Required permits for window replacement in Spain: a step-by-step guide

Your neighbor replaces windows in two days without any paperwork, but you’re forced to wait three months for permission? The building manager says permission isn’t needed, but the mayor’s office demands an architect’s plan? We’ll explore which documents are needed, how much it costs, and how to speed up the process. We’ll also provide real-life examples and sample applications.

When permission isn’t needed - simple cases

In some situations, you can replace windows without the hassle. But “no permission required” doesn’t mean “do whatever you want” – basic requirements must still be met.

Replacing glass or double-glazed windows in an existing frame doesn’t require any permits. Replacing broken glass or an old double-glazed window with energy-efficient glass is a renovation, not construction work. The main thing is that the appearance (tint, reflectivity) remains unchanged.

Hardware repairs – replacing hinges, handles, locks, and seals – are considered maintenance. Even if you’re replacing a complete set of hardware for €500, a permit isn’t required.

Interior work, not visible from the street, includes installing window sills, slopes, and interior mosquito nets. However, if the mosquito net changes the appearance of the façade (for example, a roller net is visible from the outside), questions may arise.

A private home on its own property outside of urban developments and historic zones—replace the windows as desired, as long as the CTE technical standards are met. However, if the house is in an urban development, a listed building, or a protected area, the rules are the same.

An important caveat: the lack of a permit requirement does not exempt you from liability. If you install windows that do not meet safety standards and an accident occurs, you are entirely responsible. The insurance company may refuse to pay.

Declaration of Liability—the most common case

Declaration of Responsibility or Preliminary Communication is a simplified procedure for work that does not affect the building’s structure. It is suitable for 70% of window replacements in standard apartments.

When is the declaration appropriate?

• Replacement of windows with similar sizes and appearances
• Installation in the same openings without changing the dimensions
• Material and color match existing or permitted ones
• The façade configuration remains unchanged

Required documents:

1. Declaration form (descarga on the ayuntamiento website)
2. Copy of DNI or NIE
3. Copy of escritura or lease agreement
4. Description of work (can be handwritten)
5. Sketch or photo of windows
6. Budget from the installer
7. Receipt for payment of municipal tax

Cost: €50-€200 depending on the municipality. Madrid - €85, Barcelona - €120, Valencia - €65, smaller cities - often €30-€50.

Process: Submit documents to the municipal registry or online through the electronic signature system (an electronic signature is required). Work can begin immediately after submission—you don’t need to wait for a response. However, the municipality can check within three months and stop the work if anything is wrong.

Typical Mistake: Many people think that since work can begin immediately, they can file a declaration later or not at all. This is a violation. The fine is from €300 to €3,000, plus legalization.

Minor License—When a Project is Needed

A minor license is required for work that changes the building’s appearance or affects common areas.

Cases requiring an obra menor:

• Changing the size of window openings
• Installing external roller shutters
• Changing a material or color different from the existing one
• Combining two windows into one or dividing them
• Installing French windows instead of standard ones
• Work in cataloged buildings (grado 2-3)

Documents required for an obra menor:

1. Application on the municipal form
2. Technical memorandum from the architect or apparel specialist
3. Plans and sections indicating changes
4. Detailed presupposition by parts
5. Photographs of the current condition
6. Coordination with the owners’ association
7. Justificante payment of the fee and ICIO

Technical memorandum is the key document. The technical architect describes:

• Current status
• Planned changes
• Compliance with regulations
• Safety measures during work
• Waste management

The cost of technical memoria is €300-€800, depending on complexity and region. It’s more expensive in Madrid and Barcelona, ​​and cheaper in the countryside.

Municipal fees:

• License fee: 2-4% of the work budget
• ICIO (Construction Imperative): 2-4% of the budget
• Total: 4-8% of the work cost

Example: replacing 5 windows for €5,000 + €200-€400 in fees + €500 technical memoria = additional costs of €700-€900.

Receipt timeframe:

• Official: 1 month
• Real: 1.5-3 months in large cities
• With an additional 50% urgencia fee: 15 days

License of Obra Mayor — Complex Cases

A major license is rarely needed, but if you do, be prepared for significant expenses and a wait.

When is a major renovation required?

• Structural modifications (widening and reinforcing openings)
• Replacement of more than 50% of the building’s windows at one time
• Building façade modifications (new openings, balconies)
• Work at the Cultural Interest Center (BIC)
• Comprehensive façade rehabilitation

A complete project from an architect is required, including:

• Descriptive and justified memoranda
• Current and reformed condition plans
• Structural calculations (if necessary)
• Energy efficiency calculation
• Basic and sustainable building design
• Detailed medical and presuppositional studies
• Technical air conditioning plan

Project cost: €1,500-€5,000 depending on complexity. For historic buildings, the cost can reach €10,000.

Additional requirements:

• Architect’s College Visa (200-500 euros)
• Architect’s Certificate of Eligibility
• Property Management Certificate
• Property Management Coordinator (if multiple companies are involved)

Deadlines: 2-6 months, up to a year for historic buildings.

Coordination with the Owners’ Association

In addition to municipal permits, coordination with the owners’ association is required.

What requires mandatory approval:

• Any changes to the exterior façade
• Installation of external elements (roller shutters, awnings)
• Changes to window color or material
• Installation of air conditioners on the façade

Approval procedure:

1. Written notification to the administrator one month before the meeting
2. Including the issue on the agenda
3. Presenting the project at the meeting
4. Voting (3/5ths required for façade changes)
5. Obtaining an extract from the act

If the community is against:

• Can be challenged in court if the refusal is unlawful
• Arguments: energy efficiency improvements, similar work by neighbors
• Appeal period: 1 year
• Cost: from €2,000

Life hack: If several neighbors want to change their windows, team up. A group application has a better chance of being approved, plus you can receive a discount from the supplier and share the project costs.

Features for Tenants

Tenants can change windows, but there are restrictions and obligations.

Required:

• Written permission from the owner
• Agreement on who pays and who gets to keep the improvements
• All municipal permits are issued to the tenant
• Approval from the community on behalf of the owner

Typical Schemes:

• Tenant pays, lease is extended
• Costs are shared, windows remain with the owner
• Owner pays, rent is increased

Important: Without the owner’s written permission, any changes are a breach of contract. The owner can demand restoration to the original condition at the tenant’s expense.

Working with Installers - Who is Responsible for What

A licensed installer can handle the paperwork. This typically costs 200-500 euros on top of the labor, but saves time and hassle.

What the installer must provide:

• A detailed presupposition with specifications
• CE certificates for the product
• RC (liability) insurance
• Installation certificate after completion of the work
• Residual disposal (disposal of old windows)

Residual disposal is mandatory. Old windows cannot be disposed of in a regular container. The installer must:

• Take them to a recycling center
• Provide a recycling certificate
• Include this in the price (usually €30-€50 per window)

Subsidies — How to Maintain Your Eligibility

Critically Important: Most subsidies require an application BEFORE work begins. If you begin work without approval, you lose your eligibility.

Procedure for receiving a subsidy:

1. Initial energy audit (300-500 euros, sometimes subsidized)
2. Submitting a subsidy application with a project and presupesto
3. Waiting for preliminary approval (1-3 months)
4. Obtaining a municipal license
5. Completing the work within the specified timeframe (usually 6-12 months)
6. Final energy audit
7. Submitting documents for payment
8. Receiving the funds (2-6 months after completion)

Documents for the Plan PREE subsidy:

• CEE (energy performance certificate) prior to work
• Project or technical memorandum
• Three presupestos from different companies
• Declaration of responsibility for no tenant deudas
• Property documents
• Empadronamiento (for primary residence)

Timeframes and how to speed them up

Actual timeframes for receiving Permits:

Declaration of Liability:

• Online submission with digital certificate: same day
• Submission to the registro: 1-3 days for registration
• Work begins: immediately after registration

Regular Obra Menor:

• Madrid: 45-60 days
• Barcelona: 60-90 days
• Valencia: 30-45 days
• Cities with a population of up to 50,000: 15-30 days

How ​​to speed up the process:

1. Urgentization process — 50% surcharge, halving the timeframe
2. Online submission saves 5-10 days on registration
3. Complete set of documents — incomplete ones will be returned, losing 2-3 weeks
4. Preliminary consultation in urban planning — learn the exact requirements
5. Working with gestores — they know the system and have contacts (cost) 300-600 euros)

Fines and consequences of violations

Work without a permit:

• Fine: 600-3,000 euros for individuals
• Legalization obligation
• If legalization is not possible, restoration to the original condition
• Legalization costs often exceed the original permit cost

Work performed does not comply with the project plan:

• Fine: 300-6,000 euros
• Modification of the license (new project)
• Possible reworking of the work

Violation of community rules:

• Civil suit from the community
• Obligation to restore the original condition
• Compensation for damages (if they can prove a decrease in the building’s value)
• Legal costs (3,000-10,000 euros)

Checklist of documents by permit type

For the declaration of liability: ☐ Declaration form Completed ☐ Copy of DNI/NIE ☐ Title deed ☐ Description of work (1 page) ☐ Photo/sketch of windows ☐ Installer’s specifications ☐ Payment receipt ☐ Community consent (if appearance is being changed)

For a residential building, add: ☐ Technical memorandum from an installer ☐ Plans with changes ☐ Detailed specifications by parts ☐ Installer’s RC specifications ☐ Residence permit plan

For a residential building, add: ☐ Project from an architect ☐ College visa ☐ Residential studio ☐ Contract management ☐ Energy efficiency calculation

Features of Popular Cities

Madrid:

• Online submission via sede.madrid.es works well
• They require photos of all building facades
• In the center (inside the M-30), they check the RAL color
• The express procedure actually works in 15 days

Barcelona:

• The strictest requirements for historic buildings
• They require technical information even for the declaration
• The online system is often glitchy, so it’s better to use the online system
• In Eixample, an obra menor is almost always required

Valencia:

• Relatively fast turnaround times
• They are lenient towards modern materials
• They require a waste evacuation plan
• Subsidies are processed separately through the GVA

Seville:

• Only white windows in the historic center
• They require approval from the Patrimonio (+2 months)
• Any external elements on the facade are prohibited
• Work only from October to March (due to the heat)

Bilbao:

• Increased water resistance requirements
• Mandatory asbestos testing for buildings built before 1980
• The most generous subsidies in Spain
• Fast review (15-30 days)

Practical advice from experts

From a technical architect: “Don’t skimp on technical documentation. A good document not only guarantees quick approval but also protects against claims from neighbors and the municipality. It’s worth including a ‘before and after’ photomontage—officials love visuals.”

From a window installer: “Always ask the client for a copy of the permit before starting work. If the inspector arrives on-site and there’s no permit, both the client and the contractor will be fined. We’ve had cases of fines of 2,000 euros each.”

From a real estate lawyer: “The most common problem is conflicts with the community. Even if community permission isn’t legally required, it’s better to notify and at least obtain tacit consent. Courts often side with aesthetic uniformity.”

From gestor: “Start the paperwork 3-4 months before the planned work. Haste is always more expensive – urgencia, additional trips, corrections. And never start work in August – half the officials are on vacation.”

Properly obtaining permits isn’t about bureaucracy; it’s about protecting your investment. Spend time on the paperwork now to avoid paying fines and having to redo the work later.