Guest registration: obligations and SES.HOSPEDAJES
Royal Decree 933/2021 governs registration and reporting obligations for accommodation activities. To organise your current operation, consult the SES.HOSPEDAJES instructions and distinguish the initial details of the business from those relating to bookings and travellers.
The process is not limited to check-in: it must be coordinated from the booking stage and cover changes, cancellations and the start of the service.
This legislation makes operations more complex, as it considerably expands the information that must be collected from registered guests and the records that must be retained.
In this article, we explain the main changes introduced by the legislation.
Guest registration: details, signatures and reporting
Who does it apply to?
The Royal Decree applies to all individuals and legal entities providing accommodation in Spain, whether or not they do so professionally.
This means that both managers and owners of any type of accommodation must comply, whether it is a hotel, guesthouse, rural property, aparthotel, holiday let or another form of accommodation.
How are arrival registration forms signed?
Article 4.2 of Royal Decree 933/2021 requires signatures from people over fourteen years of age. Details of children under fourteen are supplied by the adults accompanying them. Collecting details and requiring a signature are separate obligations.
What record-keeping obligations apply?
Article 5 of the Royal Decree states that a computerised register containing guest details, regardless of age, must be kept for three years from the end of the accommodation service.
The change makes electronic registration of all travellers’ details compulsory, including those over fourteen. The previous rules also required registration books to be retained for three years.
The record-keeping obligation distinguishes between professional and non-professional activities. Do not automatically equate an individual owner with a non-professional activity: check how the activity is actually classified and distinguish data retention from reporting.
The obligation to report to the authorities
The reporting obligation covers both professional and non-professional operators under the terms of the Royal Decree. Consult the Spanish Ministry of the Interior’s SES.HOSPEDAJES service for the current system and operating instructions.
Reporting before starting the activity
Initial details of the activity must be reported before it begins and within a maximum of ten days after completing the required administrative procedures, under Article 6.2. This must not be confused with the deadline for reporting each booking or the start of the service.
Any subsequent changes to those details must also be reported.
Information must be reported to the authorities electronically by professional operators; non-professional operators may also use non-electronic means.
Professional operators must report the following information:
- Company details.
- Establishment details.
Non-professional operators must report the following information:
- Property owner’s details.
- Property details.
Reporting obligations during the activity
As mentioned above, it is essential for both professional and non-professional operators to report the information required by the Royal Decree to the authorities.
Article 6.3 requires immediate reporting, within a maximum of twenty-four hours, for the events it lists: booking or formalisation, cancellation and commencement of the service. Organise the process so that you do not wait solely until arrival.
The information to be reported under the Royal Decree differs according to whether the operator is professional.
Professional operators must report all the information relating to travellers and the transaction. Non-professional operators must also report traveller details and transaction information.
What has changed compared with the previous rules?
Implementation forecasts in a 2022 guide no longer describe the current process. Use the Ministry of the Interior’s current system and instructions, and check that reports have been accepted.
Use the procedure and reporting system specified by the Ministry of the Interior for the activity. An old WebPol tutorial is not a substitute for the SES.HOSPEDAJES instructions.
Many agencies manage holiday lets, hotels and other types of accommodation.
At Alehost, we manage these properties in accordance with the updated rules, handling traveller check-in and check-out under the legislation in force.
If you delegate management, set out in writing who collects the details, checks their accuracy, submits reports and handles errors. Delegation requires supervision and a clear allocation of responsibilities.
How to organise compliance without duplicating data
Define who collects the information, who checks issues and who sends the reports. If you use a check-in provider, confirm the contracted scope, data access, supporting records and procedure for handling errors. Automation does not remove the need to check that a report has been accepted.
Article 5 distinguishes record retention from the exception for non-professional activities. Do not confuse that exception with having no reporting obligations. Restrict access and establish a retention and deletion procedure appropriate to your circumstances.
Identification does not mean keeping a copy of an identity document
The Spanish Data Protection Agency (AEPD) cautions against requesting full document copies to meet registration requirements: collection must be limited to the necessary details and proportionate identity verification. Avoid storing images of identity cards or passports by default, and do not use those details for unrelated commercial purposes.
For day-to-day implementation, see how to manage registration between booking and arrival.
