Are self check-ins and key boxes really becoming illegal? Let's clarify

Over the past few years, Self Check-in has rapidly gained traction, with more than 40% of accommodations worldwide using automated systems, particularly in the short-term rental and vacation home sectors (source: Hotel Tech Report). Key Boxes, in particular, are popular among smaller operators for their simplicity and cost-effectiveness, reducing operational costs by eliminating the need for staff to hand over keys.

However, even before the Ministry’s statement, these tools sparked heated debates, as they were considered both unsafe and a driver of overtourism. Florence, for example, has decided to ban the use of Key Boxes starting in 2025.

Surprisingly, even Airbnb has sided with Italian cities, expressing support during the recent ANCI assembly in Turin. The platform committed to promoting more responsible hospitality centered on direct guest interaction. Airbnb has announced targeted initiatives to combat the illegal use of Key Boxes in public spaces, including educational campaigns and collaboration with its network of local co-hosts.

Italian regulations on guest identity verification date back to Royal Decree No. 773 of 1931. Article 109 of the TULPS (Consolidated Text of Public Safety Laws) currently governs this requirement.

It specifies:

• Applicability: The law applies to "hotel operators and other accommodation providers, including those offering lodging in tents, caravans, vacation homes, and guesthouses, as well as operators of unconventional hospitality establishments, except alpine shelters included in specific regional or provincial lists."
• Identity Verification: Guests may only be accommodated if they present a valid ID card or other documents attesting to their identity under current regulations.
• General Information Form: Accommodation providers must provide guests with a general information form approved by the Ministry of the Interior. Even if filled out by the operator, this form must be signed by the guest.

The automated nature of Self Check-in and Key Boxes inherently conflicts with these requirements, as they do not include direct verification of documents or personal interaction, potentially exposing accommodations to violations of current laws.

In its November 18, 2024 Circular (No. 38138/2024), the Ministry of the Interior reaffirmed that Self Check-ins and Key Boxes are non-compliant with Article 109 of TULPS if they do not include direct identity verification of guests.

The statement emphasized the obligation for operators to verify guest identities "de visu" (in person) to ensure consistency with the presented identification document.

This measure was driven by the increase in short-term rental activity, influenced by numerous political, cultural, and religious events scheduled in Italy, including the 2025 Jubilee in Rome. The clarification aims to prevent illegal activities and safeguard public security.

The Ministry’s statement has had a significant impact, forcing many accommodations to reevaluate their operations.

Using Self Check-ins without proper precautions poses risks for both the public and accommodation providers:

• Compromised security: The lack of personal verification facilitates access by unidentified individuals, increasing the risk of crime or illegal activities.
• Legal non-compliance: Accommodations violating the regulations may face administrative sanctions or, in severe cases, suspension of operating licenses.
• Legal liability: In the event of incidents or misuse of the property, the absence of identification can expose operators to severe legal consequences.
• Unauthorized access: Low-cost Key Boxes are especially vulnerable to theft and tampering, heightening the risk of unauthorized entries.

In various countries, advanced technologies like facial recognition have enabled the use of Self Check-ins while maintaining safety standards.

• Singapore: Hotels use the E-Visitor Authentication (EVA) system, allowing guests to scan passports and verify identities through facial recognition. Data is sent to the Immigration and Checkpoints Authority (ICA) for validation.
• United States: Some accommodations use mobile apps for remote check-ins, enabling guests to verify their identity via a selfie and receive a digital room key.
• Europe: Adoption varies, but there is a growing trend toward hybrid systems combining facial recognition with legal compliance.

The future of Self Check-in could be shaped by artificial intelligence and biometric technologies like facial and iris recognition.

Airlines are already leading the way in this regard: Lufthansa and Austrian Airlines already use biometric recognition for security checks, lounge access, and boarding without physical documents.

The Zayed International Airport in Abu Dhabi is also working on a "Smart Travel" project that aims to implement biometric authentication and artificial intelligence at all security checkpoints by 2025. This system, integrated with the databases of the United Arab Emirates authorities, will allow travelers to be authenticated automatically.

Until official regulations are introduced for AI and biometric technologies in the hospitality sector, what solutions are available for accommodations aiming to comply with the law without sacrificing efficiency?

To help answer this question, we’ve prepared a brief guide containing the full text of the Ministry’s statement, our commentary, and actionable solutions.

Download it now!