Is there a min distance between spa disconnect panel and outdoor shower?
I can find nothing in the National Electrical Code to prevent you from doing this.

It is the hot tub that is required to be at least 5' away from the disconnect.


  680.12 Maintenance Disconnecting Means. One or more means to simultaneously disconnect all ungrounded conductors shall be provided for all utilization equipment other than lighting. Each means shall be readily accessible and within sight from its equipment and shall be located at least 1.5 m (5 ft) horizontally from the inside walls of a pool, spa, or hot tub unless separated from the open water by a permanently installed barrier that provides a 1.5 m (5 ft) reach path or greater. This horizontal distance is to be measured from the water’s edge along the shortest path required to reach the disconnect.


Light fixtures and switches are regularly close to showers indoors and I would argue this is similar even though it is outdoors. Electrical panels are not allowed in bathrooms, but this is not a panel and a lone shower does not constitute a bathroom.

Still, if feasible I would place it further away just as a safety measure.

Good luck and stay safe!