The Spanish Confederation of Hotels and Tourist Accommodation (Cehat) has once again reiterated its opposition to Royal Decree 933/2021, on documentary registration obligations for reservations, which will be applied on 1 October, increasing its concern about “the chaos that its implementation would produce due to the impossibility of compliance”.
In a statement, the association has raised a series of concerns that are increasing due to the fact that there are only two weeks left before the entry into force of the last extension of Royal Decree 933/2021. Among them is the “competitive disadvantage” in the national and European market, as the obligations imposed by the regulation place Spanish companies or those operating in Spain at “a clear disadvantage” compared to competitors in other EU countries that do not have similar rules, according to the organisation.
“Currently, the technological infrastructure necessary to comply with registration and reporting obligations is not fully operational, which results in legal uncertainty, the impossibility of compliance and adds the likelihood of operational and reputational risks for the obligated parties,” the association stressed.
In the hoteliers’ opinion, the Royal Decree lacks the precision and clarity necessary to avoid legal loopholes, which “leads to legal uncertainty”. They also criticised the fact that the regulation ignores the operational complexities of the companies affected, which face difficulties in compiling the required data prior to the provision of services.
In addition, Cehat stressed that the new registration and identification requirements represent “an excessive administrative burden”, especially for small and medium-sized enterprises (SMEs), which constitute the core of the tourism sector (95% of businesses). “Implementing these requirements increases operational costs and management complexity, something that many companies cannot afford, facing not only the exposed operational and reputational risks, but also serious financial penalties for non-compliance,” the association concluded.
The association has yet again taken the matter up with the Ministries of Tourism and Interior, as well as the Directorate General of Police and the Civil Guard, demanding their review and adjustment to ensure proportionality and data minimisation, as well as a long period for technological adaptation and adaptation of the companies’ operating systems. If the modification does not take place, the hoteliers have warned of the impossibility of compliance and the loss of the reliability of the data currently available to the State Security Forces and Corps to prevent crime and terrorism.
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