With the ruling of 21 November 2025 , the Council of State accepted the appeal of the Ministry of the Interior , restoring the validity of the circular of the Chief of Police of 18 November 2024 .
The decision reaffirms the obligation, set forth in Article 109 of the TULPS , for all managers of accommodation facilities , including short-term rentals , to identify guests in person (de visu) and to communicate their data to the competent Police Headquarters according to the methods established by the Ministerial Decree of 16 September 2021 .
Therefore, entirely remote check-in procedures that are limited to collecting documents and sending access codes are not permitted, as they do not guarantee that the document actually corresponds to the person staying.
The Council of State only allows remote identification , provided that:
- occurs upon entry ,
- whether actually de visu ,
- use suitable video connection tools (for example digital peepholes or systems that allow a still image),
- allows you to verify the correspondence between guest and document in real time.
Visual inspection therefore remains essential and cannot be replaced by simple automated procedures.
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