With judgment no. 10210/2025, published yesterday, May 27, the Administrative Court of Rome (TAR Roma) annulled the contested Circular issued by the Ministry of the Interior, which required managers of non-hotel accommodation facilities to identify guests “in person.”

The Court upheld the appeal filed by the Federation of Non-Hotel Accommodation Associations (F.A.R.E.), represented by a legal team from Ughi e Nunziante, led by partner Andrea Marega and composed of Emily Maxwell, Tiziana Fiorella, Francesco De Filippis and Giorgia Diotallevi. The Court found the measure to be unlawful on several grounds.

At the heart of the case was the interpretation of Article 109 of the TULPS (Consolidated Law on Public Security), which was amended in 2011 to simplify the obligations for operators. According to the TAR, the Circular issued in November 2024 had effectively reintroduced an in-person identification requirement that had already been repealed, disregarding the reform and placing an unnecessary burden on the sector.

The panel also emphasized that in-person identification does not provide greater security than remote check-in and criticized the lack of concrete data supporting the measure. “There is no evidence,” the ruling states, “to show why remote identification would not be equally effective.”

With this decision, the TAR reaffirms a key principle: administrative measures must be proportionate, well-grounded, and compliant with the current legal framework. In the meantime, digital check-in is reinstated for non-hotel hosts — and they can breathe a sigh of relief.