In-person check-in: meaning, regulations and self check-in
What it means, what the regulations require and how self check-in works
He in-person check-in represents a fundamental element in the management of Italian accommodation facilities. In recent years, however, this obligation has generated numerous doubts among hoteliers, B&B managers, guest house operators and sector professionals, especially regarding the spread of the online check-in and self check-in.
What does “de visu” really mean? Is the physical presence of the manager mandatory? Is it possible to recognise the guest remotely using digital tools?
Legislation and, above all, recent case law have helped to clarify these aspects.
What does check-in de visu mean?
The term “visually” it derives from Latin and literally means “with the eyes”, “visually”.
In the accommodation sector, the visual recognition it consists of verifying the guest's identity by checking that the person matches the identity document presented.
It is therefore not simply a matter of acquiring personal details or copying the document: the operator must be able to verify that the person accessing the facility actually matches the document presented.
This aspect assumes particular importance within the scope of the public security obligations laid down for accommodation facilities.
In-person check-in and Article 109 of the TULPS
The main regulatory reference is’Article 109 of the Consolidated Law on Public Security (TULPS).
The provision establishes the obligations regarding guest identification incumbent upon accommodation facility managers. In particular, the first paragraph stipulates that lodgings may be provided to persons possessing a suitable document to attest their identity.
Identity verification cannot therefore be reduced to the simple receipt or acquisition of the document.
The concept of visual identification indeed, it requires a check to verify that the document matches the person presenting themselves at the facility.
It is precisely this passage that has generated, in recent years, numerous questions regarding the use of digital technologies for the automated management of arrivals.
Online check-in and de visu recognition: what is the relationship?
The spread of check in online it has profoundly changed the way arrivals are managed.
Through a digital platform, the guest can in fact enter their details, transmit the requested information and, in certain systems, upload their identity document before reaching the property.
This procedure makes it possible to reduce waiting times, streamline staff tasks and automate numerous processes.
For a long time, however, a fundamental doubt remained: Can online check-in replace in-person verification?
The issue is particularly important for facilities that use systems of self check-in, automated access and digital receptions.
In fact, simply sending the data and the document does not necessarily equate to a visual verification of identity. The central point is to establish at what time and through what methods the correspondence between the person and the document must be ascertained.
The Ministry of the Interior Circular of 18 November 2024
The debate has further intensified with the Ministry of the Interior Circular of 18 November 2024, which has helped to fuel various interpretations among industry practitioners.
In particular, many operators considered that face-to-face identification could be carried out exclusively through the traditional method: the manager physically present on the premises who directly verifies the guest's face and identity document.
This interpretation seemed to create a contrast between public safety obligations and the digitalisation of reception processes.
Subsequent case law has nevertheless helped to outline a different picture.
The Council of State judgment no. 9101/2025
A particularly significant development for the accommodation sector is represented by judgment no. 9101/2025 of the Council of State, which addressed the issue of guest recognition and the methods by which the in-person check can be carried out.
The principle emerging from the ruling is particularly relevant for all facilities that use automated reception systems.
The obligation of recognition this does not necessarily have to be interpreted as requiring the manager's physical presence inside the facility.
What is relevant is the possibility of carrying out a actual visual check of the guest, including through technological tools that allow the operator to see the person and verify their identity.
In other words, Physical presence and visual presence do not necessarily coincide.
Can de visu recognition be carried out remotely?
Yes, according to the principle established by the ruling, recognition can also be carried out remotely, provided that the technology used allows an effective verification of the guest's identity.
The fundamental element is therefore not the location where the manager is situated, but the possibility of carrying out a suitable visual inspection to verify the correspondence between person and document.
Depending on the configuration of the facility and the solutions adopted, technological tools can be used such as:
- video intercoms;
- video calls;
- real-time visual control systems;
- digital access control devices;
- identification solutions integrated with the check-in process.
The use of technology must in any case be designed in a way that is consistent with the obligations laid down by regulations and with the specific characteristics of the facility.
The aim is to ensure that the identified person is the same one who actually enters the premises.
Digitisation and security can coexist
Regulatory and technological evolution demonstrates how digitisation and security are not necessarily in conflict.
On the contrary, if properly designed, digital systems can help make the reception process more efficient, traceable and secure, whilst at the same time reducing the operational burden on staff.
For hotels and accommodation providers, this means being able to automate a significant part of the check-in process without forgoing the obligation to identify guests.
The real issue, therefore, is no longer just “self check-in yes or no?”, but “How should a self check-in be designed to guarantee identification, security and regulatory compliance?”
In-person and technology check-in: the future of hospitality
The digital transformation of the hotel industry is driving more and more properties towards models of automated reception, online check-in and digital access.
In this scenario, in-person identification represents an element that must be integrated within the digital process and not necessarily an obstacle to its automation.
Indeed, technology can allow the operator to maintain control over guest identification even without being physically present at the reception desk.
The principle is simple: innovation and security can coexist when technology is used to guarantee, and not to circumvent, the obligations established by regulations.
For accommodation providers intending to adopt self check-in systems, it therefore becomes essential to choose solutions designed not only to improve the guest experience, but also to properly manage aspects related to identification, security and compliance.