Self check-in, key boxes and smart locks: is it legal to hand over keys without seeing the guest? (Spain, Portugal, Italy and Greece, 2026)

Updated: 9 November 2026

Self check-in saves time and guests like it. But the rules differ by country. We read the Italian ruling, the Spanish royal decree, the SIBA manual and official Airbnb and Booking.com pages (links at the end). Where we could not confirm something we say so. This is not legal advice: check with your adviser.

Italy: you must identify the guest

Official summary of Council of State ruling 9101 (21-11-2025):

Art. 109 TULPS requires the manager to check the guest matches the ID document, at least the photo.
The data are then sent to the Questura (police).
Remote-only check-in is not enough.
A video system at the entrance is allowed if it lets you check in real time that the guest is the document holder.
Examples given: a digital door viewer or a QR code that creates a still image of the document.
According to the press, this ruling overturned the May 2025 TAR Lazio ruling that had annulled the Interior Ministry circular of 18-11-2024. We have not read the full text.

Spain: what Royal Decree 933/2021 says

We read the consolidated text in the BOE:

Every guest over 14 signs the check-in form.
ID documents must be «shown or provided» by the guest.
You are responsible for the data matching the documents.
The decree does not literally say you must see the guest in person.
You send the data immediately and within 24 hours at most, electronically.
We could not open the Interior Ministry's SES.HOSPEDAJES FAQ.

Key boxes on the street

We found no official Spanish municipal by-laws banning them. Ask your town hall before fixing one to a façade or lamp post.

Portugal: SIBA

Foreign guests are reported electronically via SIBA. This includes local accommodation (alojamento local).
The official manual forbids registering a guest before arrival.
It does not mention in-person checks or deadlines. We have not confirmed them.

Greece

We found no official rule on self check-in or in-person identification. Ask your accountant or adviser.

Airbnb and Booking.com

Airbnb lists three methods: smart lock, keypad and lockbox.
It recommends a unique code per booking. Guests get instructions 24-48 hours before.
Its page does not mention local laws: the platform does not exempt you from them.
Booking.com lets you set a primary and an alternative check-in method.

Good practice

Collect documents before arrival, but verify identity as your country's rules require.
In Italy, if you are not there, use a real-time video system.
Change the code for every stay.
Explain the arrival method before booking.

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Frequently asked questions

Can I use a key box in Italy?

A key box alone, without identifying the guest, is not enough according to the Council of State (9101/2025). Real-time video at the entrance is allowed.

Does Royal Decree 933/2021 require me to see the guest?

It does not say so literally. It requires documents shown or provided, a signed form and reporting within 24 hours.

Does Airbnb allow self check-in?

Yes: smart lock, keypad or lockbox, with a unique code per booking. Local laws still apply.

Sources

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