The introduction of the National Identification Code (CIN) for short-term lettings in Italy aims to standardise and integrate existing regional codes, such as the CIR Code (Regional Identification Code).
The CIN is issued by the Ministry of Tourism through an automated process, at the owner’s request of the property, who must provide the land registry details and guarantee the safety requirements of the building.
Operators, too They may apply for the code with the owner’s authorisation. The application must be submitted via the Ministry of Tourism’s official portal, within the Accommodation Facilities Database, and the code will become mandatory from 3 September 2024.
The CIN is required for all accommodation facilities intended for tourist use, whether hotels or other types of accommodation, and whether operated on a commercial or non-commercial basis. This includes holiday homes (CAV) and holiday flats.
It will be It is compulsory to display the code outside of the building in all online adverts, on platforms such as Airbnb, Booking.com and other websites. The CIN trial began on 3 June 2024 in six Italian regions (Puglia, Veneto, Abruzzo, Lombardy, Marche and Calabria) and was completed on 3 September 2024, making the code mandatory nationwide.
The Decree-Law No. 145 of 18 December 2023 It has introduced new regulations for short-term lettings, including a tax rate of 26% for those managing more than one property, the application of stricter safety standards and the requirement to use the CIN code, with penalties for non-compliance.
This article is aimed at owners, operators and property managers of short-let properties, offering guidance on the timelines and implications of the CIN requirement. It will explain the importance of the code, how to obtain it and the new regulations that must be complied with, including the penalties for non-compliance.
What is the CIN code?
The National Identification Code (CIN) is a a unique alphanumeric code assigned to all properties used for tourism purposes in Italy. This includes both short-term lettings and accommodation facilities such as hotels, bed and breakfasts, hostels, farm stays and guesthouses. The CIN is issued by the Ministry of Tourism at the request of the property owner, or of an authorised operator acting on their behalf. The main innovation introduced by the CIN is the creation a National Database, which compiles all information relating to the facilities accommodation providers. The aim is to improve traceability and oversight, facilitating more transparent and efficient management of the tourism sector and short-term lettings. This system enables better monitoring of compliance with regulations and ensures greater transparency for consumers and the authorities.
What is the structure of the CIN code?
The National Identification Code (CIN) is an alphanumeric code structured to provide detailed information about the property and ensure its unique identification. Each part of the code has a specific meaning: – Ministry Recoding Code: a specific code assigned by the Ministry of Tourism to identify the origin of the CIN. – ISTAT code for the province: Indicate the province in which the property is situated, using the ISTAT code system that identifies each Italian province. – ISTAT code for the municipality: represents the municipality in which the property is situated, based on the ISTAT code assigned to each Italian municipality. – ISTAT Classification Code: defines the type and classification of the accommodation facility in accordance with ISTAT criteria. – Random alphanumeric sequence: a random sequence of letters and numbers, designed to ensure that every CIN is unique and cannot be duplicated. A practical example of a CIN code might be IT 039 007 B1 ooooo, where each section of the code provides detailed information about the property intended for tourist use. This structure ensures clear identification and facilitates the monitoring of accommodation facilities in Italy.
Mandatory use of the CIN code
The CIN code is compulsory from 3 September 2024. From that point onwards, all accommodation providers, whether hotels or other types of accommodation, will have 60 days to comply with the new regulations. As indicated by the Ministry of Tourism, the requirement comes into force upon publication of the official notice in the Official Gazette, which confirmed the launch of the Accommodation Establishments Database (BDSR) and the online portal for the allocation of the CIN. This notice was published on 3 September 2024, the date from which owners and operators of accommodation establishments will be required to obtain and display the code.
Entry into force of the CIN Code
The National Identification Code (CIN) for short-term lettings came into force on 3 September 2024, as officially announced by the Ministry of Tourism in the Official Gazette.
Here is a summary of the steps that led to its adoption
In April 2024, the Ministry of Tourism, in collaboration with the regions, set out the procedures for issuing the CIN code and ensuring interoperability between the various institutions.
From 3 June 2024, a pilot phase was launched in the Puglia region, where all facilities, including those with the previous CIS code (Facility Identification Code), were required to obtain the new CIN code. This pilot scheme was subsequently extended to the Autonomous Regions and, finally, to all other Italian regions.
According to the Ministry, the CIN is set to become mandatory throughout the country by September 2024, once the trial phase has concluded and the Accommodation Facilities Database (BDSR) has been launched.
From the date of entry into force, all owners of properties intended for short-term lets are required to register with the national database and obtain a CIN code.
This code must be displayed prominently on the outside of the property and included in all adverts published online and on booking websites. The regulatory update also includes new safety provisions for short-term lettings, which will come into force in 2024.
Who is required to have a CIN code?
The National Identification Code (CIN) is compulsory for the following types of properties and buildings:
- Accommodation units used for tourist rentals;
- Properties intended for short-term lettings;
- Tourist accommodation facilities, including both hotels and non-hotel accommodation.
How to obtain a CIN
To obtain the National Identification Code (CIN), you must follow an online procedure via the Ministry of Tourism’s official portal. The steps and requirements are set out below:
1. Online enquiry: The owner of the accommodation must submit the application via the Ministry of Tourism’s official website. The procedure is fully automated and requires login using digital credentials, such as SPID (Public Digital Identity System) or an Electronic Identity Card (CIE).
2. Required documentation: It is compulsory to provide the property’s land registry details and to attach a declaration or self-certification confirming that the property complies with the safety requirements laid down by current legislation.
3. ATECO code for business activities: Organisations operating as businesses must state their ATECO code, which classifies the economic activity they carry out.
4. Non-business activities: If the activity is carried out on a private, non-commercial basis, without a VAT number, you may select the ‘not applicable’ option in the section relating to the ATECO code.
5. New facilities: For newly opened establishments, it is necessary to complete the registration at regional level, where required, before applying for the CIN code.
In summary, The owner or operator of the accommodation facility, whether a hotel or non-hotel accommodation, must submit a specific application to the Ministry of Tourism via the BDSR (Accommodation Facilities Database) portal. The documentation to be provided varies depending on whether the activity is of a private or business nature, but in all cases it is essential to ensure compliance with the safety requirements laid down by law.
Can a fund manager request the CIN code?
Yes, it is possible. If you are a property manager, you can apply for a National Identification Code (CIN) even if you are not the owner of the property. However, you must have a official authorisation from the account holder from the property owner, authorising you to apply for the CIN and to ensure compliance with safety regulations, such as the presence of fire extinguishers and carbon monoxide and gas detectors.
Once you have obtained the authorisation, you can follow the procedure set out on the Ministry of Tourism’s website to complete your application.
How and where should the CIN code be displayed?
The CIN code must not be disclosed, but complaint. Landlords are required by national law to display the CIN both outside the property and in online adverts. The guidelines are as follows:
– Outside the building: The CIN code must be clearly displayed on the outside of the building, next to the name of the property to which it refers, to ensure that the building is correctly identified.
– In online adverts: The CIN code must be included in all listings published on OTA platforms (such as Airbnb, Booking.com and Expedia) and on any other website where the property is promoted, including direct booking sites. This ensures transparency and legal compliance during the online search and booking process.
Safety requirements for short-term lettings in 2024: new obligations
New safety requirements have been introduced as part of the new regulations on short-term lettings, whether managed on a commercial basis or not. In particular, anyone managing short-term lettings, regardless of their legal status, must comply with the following obligations:
– Gas and carbon monoxide detectors: It is compulsory to install fully functional devices to prevent risks associated with gas and carbon monoxide leaks.
– Fire extinguishers that are visible and accessible: Fire extinguishers must be provided in key areas of the building, with at least one per floor and one for every 200 square metres of floor area.
Under Article 13-ter of Law 191 of 2023, These requirements apply not only to business activities, but also to private lettings. Consequently, private owners who let out their properties on a short-term basis must also bring their properties into line with the required safety regulations, with the exception of certifications for technical installations.
