ON-SITE CHECK-IN: REMOTE IDENTIFICATION NOT ALLOWED FOR ACCOMMODATION FACILITIES

LT Immobili & Design 16 January 2025

The Italian Ministry of the Interior has recently clarified, through a circular signed by Police Chief Vittorio Pisani, that remote check-in for accommodation facilities—where guests are identified via online submission of identity documents and access to the property is granted through digital codes or key boxes—is not permitted.

According to the circular, remote identification does not meet the minimum security standards required by current regulations. When access to a property occurs without an in-person identity verification following the online submission of documents, there is no guarantee of the actual identity of the occupants. This poses a security risk, as law enforcement authorities may not be able to quickly identify the guests staying at the property.

The Constitutional Court has also weighed in on this issue, reiterating that the obligation to report the personal details of guests, as outlined in Article 109 of the Public Security Act (TULPS), is primarily aimed at ensuring public safety. Accurate and timely communication of guest data allows law enforcement to monitor who is staying in accommodation facilities—an essential tool for preventing crimes and other illegal activities.

The circular also addresses home-swapping platforms like HomeExchange. In such cases, the details of all individuals involved must be registered on the Alloggiati Web portal. This requirement aims to prevent the risk of false data being submitted to evade controls or occupy a property without proper identification by authorities.

The same rules apply to Marina Resorts, which are facilities designed for tourists to stay overnight on moored recreational boats. Although these are not traditional accommodation facilities, they are treated as such under fiscal and legal regulations. As a result, Marina Resorts must comply with Article 109 of the TULPS, including the requirement for in-person identification of guests.

The circular emphasizes that any exceptions or distinctions proposed by private operators, such as claims of being unable to physically verify documents, are irrelevant and contrary to the purpose of the law. The primary goal remains to ensure public safety, which requires direct and in-person identification of guests.

Accommodation operators must adapt to these requirements and ensure that guest identification is conducted exclusively in person. This may involve updating internal processes and technologies used for access management.

While these measures might appear to hinder the simplification of procedures, they represent a crucial step in preserving public safety and mitigating risks associated with the remote management of accommodation facilities.

If you have questions about how to comply with these new regulations or would like to learn more, feel free to contact us. We're here to help ensure your facility adheres to the rules and provides a safe and reliable experience for your guests.