Condo Debtor Lists in Colombia: What Can Be Published?

Law 675, article 30 allows publication of overdue common-fee information inside the property while the default continues. Publication must avoid places with constant visitor traffic and allow owners to learn of the default.

What it is

A debtor list identifies owners with overdue common fees. Article 30 permits a restricted notice within the property; it does not require that notice. The assembly minutes must include owners in arrears. Article 39, paragraph 2, requires the meeting notice to list owners who owe common contributions.

In C-328/19, the Court upheld the challenged publication sentence in article 30(2). It also upheld article 59(1), which concerns non-monetary breaches. Both decisions address the constitutional challenges examined in that case.

Sections 2.1.1.11–2.1.1.15 treat common-fee default information as semi-private. For this restricted internal publication, the Court did not require the ordinary consent used for credit-risk databases. It preserved rights to dispute, correct and update data throughout the process required before any sanction. This ruling does not approve every notice or digital channel.

Who it applies to

This guide covers administrators and councils handling common-fee records. It does not assess a specific debt or authorize a particular publication. A Colombian lawyer can assess the channel and procedure for the case.

Personal-data principles

Law 1581, article 4, requires a lawful purpose, accurate current information, restricted access, security and confidentiality. The purpose must be disclosed to the data subject. Consent must be prior, express and informed, with legal exceptions. The special permission in article 30 does not remove the other safeguards.

The SIC condominium data guide, pages 8–10 and 12–15, explains relevant data, authorization, third-party duties and data subjects’ rights. It is general guidance. The specific ruling on the debtor-list permission cited here is C-328/19.

Internal review and public disclosure

Audience or channel	Scope and limit
Administrator and authorized accounting team	Records needed for accounting and collection, within the lawful purpose and assigned work.
Council, where one exists	Information needed for its lawful reporting and decision role. Membership does not allow unrestricted disclosure.
Owners' meeting notice and minutes	The lists required by articles 39 and 30. These duties do not make the documents public internet content.
Notice within the property	Article 30 allows publication while the default continues, away from constant visitor traffic.
Public website, social network or open chat	Article 30 does not authorize disclosure to the general public. Law 1581 restricts mass access to non-public personal data.

This table reads the functions in articles 51 and 55 together with articles 4 and 13 of Law 1581. A private channel still needs lawful recipients and effective access controls.

Steps

Suggested evidence checks before any proposed notice. These checks do not replace the procedure required before any sanction:

Check the charge and due date against the supporting records.
Compare the unit balance with receipts and actual bank credits.
Review unidentified payments before treating the unit as unpaid.
Give the affected owner a channel to dispute or correct the information before publication.
Record the purpose and lawful recipients of the proposed disclosure.
Limit the draft to relevant debt information.
Exclude ID copies, phone numbers, bank details and personal explanations unrelated to the debt.
Check the actual audience of the notice location or digital channel.
Correct errors and update the current notice when the payment position changes.

A restrained draft can identify the owner or unit, the relevant period and the documented overdue balance. This is a proposed control, not an official list of mandatory fields. Applying article 3 of Law 1581, a unit number is personal data if it can be linked to an identifiable individual.

See unidentified payments and bank reconciliation before drawing conclusions from a balance. Building fees and late interest have separate guides.

Documents

Suggested review file: approved charges, unit account, payment records, correction requests, notice version and recipient or access record. A council summary can follow the administrator report guide. Full bank records need the controls in the statement access guide.

Deadlines

Article 30 limits the notice to the period when the default continues. A paid balance must not remain described as currently unpaid. This concerns the current notice. Historical records and corrections to past minutes need separate review. Formal data complaints follow article 15 of Law 1581. A complete pending complaint must be marked in the database under that procedure.

Common mistakes

Using a visible entrance wall. Constant visitor traffic conflicts with article 30.
Publishing an unreviewed balance. An unapplied payment may explain the difference.
Adding private explanations. Health or family details do not belong in a routine debt notice.
Assuming no name means no personal data. A unit can still identify its owner.
Using the wrong rule. Article 59 concerns non-monetary breaches; it does not expand article 30's publication permission.

Exceptions

This guide covers common-fee notices inside a condominium. Credit-bureau reporting, court filings and non-monetary sanctions need separate legal review. A disputed debt or failed payment allocation requires examination of the evidence, not a public accusation.

Sources

Sources checked on 26 October 2026.

Educational information, not legal or tax advice. Ask a Colombian lawyer or accountant about your case.

Next step

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Frequently asked questions

Does personal-data law prohibit every condo debtor list?

No. Article 30 permits restricted publication while the default continues. C-328/19 upheld the challenged sentence for the constitutional grounds examined. It preserved rights to dispute, correct and update the data before a sanction.

Can the list go on the entrance noticeboard?

Not if the location has constant visitor traffic. Article 30 limits the location and requires that owners can learn of the default.

Does a private resident chat make publication lawful?

The chat label alone proves nothing. Its recipients, purpose and access controls need review. Article 30 does not grant permission for unrestricted forwarding.

Does removing names make unit numbers anonymous?

Not necessarily. A unit number remains personal data if it identifies or can link to a natural person.

What if an owner says the fee was paid?

The administrator needs to review the receipt and bank records. An error needs correction. The owner keeps rights to dispute and update the data.

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