The Spanish Confederation of Hotels and Tourist Accommodation (CEHAT) has demanded that the central government repeal the new traveler registration system introduced by Royal Decree 933/2021. The federation argues the regulation violates European Union law, creates excessive bureaucracy, and risks harming the country’s tourism industry.
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What the Law Requires
Royal Decree 933/2021 came into force on 2 January 2023, with a phased adaptation period ending on 2 December 2024, after which non-compliance may be fined.
The decree applies to all types of accommodation in Spain, including hotels, apartments, guesthouses, hostels, campsites, resorts, and spas. It also extends to intermediary services and online platforms, as well as vehicle rental companies.
One of the most notable changes is the switch to the new SES.Hospedajes platform, where establishments must send guest data directly to the Ministry of the Interior, replacing the previous systems used by the Civil Guard (Hospederías) and Police (WebPol.
CEHAT’s Objections
CEHAT, which represents the sector through 51 regional and sectoral associations, has raised strong objections:
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Legal conflict: The federation argues the decree “violates EU law and regulations regarding data protection” and undermines the free movement of people.
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Data demands: Businesses must now collect 17 items of personal information from every guest, compared with 9 previously. This includes names, surnames, gender, nationality, date of birth, full address, phone numbers, email, number of travellers, and relationships between them if minors are present.
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Administrative burden: CEHAT says the decree forces hotels and small businesses to act as data collection agents for the state, increasing costs and paperwork without clear benefits.
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Unclear obligations: The decree does not fully specify how requirements apply to different operators. CEHAT insists the government must clarify this through a ministerial order.
Fines and Sanctions
Failure to comply can result in heavy penalties under Spain’s Citizen Security Law (Organic Law 4/2015).
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Minor infractions: €100–€600, for late submissions or incomplete registration.
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Serious infractions: €601–€30,000, for failing to keep required records or not submitting guest data at all.
These penalties apply nationwide, except in Catalonia and the Basque Country, where establishments must continue reporting to regional police (Mossos d’Esquadra and Ertzaintza).
Industry Calls for Change
CEHAT President Jorge Marichal has urged the Ministry of the Interior to “restore common sense” and either repeal Royal Decree 933/2021 or urgently adapt it. He warns the regulation creates “rejection and increased administrative burdens for those who have always shown a sincere attitude of collaboration”.
Until the government clarifies the law or revises the decree, hotels, rental platforms, and even car hire companies remain uncertain about how to comply with both Spanish and EU rules.
