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 is what orders those two items to be transmitted and sets when, 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.”

Royal Decree 933/2021, Article 6.3²

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

	Booking communication (reserva de hospedaje)	Traveller report (parte de viajeros)
What it reports	The contract: reference and date, arrival and departure, property and payment details	The people: each traveller’s full identity
When it is sent	When the booking or contract is made (and also when cancelled)	At the start of the stay
Deadline	Immediately, at most 24 hours from the booking	Immediately, at most 24 hours from arrival
Who it identifies	Only the contract holder	Every traveller; anyone over fourteen signs their own entry report
Who files it	The lodging on a direct sale; the platform when the booking comes through it	Always the lodging

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.

That data is Annex I item 3, “traveller data”¹:

Identity: name, first surname, second surname, sex, date of birth and nationality.
Document: type (DNI, passport, TIE), document number and support number.
Habitual residence: full address, town and country.
Contact: landline, mobile and email.
Group: number of travellers and the family relationship between them when any of them is a minor.

Under the non-professional regime the list is the same except for the document support number, which the Annex asks for only in professional practice¹.

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 two sentences split the group at the same point: someone who has turned fourteen is no longer “menor de catorce”, so they sign for themselves from the day of the birthday, and there is no in-between band calling for both signatures. Which document each age needs, and what relationship has to be declared, is in minors on the guest report.

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 in question 26, which asks precisely about a change to booking data: “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 defines lodging activity as providing, “for a price, consideration or compensation, a room or space for overnight stay”, professionally or not, and lists four groups that are included “in any event”⁶:

Commercial establishments open to the public in the sector: hotels, hostels, guesthouses, boarding houses, rural tourism establishments and the like.
Campsites and motorhome parking areas, apartments, bungalows and other similar tourist accommodation.
Tour operators that intermediate between lodging businesses and consumers.
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 with a one-line definition:

“Obliged subjects: the natural or legal persons who carry out or intermediate in the performance of the activities described.”

Royal Decree 933/2021, Article 2.3⁶

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.

Non-compliance also 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)⁵.

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 poses the exact case, a property advertised and rented through an intermediary such as a web platform, and answers it in question 10:

“Each of the subjects must transmit the information it holds and which it is obliged to report under the Royal Decree, although when several intermediary entities participate in the commercial relationship, the subject obliged to report the data is the one that holds a direct and final contractual relationship with the client.”

Ministry of the Interior FAQ, question 10⁵

The answer has two parts, and they are worth telling apart because usually only the second gets quoted: the general rule is that each subject transmits the information it holds and is obliged to report; the tie-breaker, the direct and final contractual relationship with the client, comes into play only when several intermediary entities take part.

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.

The three-year register and the non-professional exemption

Reporting is not the whole decree. On top of transmitting, article 5 requires obliged subjects to keep a registro informático, a computerised register holding the Annex data, and its paragraph 3 says how long for:

“Los datos del registro informático deberán conservarse durante un plazo de tres años a contar desde la finalización del servicio o prestación contratada.”

Real Decreto 933/2021, article 5.3⁷

The data must be kept for three years counted from the end of the contracted service, not from the date the communication went out. On a long stay, or one that gets extended, the gap between those two dates is not trivial.

The next paragraph takes the non-professional host out of all of it:

“Los sujetos obligados que desarrollen actividades de hospedaje de manera no profesional quedan exceptuados de las obligaciones de registro documental y conservación de datos previstos en este artículo, y solo estarán sujetos a las obligaciones de comunicación previstas en el artículo siguiente.”

Real Decreto 933/2021, article 5.4⁷

Non-professional hosts are exempt from the documentary register and the data retention of that article, and remain bound only by the reporting duties of the following article. Read what that exempts carefully. They keep no register and hold nothing for three years, but they still file everything article 6 requires: the booking communication on their direct sales and the traveller report on every arrival, to the same deadlines. It is an exemption from filing away, not from filing.

What article 6.4 adds for them is a route of their own. The decree’s communications are made by electronic means, and non-professional subjects are excepted from that rule: they “podrán realizarlas por medios no telemáticos, por el procedimiento que se determine”, they may make them by non-electronic means, under whatever procedure is laid down².

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.

How long must the reported data be kept? The reported data must be kept for three years, counted from the end of the contracted service and not from the date the communication went out: article 5.3 of RD 933/2021 sets that period for the computerised register the same article requires. Anyone running lodging activity non-professionally is exempt from that register and that retention under article 5.4, and stays bound only by the duty to 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:

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.
Something changes or it cancels: new communication, from whoever filed the booking.
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.
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.