National identification code CIN mandatory for all accommodation businesses from 2 November 2024

All accommodation businesses must register by 2 November 2024 on the website of the Ministry of Tourism and apply for the allocation of their own identification code, the so-called CIN („Codice Identificativo Nazionale“). The obligation goes back to the decree accompanying the Budget Law for 2024 (Law Decree No. 145/2023), by which the introduction of a uniform code was required, intended to standardise the local codes (CIR) already in use in several regions. On 3 September the corresponding obligation was published in the Official Gazette, and from that date accommodation businesses now have 60 days (in South Tyrol as well) in which to apply for the new identification code.

The intention is to provide a clear identification of accommodation businesses, and thus in particular also of short-term letters; the aim is in particular to subject the latter form of letting to closer control. Tax evasion is to be curbed and compliance with general rules is to be ensured.

Obligation:

The new code is required for the following categories of buildings and structures:

• Residential properties intended for letting to tourists
• Short-term letting of properties
• Accommodation businesses, such as hotel-type and non-hotel-type tourist accommodation businesses, structures for the letting of guest rooms and furnished holiday apartments as well as structures providing accommodation in the context of farm holidays.

Application:

In order to obtain the new national identification code (CIN) for a tourist facility, the website of the Ministry of Tourism must be accessed. Here is the address: bdsr.ministeroturismo.gov.it.Websitehttps://bdsr.ministeroturismo.gov.it/

Important: in order to be able to submit the application, one must have SPID or CIE access!

The following documents are required for the application:

• For persons not carrying on a business activity: a declaration containing the land register data of the property is required.
• For commercial activities: here, in addition to the documents containing the land register data, a certificate of compliance with the newly established safety requirements is necessary.

Use of the code:

For the time being, the CIN code does not have to be notified to the Chamber of Commerce or to other authorities, but it must be displayed visibly on the outside of the accommodation structures and properties used for short-term letting or for tourist purposes. The guidelines are as follows: the CIN code must be affixed visibly on the outside of the building, next to the name of the building to which it relates. This step is important in order to ensure an unambiguous identification and visibility of the property.

In addition, the code must be stated in every advertisement or communication - irrespective of where it is published. In particular, the code must be clearly visible in every listing appearing on OTA portals (such as Airbnb, Booking.com, Expedia) and on every website on which the property is advertised, including the website for direct bookings.

Safety rules:

The fire safety provisions for holiday apartments used for short-term letting have been amended. By the above-mentioned Law Decree No. 145/2023 and Conversion Law No. 191/2024, the fire safety rules and safety requirements for holiday apartments and short-term lettings were updated. In particular, the structures must be equipped with the following devices:

• Detectors for combustible gases, liquefied petroleum gas or methane gas, which should preferably be installed with a mains connection;
• Carbon monoxide detectors, which may also be battery-operated;

• Portable fire extinguishers, to be placed in easily accessible and visible locations, in particular near the entrances and near the areas of greatest danger. The rules provide for the installation of at least one portable fire extinguisher per 200 square metres of floor area or part thereof, whereby at least one fire extinguisher must be available on each storey. Among the various portable fire extinguishers, fire protection companies recommend a 6-litre hydraulic foam extinguisher which is approved for fire classes A and B and tested for class F fires in accordance with UNI 3/7:2008. This extinguisher is also suitable for use on live electrical equipment up to 1000 V at a distance of 1 m.

In addition to the installation, regular maintenance of the detectors is also required. Not mandatory, but advisable, is also the acquisition of a fire blanket.

Prevention and management of emergencies: it is important to inform guests about preventive measures. This also includes ensuring that the emergency telephone numbers are clearly communicated, so as to enable a successful rescue. In particular, where guests are restricted in their mobility, they should be instructed on the procedures for comprehensive emergency management.

Administrative penalties:

The administrative penalties for infringements of the provisions on the national identification code vary according to the type of infringement. If a facility advertises or lets a property without holding the CIN code, fines of between 800 euro and 8 000 euro may be imposed. If the CIN code is not displayed on the outside of the property or in online advertising on portals and websites, fines of between 500 euro and 5.000 euro may be imposed.

As regards the safety requirements, non-compliance with these rules may entail penalties of between 600 and 6 000 euro for each infringement established. The changes under Law Decree 145/2023 also include an amendment concerning the certified declaration of commencement of business activity (SCIA), in so far as the letting of rooms is carried on in the context of a commercial activity. Failure to notify the commencement of the activity to the Companies Register may be punished with penalties of between 200 and 10.000 euro.

In the coming weeks, further details on the forthcoming obligations will certainly be published, and we recommend that you follow developments closely.

According to initial communications from the Autonomous Province of Bolzano, it appears that the national rules described are applicable in South Tyrol without restrictions.