CORONAVIRUS AND TOURISM IN SPAIN 279 making it clear – as it was to hope – that the Order had been formulated in broad terms and that, therefore, the suspension does cover all types of tourist accommodation, both hotel and non-hotel. Undoubtedly, greater precision would have improved the content of the standard. In the second part, an exception allows those establishments that host clients who, at the time of the alarm declaration, were staying in a stable and seasonal way, to remain open provided their occupants have the infrastructure, in their own housing, to carry out the activities of first necessity in the terms established by Royal Decree 463/2020. However, these establishments will not be able to admit new customers until the suspension ends. The closing will take place at the moment in which the establishment has no clients and, in any case, within a maximum period of seven calendar days from the entry into force of the Order (19 March 2020). In other words, the closure of the establishments, with the exceptions mentioned, was due to take place at 23:59 on 26 March 2020; their validity will last until the end of the declaration of the State of Alarm or extensions thereof. Keep in mind that the Congress of Deputies has authorised the extension until 00:00 on 26 April (Resolution of 9 April 2020, of the Congress of Deputies, ordering the publication of the Authorisation Agreement of the extension of the state of alarm declared by Royal Decree 463/2020, of 14 March). Will establishments be able to admit new clients? This question was answered in the report from the Ministry of Industry, Trade and Tourism, which alluded to the last clause of the second section and, therefore, new clients are prohibited from said establishments from the time the Order entered into force, notwithstanding the clients who would have started their accommodation on 19 March 2020. All of this without prejudice to the provisions of Order TMA/277/2020, of 23 March. García Rato, in his analysis of the economic impacts on restaurants, warns of the enormous economic damage that this entails for entrepreneurs who have lease contracts and who may face contractual resolutions for a more significant cause or, at least, the novation of the terms agreed under the rebus sic stantibus clause. Is COVID-19 a reason for contractual termination? Who would think that there could be a global pandemic? In Royal Decree 463/2020 the legal term “force majeure” is not mentioned, so its application does not seem easy. In conclusion, it is necessary to note that Royal Decree 463/2020 does not expressly include tourist guides, despite being very clear that they cannot carry out their activity during the State of Alarm as they provide their services in the street, museums and various monuments. The problem that initially arose was that, in order to qualify for the extraordinary cessation without having to prove
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