Guest Registration in Catalonia & the Basque Country

Managing across several Spanish regions runs smoothly until one of the properties sits in Barcelona or Bilbao. At that point the setup you built to comply with Royal Decree 933/2021 stops working, and not because you configured anything wrong: that property’s guest report does not go where the rest of your portfolio’s reports go.

It isn’t an administrative oversight. It’s how public-safety competences are distributed in Spain, which in these two autonomous communities puts the regional police force where the Ministry would otherwise be.

Why Catalonia and the Basque Country do not use SES.HOSPEDAJES

RD 933/2021 recognises no territorial exceptions. Its Article 3 says so without qualification:

“The provisions of this royal decree shall apply throughout the national territory to lodging activities and to the rental of motor vehicles without a driver, whatever the modality, the legal personality of the operator or the organisational model.”

So what is divided up is not the scope of the duty: it is the authority that receives the report. The duty to tell the police who is staying predates the decree and belongs to public safety, an area where two autonomous communities have a fully integrated police force and their own competences.

Orden INT/1922/2003, which governed guest registers and entry forms before the decree and which RD 933/2021 itself keeps in force insofar as it does not contradict its content¹, put that recognition in writing:

“The provisions of this Order shall be without prejudice to the competences that, in this matter, are recognised to those Autonomous Communities holding competences for the protection of persons and property and for the maintenance of public safety.”

On that footing, each of the two communities legislated for itself:

• Catalonia: Orden IRP/418/2010. It requires accommodation establishments located in Catalonia to report their guests’ data to the Dirección General de la Policía, electronically and through the Mossos d’Esquadra website³.
• Basque Country: the Order of 25 November 2022, in force since 2 January 2023. It applies to any accommodation activity in Euskadi and channels registration and reporting to the Ertzaintza⁴.

Each rests on its region’s statute of autonomy. Catalonia’s assigns the Mossos d’Esquadra public safety across the whole Catalan territory⁵. Article 17.1 of the Statute of Gernika reserves to the Basque institutions the regime of the Autonomous Police “for the protection of persons and property and the maintenance of public order within the autonomous territory”⁶.

The consequence for you is concrete: the substantive obligation does not change (you collect the guest’s data and report it within 24 hours), but the recipient does. Your SES.HOSPEDAJES credentials open neither system.

SES.HOSPEDAJES, Mossos and Ertzaintza: what differs

The three channels ask for almost the same thing and differ in what you have to configure: who receives it, with which credentials, within which deadline and on which form. The deadlines come from Article 6.3 of RD 933/2021¹, Article 6 of Orden IRP/418/2010³ and Article 3.2 of the Basque Order⁴; the data, from their respective annexes.

The two rows that cause trouble are credentials and when the clock starts. A single procedure applied to the whole portfolio ends up either late in one territory or collecting surplus data in another.

Do I need to register guests with Mossos and SES.HOSPEDAJES?

You do not need to register guests with the Mossos and SES.HOSPEDAJES. None of the rules says so in those words. What they do establish is that public-safety competence is regional in both territories and that the state order applies without prejudice to it. Our reading is that reporting to the regional force satisfies the duty, rather than adding to the national channel.

The location of the property decides the channel. A flat in Barcelona reports to the Mossos, a flat in Bilbao to the Ertzaintza, a flat in Valencia to SES.HOSPEDAJES.

Galicia is the opposite case and worth keeping apart: there the Xunta adds a channel of its own on top of the national one, with quarterly occupancy reports through TURESPAZO as well as the guest report to SES.HOSPEDAJES. When the submission really does double, that is why, not because of the region. The detail is in TURESPAZO in Galicia.

Reporting to the Mossos d’Esquadra: access, data and deadline

Article 3 of Orden IRP/418/2010 names the entry point and the credentials:

“The reporting of the data shall be carried out through the aforementioned website, option Servicio y Registro de viajeros de establecimientos de hospedaje. To access this application it is necessary to hold the corresponding username and password.”

The option’s name is literal, so look for it exactly like that on the force’s website. And it is a username and password specific to that application: your SES.HOSPEDAJES lessor code will not do, because these are two separate enrolments with two separate administrations.

What travels is annex 2 of the Order³:

• Establishment: CIF or NIF, name, address, municipality and province.
• Each guest: document number and type, date of issue, first name, surnames, sex, date of birth, nationality and date of arrival at the establishment.

That is a shorter list than Annex I of RD 933/2021: Catalonia asks for no phone, no email, no habitual residence, no relationship to the accompanying adult when minors travel and no payment block. Mind the asymmetry, because it is not only a trim: the document’s date of issue is absent from the national annex and present in the Catalan one. If your check-in form mirrors Annex I, that field will be missing in Catalonia.

The deadline is set by Article 6:

“The information contained in annex 2 must be reported through the systems provided for in this Order within twenty-four hours following the start of each person’s stay.”

Note the starting point: the start of the stay, not the booking. Against the national double clock, the Catalan one starts only when the guest arrives, and the safe practice is still to report at check-in.

Reporting does not exhaust the duty. Article 2 also requires a register of your own: every guest is recorded with the mandatory information from the annex 1 model, which the Order calls “Registro de personas alojadas”. That register is kept for three years at the Mossos’ disposal and produced when they ask for it³. The unit is one sheet per stay, numbered consecutively. The force’s workflow still calls them “hojas de viajeros”, which is the same thing as the guest report.

A non-electronic route exists on paper and is exceptional. Article 4 opens it only where, for duly justified special reasons, you cannot use electronic means. You then hand in two copies of the document at Mossos premises, in person or by post, or fax it to the relevant police station³. It is not a channel you can pick for convenience.

The Catalan procedure field by field, with its daily workflow, is in the Mossos registre de viatgers.

Basque Country: how the Ertzaintza guest report works

The Basque rule is the Order of 25 November 2022 of the Vicelehendakari Primero y Consejero de Seguridad. It has been in force since 2 January 2023 and repealed the Order of 18 May 2012 that governed before it⁴.

It follows RD 933/2021 very closely, starting with its scope. It applies to “all accommodation activities carried out within the Autonomous Community of Euskadi, whatever the modality, the legal personality of the operator or the organisational model”⁴, word for word the formula of national Article 3. If you already comply with SES.HOSPEDAJES, you will recognise almost everything here except the recipient.

The circuit has two steps, not one:

1. Enrol the establishment before you start trading. Register it on the Basque Government’s electronic office with the identifying data listed in the Order’s annex.
2. Then report each stay. Guest and transaction data go to the Ertzaintza within the deadline of Article 3.2, which counts twice.

The way into the first step is the “Servicio de comunicaciones para establecimientos hoteleros” block on the Ertzaintza website, under activities relevant to public safety⁷. If any of those identifying details change later, Article 3.1 requires you to report them again⁴.

“This report shall be made immediately and, in any case, within a period not exceeding 24 hours, respectively, from the following moments: a) On making the booking or signing the contract or, where applicable, its cancellation. b) At the start of the contracted services.”

In other words: two reports per stay, not one. The booking (or its cancellation) opens its own 24-hour window and the arrival opens another. It is the same double trigger as Article 6.3 of RD 933/2021, and the practical difference from Catalonia.

Other rules of the Basque regime, spread across Articles 2, 3 and 4.2 of the Order⁴:

• Reporting is electronic. The exception is anyone carrying out accommodation activity non-professionally, who may report by non-electronic means.
• The computerised register is kept for three years at the Ertzaintza’s disposal. A non-professional operator is exempt from the register and from retention, and answers only for the reporting.
• Anyone over fourteen signs. The data of someone below that age is supplied by the adult accompanying them, exactly as in Article 4.2 of RD 933/2021.

The annex’s fields are close to national Annex I’s⁴:

• Each guest: name and surnames, sex, document number and type (DNI, pasaporte, TIE), the document’s support number, nationality, date of birth and place of habitual residence.
• Contact: landline, mobile and email.
• The party: number of guests and the relationship between them where one is a minor.
• The transaction: contract data, date and time of arrival and departure, property data and the full payment block.

Non-professional operators are asked for slightly less: the annex drops the document’s support number.

Who fines you in Catalonia and the Basque Country

The penalty regime is not devolved. It is still Ley Orgánica 4/2015 on the protection of public safety, the same rule and the same amounts as in the rest of Spain. What changes is who signs the decision:

“The corresponding authorities of the Autonomous Community shall be competent to impose the penalties defined in this Law within the scope of their competences in matters of public safety.”

Outside those two territories a serious or minor infringement is decided by the Delegado del Gobierno; in Catalonia and the Basque Country the file is handled and decided by the regional administration⁸. The two conducts that can reach you are the same across all three jurisdictions:

• Serious (Article 36.20): lacking the required registers or omitting mandatory reports. Fine of 601 to 30,000 euros.
• Minor (Article 37.9): irregularities in completing the registers, or reports filed outside the set deadline. Fine of 100 to 600 euros.

Between not reporting and reporting late there are two orders of magnitude, so a late submission is almost never the worst outcome. The grades within the serious fine and the graduation criteria are in the penalties for non-compliance with RD 933/2021.

Properties in several regions: one check-in, three channels

This is the reality for many agencies: one property in Madrid, another in Barcelona, another in Bilbao. Each address decides its own channel:

• Madrid and the rest of Spain: SES.HOSPEDAJES.
• Catalonia: Mossos d’Esquadra.
• Basque Country: Ertzaintza.

The data you collect from the guest is almost the same in all three, with Annex I of RD 933/2021 as the baseline. What multiplies is credentials, clocks and technical formats. The cleanest way to organise it:

1. Centralise check-in in a single tool, with the same form for the whole portfolio. Collect the superset of fields, including the document’s date of issue that the Catalan annex requires.
2. Split the submission by property. Those in SES.HOSPEDAJES territory go through that channel; those in Catalonia and the Basque Country are exported or entered into the regional system.
3. Match the deadline to each rule: in Catalonia the clock starts with the stay, in the rest of Spain and in the Basque Country it starts with the booking.
4. Document who reports what, with which credentials and from which account. That is the step that stops a property going unreported when the person on duty changes.

It is not an elegant circuit, but while each territory keeps its own system it is what holds duplication to a minimum.

What does RegistroViajero cover today?

Today RegistroViajero submits guest reports only to SES.HOSPEDAJES (Ministry of the Interior). We do not report to the Mossos d’Esquadra’s registre de viatgers or to the Ertzaintza’s system: both integrations are in development, with no committed public date.

What that means for your portfolio:

• If all your properties are in SES.HOSPEDAJES territory (Madrid, Andalusia, Valencia, Galicia, Castilla y León and the rest), we cover the guest report end to end.
• If any of them is in Catalonia or the Basque Country, that property falls outside and needs the region’s own procedure. There we cannot be your only solution.

The test applies to any provider, not just to us: covering all of Spain is three integrations, not one. If most of your portfolio sits in Catalonia or the Basque Country, an “all of Spain” promise only holds up with both regional integrations working.

Which channel applies when the OTA does not name the region

Another common doubt: if an OTA marks the accommodation as “Spain” without specifying the region, what happens?

Nothing. Neither order’s scope depends on the portal. The Catalan one applies to “all accommodation establishments located in Catalonia”³; the Basque one, to accommodation activities “carried out within the Autonomous Community of Euskadi”⁴. It is the property’s address, not the portal’s listing, that fixes the channel.

It works the same way in reverse: a booking taken through a Catalan portal for a flat in Seville is reported to SES.HOSPEDAJES.

Frequently asked questions

Can I use SES.HOSPEDAJES in Catalonia or the Basque Country? SES.HOSPEDAJES is not the valid system in Catalonia or the Basque Country. In Catalonia the report goes to the Mossos d’Esquadra through the force’s website, under the option “Servicio y Registro de viajeros de establecimientos de hospedaje”. In the Basque Country it goes to the Ertzaintza through the Basque Government’s electronic office. Your SES credentials do not work in either.

Do I have to send the guest report twice if the property is in Catalonia? You do not have to send the guest report twice. No rule says so in those words, but public-safety competence is regional in both territories and the state order applies without prejudice to it, so our reading is that reporting to the regional force satisfies the duty. The same holds for the Basque Country with the Ertzaintza.

What is the reporting deadline in Catalonia and the Basque Country? The deadline is 24 hours in both territories, although it does not start at the same moment. In Catalonia it is twenty-four hours from the start of each person’s stay, a single clock. In the Basque Country the report is immediate and, in any case, within 24 hours of the booking or the signing of the contract. A second 24-hour window runs from the start of the contracted services, so there are two clocks.

Who imposes the penalty if I fail to report? In Catalonia and the Basque Country the penalty is imposed by the regional administration, and in the rest of Spain by the central government, but all three apply the same Ley Orgánica 4/2015 on the protection of public safety. Lacking the registers or omitting reports is a serious infringement, 601 to 30,000 euros; irregularities and late filing are minor, 100 to 600 euros.

What if I let non-professionally in the Basque Country? If you let non-professionally in the Basque Country you are exempt from the computerised register and from retaining the information, but not from reporting the data, and you may report by non-electronic means. The duty to report stands.

What to read next if you manage several regions

• If your portfolio sits in SES.HOSPEDAJES territory and you want to automate the circuit, the step by step is in how to automate guest registration.
• For the national framework field by field, read what RD 933/2021 requires.
• For the Catalan procedure in detail, see the Mossos registre de viatgers.

This article is informational and does not replace legal advice. Procedures for the Mossos d’Esquadra and the Ertzaintza can change. Always cross-check with the official portals of the Department of Interior of the Generalitat of Catalonia and the Department of Security of the Basque Government. RegistroViajero is the product of the authors of this blog.