A Spanish community of owners is an entity without legal personality, with a tax number starting with H. It can get a representative certificate for an entity without legal personality from the FNMT, Spain's Royal Mint. The president or a property manager authorised by the owners' meeting applies and proves their identity in person. It is free and valid for 2 years. It cannot be renewed: when it expires you apply again. And it is personal: whoever applied keeps it.
Why does the community need a digital certificate?
Because the law requires it to deal with public authorities online. Article 14.2 of Law 39/2015, Spain's general administrative procedure law, includes "las entidades sin personalidad jurídica" (entities without legal personality, which is what a community of owners, or comunidad de propietarios, is) among those who must deal with the authorities electronically "para la realización de cualquier trámite de un procedimiento administrativo" (for any step in an administrative procedure). It also includes "quienes representen a un interesado que esté obligado" (anyone representing a party who is so obliged), meaning the president or the property manager when they act for the community.
What matters most in practice is official notices:
- If you are obliged, notices are served electronically (art. 41.1).
- A compulsory electronic notice "se entenderá rechazada cuando hayan transcurrido diez días naturales desde la puesta a disposición de la notificación sin que se acceda a su contenido" (is treated as refused once ten calendar days have passed since it was made available without anyone opening it) (art. 43.2). The procedure goes ahead even if nobody read it.
- The Central Economic-Administrative Court (Tribunal Económico-Administrativo Central, TEAC), in a ruling to unify criteria of 22 January 2021 (RG 00/04868/2020), held that since Law 39/2015 the Tax Agency's power to serve electronic notices on those covered by article 14.2, entities without legal personality included, "no puede depender de la previa notificación de su inclusión" (cannot depend on first notifying them that they have been included) in the electronic notice system.
Put simply: the Tax Agency (Agencia Tributaria, AEAT) may be leaving notices for your community without anyone knowing, and after ten days they count as refused. To open them, the AEAT requires identification "con certificado del obligado o de un apoderado" (with the certificate of the obliged party or of an authorised representative). And Cl@ve, the government login system, is no way out for the community: to grant powers online, the AEAT accepts Cl@ve Móvil "sólo personas físicas" (individuals only).
The community also has its own tax obligations. One example is form 347, the annual return of dealings with third parties: communities of owners file it for purchases of goods and services above €3,005.06 with the same supplier in the year, not counting water, electricity, fuel and insurance.
Which certificate can a community of owners get?
From the FNMT (Fábrica Nacional de Moneda y Timbre), the representative certificate for an entity without legal personality (certificado de representante de entidad sin personalidad jurídica). The FNMT assigns it by the first letter of the tax number (NIF), and the letter H is listed as "Comunidades de propietarios".
Two things worth understanding from the start:
- It is a certificate for a person. The FNMT issues "exclusivamente Certificados de Firma de Persona Física, como representante de una persona jurídica o entidad sin personalidad jurídica" (only signature certificates for individuals acting as representatives of a legal person or an entity without legal personality) (terms and conditions). The holder is the president or the property manager, and the certificate names the community they represent.
- It is a qualified certificate under the EU eIDAS Regulation, and it can be used for "las relaciones con cualquier Administración Pública" (dealings with any public authority) (FNMT, question 1661).
It is not the only option. The ACCV (Agencia de Tecnología y Certificación Electrónica) issues an "entity representative" certificate (Representante de entidad) that covers communities of owners under the horizontal property regime.
FNMT or ACCV at a glance
| FNMT | ACCV | |
|---|---|---|
| Name | Representative of an entity without legal personality | Entity representative |
| Who applies | President, property manager or another person authorised by the owners' meeting | President or a property manager appointed for the purpose |
| How it works | Online application and identity check in person at an office | Web form with the documents attached, reviewed by the ACCV |
| Price (October 2026) | €0 | €33.88 as software or €55.55 on a card, VAT and postage included |
| Validity | 2 years | 3 years |
| Renewal | Not renewable: you apply again | Check with the ACCV |
Who can apply, and what paperwork is needed?
The Horizontal Property Act (Ley de Propiedad Horizontal, LPH) says that "el presidente ostentará legalmente la representación de la comunidad, en juicio y fuera de él, en todos los asuntos que la afecten" (the president legally represents the community, in court and out of it, in every matter affecting it) (art. 13.3). So the president is the natural applicant. But the FNMT also accepts the property manager (administrador de fincas) and others, with the paperwork it publishes for entities with an H tax number:
- President. The original minutes book (libro de actas) recording their appointment, or a copy or certificate of the minutes of the owners' meeting (junta de propietarios) that appointed them "con firmas legitimadas ante notario" (with the signatures legalised before a notary).
- Registered property manager (administrador colegiado, a member of a professional association). A notarial power of attorney (poder notarial), granted by the meeting or the president, with a special clause to apply for and use the certificate. Or the minutes book with an express resolution of the meeting naming them as the community's representative to "solicitar, obtener y utilizar" (apply for, obtain and use) the certificate. The minutes must state that the resolution is final, that it was passed with the legal majorities, their membership number and association, and that it has not been challenged in court. If the minutes do not say so, a certificate containing those points will do (the FNMT publishes a template).
- A property management company. Also a certificate from the Companies Register (Registro Mercantil) and the deed showing the powers of its representative.
- An owner, or a property manager who is not a member of an association. A resolution of the meeting in the minutes book expressly authorising them; a non-registered manager can also use a notarial power of attorney. They must also prove their qualification: a certificate from a professional association, an official degree or a certificate of professional competence.
For the community itself, the FNMT asks for documents proving it was set up, but you do not need to bring them if the identity check is done at a Tax Agency office.
The majorities for the resolution are those of the Horizontal Property Act, except in regions (comunidades autónomas) with their own civil law covering the matter, as the FNMT itself points out in that document.
At the ACCV, the paperwork for communities includes the community's tax number, a signed statement (declaración responsable) from the holder, the legalised minutes book and the minutes of the appointment. The minutes can be replaced by an AEAT census certificate (certificado de situación censal) no more than 30 days old naming the applicant as the community's representative, or by a notarial power of attorney.
How do you apply at the FNMT, step by step?
There are four steps, in this order:
- Set-up. Install the software the FNMT lists on your computer.
- Online application. You enter the community's tax number and receive an application code by email. Three details from the application page: the tax number must be final, not provisional; the email you give goes inside the certificate and is where notices about its life cycle will arrive; and the password you choose is needed again to download it, and if you forget it, it cannot be recovered: you start again.
- Identity check in person. With the application code, the paperwork and your original, valid identity document, you go to an accreditation office. According to the identity check page, for this certificate you can use Correos post offices (no appointment needed), Tax Agency offices (appointment needed), the CNMV (the securities regulator) and the Foral Community of Navarre, as well as Spanish consulates. If you cannot go yourself, someone else can, but only with your signature on the contract legalised before a notary.
- Download. With the code and the password you download the certificate from the FNMT website. The FNMT recommends making a backup copy.
The certificate for an entity without legal personality "no tiene coste de emisión" (has no issuing cost), and the price list confirms it: €0, as of October 2026.
How long does it last, and how do you renew it?
FNMT representative certificates are valid for 2 years, and the expiry date is inside the certificate itself.
There is no renewal. The terms and conditions say it plainly: "La FNMT-RCM no contempla la posibilidad de renovar los Certificado de Representante de Entidad sin Personalidad Jurídica. Una vez caducado el Certificado, se deberá solicitar uno nuevo" (the FNMT does not provide for renewing these certificates; once expired, a new one must be requested). In other words, every two years you repeat the four steps, with up-to-date paperwork.
One important detail: under the same terms, applying for a new certificate of the same type is a ground for revoking the previous one. Plan the switch so the new one is installed as soon as you apply, not in the middle of a filing.
What happens when the president changes?
This is the practical problem. Unless the community's statutes say otherwise, its officers are appointed "por el plazo de un año" (for one year) (art. 13.7 LPH), and the certificate lasts two.
When the representation ends, the certificate must stop being used. Law 6/2020 on electronic trust services makes this a ground for revocation and adds that "tanto el representante como la persona o entidad representada están obligados a solicitar la revocación de la vigencia del certificado en cuanto se produzca la modificación o extinción de la citada relación de representación" (both the representative and the represented entity must request revocation as soon as the representation changes or ends) (art. 5.1.e). The FNMT terms also require holders to "no utilizar el certificado cuando varíen los datos del representante y solicitar la revocación del mismo" (stop using the certificate when the representative's details change, and request its revocation).
You can request revocation in three ways: at an AEAT, CNMV or Navarre office; on the FNMT website (online cancellation); or by phone, with the application code.
That is why it can pay to have the certificate in the property manager's name, backed by a resolution of the meeting. Then you do not have to revoke it and apply again every time the presidency rotates. The flip side: the FNMT lists "el cese, renuncia o pérdida de la condición de administrador" (the manager leaving, resigning or losing that status) as a ground for revocation, so if you change property manager, you revoke too.
Who keeps the certificate? Can the president hand it to the property manager?
They should not. The FNMT points out that its certificates "son personales e intransferibles" (are personal and non-transferable) and that it "recomienda encarecidamente que el certificado no se entregue a terceros" (strongly recommends not handing the certificate to third parties), with the signatory and the represented entity responsible for keeping it safe (FNMT, custody recommendations). It also cites a note from the Secretary of State for Digital Progress, of May 2019, stating that "la transferencia de la posesión o la revelación de las claves de un certificado electrónico no es conforme con la legislación vigente" (transferring possession of an electronic certificate, or revealing its keys, does not comply with the law).
So whoever applied keeps it: the president if it is in their name, the property manager if it is in theirs. The FNMT terms require them to act "con diligencia" (with diligence) in keeping keys, codes and passwords safe, and to request revocation if they suspect anyone else knows them.
If the president holds the certificate but the property manager does the work, there are two proper ways out: the manager gets their own certificate as the community's representative (with a resolution of the meeting or a power of attorney), or the community authorises the manager at the Tax Agency.
What if the property manager uses their own certificate? Authorisation at the AEAT
The Tax Agency keeps a register of authorisations (registro de apoderamientos) that lets a taxpayer authorise someone else to carry out procedures "con su propio certificado electrónico de usuario" (with their own electronic certificate). There are three ways to grant it:
- Online, with an electronic signature. For this the community already needs its own certificate.
- In person, at an AEAT office, using the official form. If the grantor is an entity without legal personality, the person attending must prove they are its legal representative or hold sufficient powers; in a community, usually the president.
- By public deed, or by a private document with the signature legalised before a notary.
For notices, the authorisation to register is the GENERALNOT procedure (or a specific one for receiving notices). The authorised person has to confirm it on their side for it to take effect. If no end date is set when it is granted online, the AEAT treats it as open-ended, "hasta que el poderdante lo revoque o el apoderado lo rechace" (until the grantor revokes it or the representative rejects it) (AEAT, access to DEHú notices through authorisation).
The limit: this authorisation works with the Tax Agency. Each authority has its own register of authorisations (art. 6, Law 39/2015), so for Social Security, the town hall or the regional government you need to check theirs, or have the community's certificate.
What should you record for each community?
If you manage several communities, keep a record for each one with:
- Type of certificate (FNMT or ACCV) and whose name it is in.
- Expiry date, taken from the certificate itself.
- The email inside the certificate, so the FNMT's notices do not land in a mailbox nobody reads.
- Which computer it is installed on and where the backup is.
- Current authorisations at the AEAT and other authorities.
- The date of the next owners' meeting, in case the president or manager changes and you need to revoke.
For the dates, our expiry tracking template in Excel does the job. If you manage many buildings and would rather be told, Renewals emails you before something expires, checks the dates every morning and keeps each company isolated in the database. More ideas for property management firms in automation for property managers.
Frequently asked questions
Is a digital certificate compulsory for a community of owners in Spain?
The law requires the community to deal with public authorities electronically and to receive their notices that way (arts. 14.2 and 41.1, Law 39/2015). To open AEAT notices you need the community's certificate or an authorised representative's. In practice, either the community has its certificate or someone is authorised.
How much does a community of owners' digital certificate cost?
From the FNMT, nothing: €0 as of October 2026. From the ACCV, €33.88 as software or €55.55 on a card, VAT and postage included.
How long is the community's certificate valid?
The FNMT one, 2 years; the ACCV one, 3 years. The exact expiry date is inside the certificate.
How do you renew a community of owners' certificate?
At the FNMT it cannot be renewed: when it expires you apply for a new one, repeating the application, the in-person identity check and the download. Bear in mind that applying for a new one of the same type revokes the previous one.
Can the property manager apply for it?
Yes. They need a notarial power of attorney with a special clause, or a resolution of the owners' meeting in the minutes book authorising them to apply for, obtain and use the certificate. The certificate is then in their name as the community's representative, and they keep it.
Sources
- Law 39/2015 on the Common Administrative Procedure of Public Administrations, arts. 5, 6, 14, 41 and 43.
- Law 49/1960 on Horizontal Property (Ley de Propiedad Horizontal), art. 13.
- Law 6/2020 on certain aspects of electronic trust services, art. 5.
- TEAC, ruling of 22 January 2021, RG 00/04868/2020 (unification of criteria).
- FNMT: representative certificate for an entity without legal personality.
- FNMT: paperwork for entities with an H tax number (communities of owners).
- FNMT: application.
- FNMT: identity check.
- FNMT: steps to obtain the certificate for an entity without legal personality.
- FNMT: price list for representative certificates.
- FNMT: terms and conditions of the certificate for an entity without legal personality.
- FNMT: validity of representative certificates.
- FNMT: scope of representative certificates.
- FNMT: how to revoke a representative certificate.
- FNMT: recommendations on certificate custody.
- ACCV: entity representative certificate.
- ACCV: paperwork for communities of owners (H tax number).
- Tax Agency: how to grant an authorisation.
- Tax Agency: access to DEHú notices through authorisation.
- Tax Agency: form 347.
This article explains the law and published court criteria as of the update date. It is not a substitute for advice from a lawyer on a specific case.