We’ve seen it before: regulations that can upend entire short-term rental markets. New York’s recent enforcement of stringent laws, France’s ‘anti-Airbnb’ law, Barcelona’s plans to phase out licenses, and Portugal’s dramatic caps on short-term rentals all signal a global shift. Now, Italy has made waves with a ban on self-check-ins.
But here’s the rub—it’s not a new law.
According to Marco Celani, CEO of Italianway and President of AIGAB (the Italian Association of Short-Term Rental Operators), this ban stems from a stricter interpretation of existing legislation. Circular 38138/2024 of the Ministry of Tourism, issued on November 18, 2024, redefines the enforcement of Article 109 of the Consolidated Text of Public Safety Laws (TULPS). This regulation, which already required guest identification, now deems self-check-in insufficient for meeting public safety standards.
What’s Changing?
Under the updated interpretation:
- Mandatory In-Person Identification: Every guest must be personally identified by the property manager upon arrival, or at the latest within 24 hours (6 hours for one-night stays).
- No Self-Check-Ins: While convenient, self-check-in methods like smart locks and key lockboxes no longer satisfy public safety requirements.
- Lockboxes and Overtourism: The use of lockboxes and similar devices is explicitly discouraged, described as ‘bypassing’ proper identification procedures. This aligns with broader efforts to address overtourism concerns, particularly in historic areas like Rome and Florence.
Non-compliance with the guest identification requirements (such as failing to conduct in-person identification or delayed reporting of guest data) can result in administrative and criminal penalties.
Why the Ban?
The Ministry of the Interior has cited “public order and safety risks” as the driving force behind this regulation. The directive aims to:
- Prevent properties from being occupied by individuals with criminal or terrorist ties.
- Address overtourism concerns in major cities like Rome, which faces immense pressure ahead of the 2025 Jubilee celebrations, expected to attract 30-35 million tourists.
- Enhance security while preserving Italy’s cultural and historic integrity.
However, critics argue that the operational burden falls squarely on property managers.
Immediate Implications for Property Managers
Increased Operational Costs
The most significant impact is financial:
- In-Person Check-Ins: Staff or contractors must be present for every guest arrival, creating logistical challenges for managers with multiple properties.
- Compliance Requirements: Hosts must verify guest identities and submit guest documentation to local authorities within 24 hours of check-in.
Large Operators Can Adapt, But at a Cost
Companies like Marco’s Italianway, with centralized operations and resources, can reorganize staff and adjust to the new requirements. However, this comes with increased operational expenses. As Marco points out, “This regulation forces us to rethink how we allocate resources, and the costs are significant.”
Small Operators Face an ‘Operational Ban’
For smaller operators managing scattered listings, the ban is effectively catastrophic. Many cannot afford to hire staff for in-person check-ins at multiple locations, leaving them little choice but to shut down or sell to larger players.
Guest Experience Challenges
Guests accustomed to seamless, tech-driven check-ins may find the in-person requirement inconvenient, potentially leading to lower satisfaction scores and repeat bookings. Managers will need to communicate clearly with guests to set expectations and mitigate frustrations.
Pressure on Growth
For larger property management companies (PMCs), the regulation could limit scalability. Adding new properties to a portfolio will require careful consideration of the increased resources needed to comply with the check-in requirements.
How the Ban Could Reshape the Market
This regulation could accelerate a shift in the makeup of the short-term rental industry, with significant implications for market diversity:
- Consolidation: Smaller operators who cannot afford the operational costs will likely exit the market. Their properties may be acquired by larger companies with the resources to comply, further consolidating the industry.
- Loss of Local Character: Smaller operators often bring unique, personalized touches to their listings, contributing to the local flavor of the short-term rental market. Their exit could lead to a more homogenized offering dominated by larger, standardized operators.
- Fewer Opportunities for New Entrants: Aspiring hosts or smaller companies looking to enter the market may find the barriers too high, reducing competition and innovation.
AIGAB’s Position and Advocacy Efforts
In its official statement, AIGAB opposes the directive for its failure to consider the technological advancements available to professional managers:
- Technological Parity: Tools like SPID (used for digital identity verification in Italy) and car rental platforms employ the same remote verification processes. AIGAB questions why the short-term rental industry is being singled out.
- Proactive Security: Professional managers already leverage robust systems to detect high-risk guests and notify authorities promptly.
- Discriminatory Impact: The directive targets compliant operators while allowing illegal players to operate unchecked.
AIGAB is advocating for:
- The acceptance of secure remote identity verification tools.
- Focused enforcement against non-compliant operators rather than blanket restrictions.
- A meeting with the Ministry of the Interior to demonstrate the industry’s capabilities in ensuring public safety.
Why Should Managers Outside Italy Care?
Italy is one of the world’s largest tourism markets, and regulatory changes here often signal broader trends.
- Operational Precedent: The directive highlights how operational mandates, not just outright bans, can disrupt entire markets.
- Overtourism Responses: Cities worldwide grappling with overtourism may take similar measures under the guise of public safety.
- Future-Proofing Operations: Understanding and preparing for these shifts is essential for professional managers everywhere.
What Actions Should Property Managers Take?
- Adapt Operations Immediately
- Hire additional staff or contract local services to manage in-person check-ins.
- Train teams on compliance procedures to streamline processes.
- Explore Alternative Solutions
- Advocate for video call check-ins or other secure, remote options.
- Leverage digital documentation tools to simplify guest reporting.
- Proactively Communicate with Guests
- Update property listings to reflect the new check-in process.
- Frame the changes positively by emphasizing enhanced security and personalized service.
- Join Industry Advocacy Efforts
- Collaborate with organizations like AIGAB to propose balanced regulatory adaptations.
- Highlight operational challenges and advocate for scalable solutions.
- Monitor and Prepare for Similar Trends
- Stay informed about regulatory developments in other key markets.
- Build operational flexibility to adapt to future changes.
The Bottom Line
Italy’s self-check-in ban is not just about compliance—it’s about survival for many operators. Large companies may adapt, but the regulation is poised to push smaller operators out of the market, reshaping its diversity and accessibility.
For professional managers, navigating this landscape requires adaptability, advocacy, and a commitment to innovation. By addressing these challenges head-on, property managers can turn obstacles into opportunities, ensuring the industry’s continued growth and evolution.
