered in the Andalusian Tourism Register.
Ask for its registration number and policy.
Make clear to the guest who organises the activity.

If you sell it with the room

A room plus an activity sold together can be a package, with its own obligations. See our guide: iquota.io/hotel-excursion-transfer-package-travel-directive-2026.

Portugal: animação turística

According to Turismo de Portugal and gov.pt (Decree-Law 108/2009, current version republished by Decree-Law 186/2015):

Anyone running tourist entertainment (animação turística) or maritime tourism activities commercially registers in the RNAAT, the national register.
It is a simple prior notification, online in the National Tourism Register, and there is a fee.
The registration number goes on contracts, correspondence and advertising, including online.
Mandatory personal accident and liability insurance covering all registered activities (art. 27).
Only those doing exclusively urban walking routes and visits to museums, palaces and monuments are exempt from that insurance.
Boats: Decree-Law 149/2014 (RAMT). Nature tourism: Portaria 651/2009.
We have not confirmed whether a hotel or local lodging offering activities to its own guests is exempt from the RNAAT.

Italy: mountain guides

Law 6/1989 sets the principles for regions to regulate the mountain guide profession.
Two grades, aspirante guida and guida alpina-maestro di alpinismo, with courses and exams; the accompagnatore di media montagna is regulated by the regions.
Surf or kayak schools and bike rental: we found no national rule. Check with your region and municipality.

Greece

The official procedures catalogue (mitos.gov.gr) has separate procedures for renting out sea recreation craft and for recreational diving providers.
We have not read their requirements, and found no general national «active tourism» rule.

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Frequently asked questions

Is a guided kayak trip for my guests active tourism in Andalusia?

Organised canoeing and kayaking is in Annex V of Decree 20/2002: you need a declaration to the Tourism Register, liability insurance and qualified staff.

How much must the insurance cover?

The decree no longer sets a minimum: it asks for insurance suited to the nature and scope of the risk. Ask your insurer.

Is renting bikes without a guide active tourism?

We found no rule or regional guidance saying so. Ask the provincial tourism office.

Sources

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