A Regulated Market: Why Identification Codes Are No Longer Optional
Anyone who owns an apartment in Genoa and is considering renting it for tourism purposes now faces a regulatory framework that has changed substantially over the past three years. This is not merely a matter of bureaucracy: identification codes have become the technical prerequisite for publishing any listing on Airbnb, Booking.com or any other platform. Without them, the listing is not published — or it is removed.
At the national level, the CIN (Codice Identificativo Nazionale) is assigned by the Ministry of Tourism and serves to display the property in listings and to track it in the National Database of Tourist Accommodation Facilities (BDSR). As of January 2025, the CIN is mandatory throughout Italy, while the CIR — the regional code — remains required in many regions as a preliminary step.
In Liguria, however, the nomenclature differs from other Italian regions, and this often creates confusion among property owners. In Liguria there are two distinct codes: the CITRA (Codice Identificativo Turistico Regionale per gli Appartamenti Ammobiliati) for short-term rentals, and the CITR (Codice Identificativo Turistico Regionale) for classified accommodation facilities. Understanding the difference between the two is the first step to determining which path to follow.
The Ligurian Regulatory Framework: AAUT, CAV and Their Identification Codes
Before discussing codes and procedures, it is necessary to clarify a fundamental distinction that Ligurian regional law makes with precision. This is the difference between two types of activities that are radically different in terms of obligations, costs and bureaucratic complexity.
AAUT: Furnished Apartments for Tourist Use
Article 29 of Regional Law 1/2024 defines furnished apartments for tourist use (AAUT) as residential real estate units intended for short-term rental contracts for tourism purposes or short-term rental contracts. This is the category in which the vast majority of private Genoese property owners who rent their apartment on platforms such as Airbnb fall.
Holiday homes (CAV) are extra-hotel accommodation facilities and require SCIA, a VAT number and classification. Furnished apartments for tourist use (AAUT), on the other hand, are not tourist accommodation facilities: they can be managed without a VAT number (within the limit of three units) and do not require classification.
Another relevant constraint for those operating as AAUT in Liguria concerns contract duration. In the Liguria Region, no more than three apartments can be intended for tourism purposes, always respecting the 30-day duration limit. The Liguria Region does not allow the possibility of renting your property for tourism purposes for a period longer than 30 days. To do so, it is necessary to create an extra-hotel accommodation facility, such as holiday homes and apartments or guesthouses, with which it is also possible to offer additional related services.
CAV: Holiday Homes and Apartments
“Holiday homes and apartments” are residential real estate units located in existing buildings, each consisting of one or more rooms, furnished and equipped with independent bathrooms and kitchen, managed as a single unit. For CAV, the registration path is more complex: SCIA submission to the SUAP of the Municipality of Genoa is required, registration in the Regional Database through the RIMOVCLI system (and not Ross1000), and — depending on the volume of activity — opening a VAT number. For CAV, the law establishes that the SCIA takes effect immediately: you can start the activity on the same day as submission.
National law has introduced an additional level: according to art. 13-ter, paragraph 8 of Decree Law no. 145/2023, anyone who offers properties for tourist use or short-term rentals in a professional manner, directly or through intermediaries, must submit the SCIA to the SUAP (Single Desk for Business Activities) of the relevant Municipality. In Genoa, SUAP applications are submitted exclusively in telematic form.
Step-by-Step Path: From Ross1000 to National CIN
For those managing an AAUT in Genoa (the most common situation among private owners), the process of bringing things into compliance is divided into two distinct and sequential phases: first the regional CITRA code through Ross1000, then the national CIN on the Ministry of Tourism’s BDSR. The order cannot be reversed: the Ministry of Tourism’s database of accommodation facilities can only be used by those who have already obtained the regional or provincial identification code, based on the rules established in their territory.
Phase 1 – The CITRA on Ross1000
Ross1000 Liguria is the regional platform used for furnished apartments for tourist use (AAUT). It is used to notify new tourist rentals, request the CITRA code, manage property data, report tourist flows and send any terminations.
The concrete procedure is as follows: you must access the regional Ross1000 portal using SPID or CIE. In the case of a foreign lessor, it is necessary to request access credentials directly from the Region’s offices. To obtain the CITRA code, you must report the new tourist apartment through the Webform. After submitting the notification, the Region registers the property and releases the CITRA. The CO-AAUT form will then be available in the Registry section.
According to the Liguria Region, for AAUT, online notification through the Ross1000 Liguria platform is immediate. Once the code is obtained, the notifier must contact the local Police Station or Headquarters for the registration of guests for public safety purposes. This requirement — registration of guests on the State Police’s Alloggiati Web portal — is mandatory and independent of the CITRA/CIN path.
An important note on the historical context: once the lessor’s notification was received, the Liguria Region registered the property in the database and released the CITRA code. With the entry into force of national regulations requiring CIN, the CITRA regulations were repealed as specified in Regional Law 1/2024 at art. 74, paragraphs 3-4. In practice, the CITRA today serves as a regional code preparatory to obtaining the national CIN, but it is no longer the code to be displayed independently in listings: that role belongs to the CIN.
Phase 2 – The CIN on the National Accommodation Database
Once the CITRA is obtained, you can access the National Accommodation Structure Database (BDSR) to request the National Identification Code. The CIN is requested free of charge on the BDSR portal of the Ministry of Tourism, by logging in with SPID or CIE. You enter the property’s cadastral data and a self-certification of safety requirements. If the data matches and the regional status is in order, the code is issued immediately and can be downloaded in PDF.
The documents required for the request include: an updated cadastral search (with sheet, plot and unit number), proof of property availability, and a self-certification of safety requirements. It’s worth paying particular attention to the latter: for all units intended for short-term rental, combustible gas and carbon monoxide (CO) detectors are required—in working order—in environments with boilers or gas kitchens, and compliant portable fire extinguishers in adequate numbers according to the surface area. The lack of detection devices and extinguishers is penalized independently, regardless of CIN ownership.
Once the CIN is obtained, the display obligations are precise: the CIN must be displayed on the exterior of the building where the accommodation is located and indicated in every listing, wherever published: your own website, OTAs such as Airbnb and Booking.com, social media and promotional material. In certain historic centers, specific materials for the external sign are required, and it is advisable to check beforehand at the municipal level. This is a detail not to overlook for those operating in Genoa’s historic center, which is subject to landscape protection constraints.
The CIN also has tax effects: from 2025, the code must be indicated in the buildings section of the income tax return; in the 2026 CU it is required at point 22. The absence of this data may trigger automatic cross-checks between the Revenue Agency and BDSR.
“The Liguria Region issues the CITRA code to AAUT lessors following registration on the Ross1000 platform. Once the CITR/CITRA is obtained, it is necessary to access the BDSR and request the CIN.”
— Liguria Region, official Identification Codes page (regione.liguria.it)
Penalties and inspections: the framework updated to 2026
The penalty system is one of the aspects that property owners tend to underestimate, perhaps because for years inspections were sporadic. Today the situation has changed, and the numbers confirm it.
Image generated with AI (Google Gemini)
Penalties provided by law
The penalty system provided for in article 13-ter of Decree-Law 145/2023 is structured on multiple levels:
- Failure to request the CIN: the failure to request the National Identification Code results in the application of a penalty ranging from 800 to 8,000 euros, depending on the size of the facility.
- Failure to display or absence of CIN in listings: amounts range from 500 to 5,000 euros. Listings considered irregular are also automatically removed.
- Business activity without SCIA: the owner is punished with a monetary penalty from 2,000 to 10,000 euros.
- Management without SCIA where required (abusive structures): typical penalties from 5,000 to 15,000 euros, with possible closure and seizures.
- Lack of safety devices: absence of minimum safety provisions: from 600 to 6,000 euros.
Who inspects and how in Genoa
Municipalities, through their local police agencies, organize inspection and verification activities on compliance with CIN regulations and, consequently, the application of penalties in case of non-compliance. The Revenue Agency and the Financial Police also support municipalities, conducting specific risk analyses—particularly targeting taxpayers renting property units without CIN—to counter tax evasion in the tourist rental sector.
In Genoa, the intensity of inspections underwent a significant acceleration in 2026. By cross-referencing data with the Revenue Agency and digital tourist registration platforms, the Municipality is monitoring inactive or unregistered accommodation facilities.
The Liguria context before the introduction of the CIN was already problematic. Around January 1, 2025—the date from which penalties would have begun—a significant share of Liguria’s structures had not yet complied: the provincial worst performer was Savona with 54% of non-compliant structures, followed by Imperia at 43%, La Spezia at 39%, and Genoa at 38%. Based on data from the Ministry of Tourism cited by FIAIP Liguria, at the end of 2024, Liguria had registered approximately 41,800 accommodation facilities and short-term rentals.
In Liguria, at the time of Genoa24’s survey, active furnished apartments for tourist use (AAUT) numbered in the tens of thousands, distributed throughout the region.
On the national front, inspections in the short-term rental sector have seen progressive intensification in recent years, with NAS campaigns that have led to inspections of thousands of structures and the discovery of a significant rate of irregularities, including both administrative and criminal violations.
“From May 20, 2026, platforms automatically verify the code before publication.”
— Ministry of Tourism, National Accommodation Structure Database (BDSR)
EU Regulation 2024/1028: the turning point of May 20, 2026
May 20, 2026 marked a structural change for the entire short-term rental sector in Europe, with concrete effects also for those renting an apartment in Genoa.
The 24-month transition period has expired. From May 20, 2026, the regulation is fully applicable: platforms and hosts must comply with the new rules, and inspections are operational. What changes in practice? Airbnb, Booking and other platforms are no longer mere showcases: from May 20, 2026, they have become guarantors of the legality of all listings they host. They are obligated to verify that the code listed in each advertisement is valid by checking it against public registers and must remove all non-compliant listings.
The platforms’ obligations are precise: they must verify the unique identification code (CIN) for every listed residential unit, refusing to publish listings without a valid code; transmit monthly to the Ministry of Tourism data relating to guests, nights booked and fees received for each property; make aggregated data available to national tax authorities, facilitating cross-checks by the Revenue Agency.
For platforms that do not comply with these obligations, the consequences are severe, which pushes them to be extremely strict in removing non-compliant hosts. This means that the risk of removal of non-compliant listings is no longer theoretical: it is automatic and immediate.
For those already in compliance with the CIN, the situation is manageable: those already in possession of the mandatory national identification code (CIN) from January 2025 have nothing additional to do. The Italian CIN already corresponds to the unique registration number required by the European Regulation. Being a regulation and not a directive, it does not require national implementation: the obligations for intermediation platforms are already in effect, and in Italy the Ministry of Tourism is the competent authority to receive data through the BDSR.
On the fiscal front, the most relevant effect for property owners is full visibility of income: income from short-term rentals continues to be subject to a flat tax rate of 21%, increased to 26% from the second unit onwards. The monthly transmission of data by platforms will make income from short-term rentals fully visible to the Revenue Agency, with possible pre-loading in the pre-filled tax return for subsequent years.
Practical implications for Genoa property owners: what to do now
Drawing together this regulatory framework, for a Genoa property owner who intends to rent their apartment for tourism purposes the priorities are clear.
If you are not yet registered: the path is Ross1000 → CITRA → BDSR → CIN. It is not possible to skip the regional step. The CITRA procedure on Ross1000 is free and immediate for Italian citizens with SPID or CIE. The CIN is then always obtained free of charge on the BDSR of the Ministry of Tourism. The CIN request is free and there are no official intermediaries. Be careful therefore of any paid services that promise to “take care of the paperwork”: the process is entirely digital and does not require intermediation.
If you already have the CITRA but not the CIN: you are in a non-compliant situation that needs to be resolved quickly. Those who already have the CIR/CITRA can request the CIN from the MITUR Telematic Portal, declaring the cadastral data of the accommodation and possession of safety requirements.
If you manage more than one apartment: you need to carefully evaluate the applicable regime. Current regulations provide for an entrepreneurial presumption threshold: those who manage three or more units are considered entrepreneurs, with the obligation to open a VAT number, file a SCIA and operate as a business. Even with one or two apartments, the 30-day limit per contract requires careful management of bookings.
On the safety front, it is essential to verify before submitting the self-certification that the apartment is equipped with gas and carbon monoxide detectors and compliant fire extinguishers. These are not “formal” requirements: their absence is sanctioned separately from the CIN.
Finally, it is worth remembering that the current regulatory complexity — regional codes, national code, EU Regulation, safety obligations, guest notification to the Police, tourist tax — has made “do-it-yourself” management of a short-term rental significantly more burdensome than a few years ago. It does not make sense for all property owners to manage independently: an error in any one of these obligations can result in penalties that wipe out several months of revenue.
For our residences in the heart of the city, we manage every administrative requirement: from CITRA to CIN, from police notification to tourist tax collection. If you are considering putting your apartment in Genoa to profitable use in a professional and compliant manner, contact us for a free assessment: our experience in managing 35+ residences allows us to guide you through this process with full knowledge of local procedures.
Processing based on public data and sources. genovabb.it is not a news outlet. The data reported have been collected from sources believed to be reliable but their accuracy is not guaranteed.
