Finance and compliance

We swapped two workers mid-stay: does the accommodation need their names?

Fan Zhang
·
October 21, 2026
·
5
min read
Short answer

Yes: in much of Europe the name on a crew booking is a legal record, because hosts in Spain and Italy must report every guest to the police within 24 hours and hotels in Germany must register foreign guests on the day they arrive. In Bonjour Residences data, 60% of crew stays were booked three days or less before check-in (58 of 97), and a full list of worker names was on file for only 39 of 141 stays. Bookers should treat the name list as part of the booking and every crew swap as a booking change, sent before the new worker reaches the door.

24hto report every guest to the police in Spain and Italy3 daysmedian time from booking to check-in for our crew stays (n=97)72%of our crew stays had no full list of worker names on file (102 of 141)3 monthsafter which a guest not registered in Germany must register with the local office

Monday, 7am. The site manager sends two welders home and two new ones are on a flight that lands tonight. The rooms are paid for, so nobody tells the accommodation. The new pair arrive at a flat booked in someone else's name.

In much of Europe that is a legal problem for the host, and it lands on the crew at the door.

Our argument: the name list is part of the booking, not admin you send later. A crew swap is a booking change. Bookers who treat it that way get the new worker through the door on the first night.

What do the rules actually require?

In Spain, Royal Decree 933/2021 makes hosts collect each guest's details and send them to the Interior Ministry within 24 hours of the booking and again within 24 hours of the stay starting. The details must match the identity document the guest shows, and the host keeps them for three years.

In Italy, Article 109 of the public security law makes hosts send each guest's details to the police through the Alloggiati Web system within 24 hours of arrival. Since 2018 this also covers lets of under 30 days. On 21 November 2025 the Council of State ruled that the host must check the guest's identity in person or by live video. A copy of a passport sent by message and a code for a key box is not enough.

In Germany, the Federal Registration Act says foreign guests in hotels and other commercial accommodation must sign a special registration form on the day they arrive and show a valid passport or ID card. German guests have not needed the form since 1 January 2025. Anyone who stays more than three months without a registered home in Germany must register with the local office within two weeks.

In Portugal, hotels and similar accommodation must report foreign guests electronically through the SIBA system.

CountryWho is registeredWhenWhat the host must check
SpainEvery guest, in hotels and tourist letsWithin 24 hours of the booking and within 24 hours of arrivalData must match the identity document shown
ItalyEvery guest, in hotels and lets under 30 daysWithin 24 hours of arrival (6 hours for stays of one night or less)Identity checked in person or by live video, not a copied document and a key box
GermanyForeign guests in hotels and other commercial accommodationRegistration form signed on the day of arrivalA valid passport or ID card; past 3 months, registration with the local office
PortugalForeign guestsReported electronically through the SIBA systemIdentity and travel document details

Aren't these rules being rolled back?

Not for now. In June the European Commission opened an infringement case against Spain, saying its traveller register collects too much data and keeps it too long. Spain has paused the follow-up order, but the decree is still in force and hosts must still report. In Italy the courts went the other way and confirmed the identity check.

What does our booking data show?

Crews are booked late, and names come last. Of 97 crew stays booked in our current system with a booking date recorded, 58 (60%) were booked three days or less before check-in. The median was three days.

A full list of worker names was on file for only 39 of 141 stays (28%). Where we had both a name list and a headcount (n=27), 13 lists named fewer people than were staying. On 89 stays we chased the booker for guest details before arrival, and 22 of those (25%) needed a second chase.

These rules touch a large share of our work: 49 of the 141 stays (35%) were in Germany, Spain, Italy or Portugal. And 25 of 141 (18%) ran past 90 nights, where the German three-month line starts to matter.

Bar charts: 58 of 97 crew stays were booked 0 to 3 days before check-in; a full list of worker names was on file for 39 of 141 stays
Source: Bonjour Residences BR OS booking data, 21 October 2026.

What goes wrong when names are missing?

The host cannot file the report before arrival, so check-in turns into a document check on the doorstep. In Italy, a self check-in with a key box is no longer an option without a live identity check, so a late-night arrival needs someone to answer a video call. If the name on the booking does not match the passport at the door, a careful host can refuse entry until the booking is corrected.

Swaps cause most of the trouble. For the host, a replacement worker is a new guest: a new report, a new identity check and, in Germany, a new form. The bed is the same, but the paperwork is not.

Two construction workers with holdalls wait in an apartment entrance hall while the host checks an ID card against a tablet
Illustrative image.

What should bookers do differently?

  • Send the name list with the booking, not the day before. Full names as they appear on the passport or ID card.
  • Treat every swap as a booking change. Tell the accommodation who leaves, who arrives and when, before the new worker travels.
  • Ask how identity is checked in Italy and Spain: in person, by video or at a reception desk, and at what times.
  • Tell workers to carry the document they were booked with. A different ID from the one on the list causes delays.
  • Watch the three-month line in Germany. For stays that may run longer, plan for registration with the local office.

Related: what goes wrong when the crew lands late on a Sunday, who pays for the empty bed when a worker goes off sick and why the property's registration number matters.

FAQ

Can we change the worker's name on a crew booking?

Usually yes, but the host needs the new name and identity details before the worker arrives so they can register them. Treat it as a booking change, not a message to the crew.

Do workers staying in Spain or Italy need to show ID at check-in?

Yes. Hosts in both countries must record each guest's identity details and report them to the police within 24 hours. In Italy the identity check must be in person or by live video.

Do workers staying in Germany for more than three months need to register?

Under the Federal Registration Act, a guest in commercial accommodation who has no registered home in Germany must register with the local office within two weeks once the stay passes three months.

Sources
  • Real Decreto 933/2021 (Spain), traveller registration obligations, Boletín Oficial del Estado, read 21 October 2026.
  • European Commission, June infringements package: letter of formal notice to Spain, INFR(2026)4005, June 2026.
  • Hosteltur, Registro de viajeros: Interior paraliza la orden, pero mantiene la norma, 26 June 2026.
  • Questura di Catanzaro, Polizia di Stato, Schedine alloggiati: servizio web per le strutture ricettive e per le locazioni inferiori a 30 giorni, read 21 October 2026.
  • Consiglio di Stato, Section III, judgment no. 9101 of 21 November 2025 (identity checks for short lets).
  • Bundesmeldegesetz, section 29, gesetze-im-internet.de, read 21 October 2026.
  • Landesbeauftragter für Datenschutz Mecklenburg-Vorpommern, Gästedaten sicher verarbeiten (guidance for accommodation providers), read 21 October 2026.
  • Sistema de Informação de Boletins de Alojamento (SIBA), siba.ssi.gov.pt, read 21 October 2026.
  • Bonjour Residences, BR OS booking data, 21 October 2026 (141 non-cancelled stays in our current system; booking date on 97). Anonymised aggregate, no client names or rates.
Last reviewed
October 21, 2026

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