Reserva de hospedaje or parte de viajeros in SES.HOSPEDAJES

You open SES.HOSPEDAJES, Spain’s guest registration portal, reach the “Alta comunicación” screen, and the system presents a choice: parte de viajeros or reserva de hospedaje. No screen explains the difference, and the doubt is so common that the comparison is one of the most searched questions about the portal.

Picking the wrong one is not a cosmetic slip. Each type has its own trigger and its own 24-hour clock, so filing a booking where a traveller report was due leaves the other communication undone, and a missing communication is not treated like a late one: the first is a serious infringement, the second a minor one.

The people who run into this most are managers working from platform bookings, because there the contract closes weeks or months before the guest sets foot in the property, and because the sales channel changes who has to report what. So here is the detail, for anyone running a rental in Spain: where the two communications come from, what each one carries, who files them when the booking arrives through a platform, and what to do about cancellations, changes and walk-ins.

What RD 933/2021 says: two triggers, two 24-hour deadlines

Royal Decree 933/2021 never uses these two names, which belong to the portal, but it does define the two data blocks in its Annex I: item 3, “traveller data”, and item 4, “transaction data”¹. And its article 6.3 sets when each is reported, in wording worth reading literally:

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

Two different triggers, each with its own 24-hour clock:

The contract-holder nuance sits in the portal’s own mechanics: in batch uploads, a booking communication carries the person with the contract holder role, while a traveller report carries all travellers³. Which makes sense: when someone books in March for August, you do not yet know who will come, but you do know who contracted, the dates and the payment. The people’s data arrives later, at check-in.

On the signature it is worth going to the letter: article 4.2 says entry reports “deberán ser firmados por toda persona mayor de catorce años”, that is, by anyone over fourteen, and that for those under fourteen the data is supplied by the adult they travel with⁴. The text does not expressly settle the case of someone who is exactly fourteen, so the prudent course is to collect their signature too.

What data the reserva de hospedaje carries under Annex I

The fields in Annex I item 4, “transaction data”, surprise almost everyone the first time, because three of them have nothing to do with payment¹:

• Contract data: reference number, date and signatures.
• Contract execution data: date and time of arrival, date and time of departure.
• Property data: full address, number of rooms and internet connection (yes/no).
• Payment data: type (cash, card, payment platform, transfer), identification of the payment method (card type and number, IBAN, mobile payment), the payment method holder, the card expiry date and the payment date.

Under the non-professional regime the Annex puts the number of rooms and the internet connection among the property data, outside the transaction block¹. Either way these are property details you declare once, and they do not change from one booking to the next.

Cancellations and changes are reported to SES.HOSPEDAJES too

Two cases almost nobody has on the radar, both in the rule:

• Cancellations. Article 6.3 says it expressly: the communication is due upon the booking “or, where applicable, its cancellation”². A cancelled reservation generates its own communication.
• Modifications. The Interior Ministry’s official FAQ is equally clear: “the modification of any of the data gives rise to the obligation of a new communication”⁵. Date change, headcount change, payment method change: new communication.

If that sounds like a lot of administrative traffic per booking, it is. A normal stay with one mid-course change means three or four communications: the booking, perhaps its correction, the traveller report at arrival, and the cancellation or correction of the report if something went wrong. On a platform sale the first two do not come from your account, but from the platform’s.

Walk-ins with no booking: which communication is due?

A guest arriving without a booking does not exempt you from the first communication: the legal trigger is “the reservation or the formalisation of the contract”, and a walk-in formalises the contract at the counter. In practice both clocks start almost together: you report the transaction and, with the start of the stay, the traveller report.

Who must report: lodgings, tour operators and platforms

The list of obliged subjects is broader than most people assume, and that breadth is the key to everything below. Article 2.1 of RD 933/2021 folds into the definition of lodging activity, alongside hotels, apartments, campsites and rural houses, both the tour operators that intermediate and “digital platforms dedicated, for payment or free of charge, to intermediation in these activities over the internet, whether or not they provide the underlying service being mediated, provided they offer services in Spain”. Article 2.3 closes the loop: obliged subjects are the natural or legal persons who carry out “or intermediate in” those activities⁶.

Booking and Airbnb, then, are not outsiders to the decree who hand you a reservation and walk away. They are obliged subjects just as you are, with communications of their own to file.

Partial relief for the non-professional host: the decree exempts them from the three-year documentary register, though not from the communications⁷. And non-compliance costs the same for everyone: omitting mandatory communications is a serious infringement (601 to 30,000 euros); filing them late, a minor one (100 to 600).

Who files the booking report for a Booking or Airbnb sale?

The platform being an obliged subject is what splits the work between the two communications. The Interior Ministry’s official FAQ sets the criterion in two parts, and they are worth telling apart because usually only the second gets quoted: the general rule is that “each of the subjects must transmit the information it holds and which it is obliged to report under the Royal Decree”, and only when “several intermediary entities participate in the commercial relationship” is the tie-breaker needed, which assigns the report to whoever “holds a direct and final contractual relationship with the client”⁵.

Applied to a platform sale, the general rule settles itself, because each communication asks for data that sits in a different place. The contract data (reference, dates, amount, payment method) is held by the platform, which generated the booking and took the money. The traveller data does not exist in any system until the people check in with you. Hence the split: the booking communication falls to whoever took the reservation, and the traveller report is always the lodging’s, as the only party that identifies who sleeps there.

In practice:

• Direct sale (your site, phone, email, walk-in): both communications are yours.
• Platform sale: the traveller report is yours; the booking communication falls to the platform, and so do its cancellations and modifications.
• Mixed channels, which is the normal case: the split is decided booking by booking, not once for the whole property. If you sell through Booking and also through your own site, you keep filing booking communications for the ones that come through your site.

One caveat on how far this goes: the criterion splits the obligation, it does not give you a way to check that the other party met it. In Hospedajes you see your own communications, not the intermediary’s, so the portal will not confirm for you that the booking report for a Booking sale went out.

Frequently asked questions

Do I have to send both communications for every stay? Sending both communications for every stay depends on the channel the booking came through. On a direct sale you send both: the booking communication when the contract is made, and the traveller report when the stay begins. If the booking comes through a platform, you send only the traveller report.

Who files the booking report for a sale through Booking or Airbnb? The booking report for a sale through Booking or Airbnb is filed by the platform, which is an obliged subject under article 2 of RD 933/2021 and holds the contract and payment data. You file the traveller report at the start of the stay, because the traveller data exists only in your check-in.

Does the booking communication identify all guests? No, the booking communication does not identify all guests: it carries the contract and holder data. Every traveller’s identity goes in the traveller report, at the start of the stay.

What if the guest cancels? If the guest cancels, the cancellation is reported too: it is in article 6.3 of Royal Decree 933/2021.

What if dates or headcount change? If dates or headcount change, a new communication is due: any modification of reported data obliges one, per the ministry’s official FAQ.

Does a walk-in need the booking communication? Yes, a walk-in needs the booking communication all the same, because the contract is formalised on arrival: that moment triggers the transaction communication, and the start of the stay triggers the traveller report.

Where is each one in the portal? In the portal, both communications start from the same place: on the “Alta comunicación” screen, the “Seleccione un tipo de comunicación” dropdown offers “Parte de viajeros” and “Reserva de hospedaje”. The full portal walkthrough is in our step-by-step guide.

Booking and traveller report, step by step in one stay

The complete picture of one stay at a Spanish rental:

1. The booking lands. If it is direct (your site, phone, walk-in), you file the booking communication within 24 hours. If it comes through Booking or Airbnb, that one falls to the platform.
2. Something changes or it cancels: new communication, from whoever filed the booking.
3. The guest arrives: traveller report with every occupant, within 24 hours of arrival. Anyone over fourteen signs their own entry report, under article 4.2 of Royal Decree 933/2021⁴; for children under fourteen, the data comes from the adult they are travelling with.
4. You made a mistake: cancel and resend the affected report.

Doing this by hand means entering the portal several times per booking and choosing the right communication type every time. It is exactly the routine worth delegating to software: RegistroViajero takes bookings from your iCal calendars, collects traveller data through digital check-in and files the traveller report within its deadline, automatically. You choose the property and little else.

This article is informational and is not legal advice. Portal menu names may change between versions; deadlines and obligations cited are those of the current text of Royal Decree 933/2021.