Overview
- The European Commission sent a formal letter of notice to Spain on Thursday that begins an infringement procedure over Real Decreto 933/2021 and gives Madrid two months to answer or face further steps.
- Brussels sets out three legal objections: the list of required data is disproportionate because it includes payment and geolocation details, police access is not restricted to specific purposes, and a three‑year retention period is excessive.
- The contested rule, implemented through the ses.hospedajes app with a sub‑24‑hour upload requirement, centralises traveller records that the Interior Ministry says include 13 mandatory fields while the sector warns of up to 42 data items.
- Hotel and travel trade groups have long argued the registry creates heavy operational burdens, duplicates data collection and exposes firms to security risks by forcing them to hold sensitive card and location information.
- If Spain's response does not satisfy the Commission, Brussels can issue a reasoned opinion and ultimately refer the case to the Court of Justice of the European Union, a move that could force changes to the rule and affect tourism SMEs' compliance costs.