From Regional CIR to National CIN: the New Regulatory Framework
For years, anyone renting an apartment in Genoa for short periods had to deal with a regional code: the CITR or CITRA, according to the Ligurian definition. To request the CIN, it is necessary to first obtain the CITR (Regional Tourist Identification Code) for accommodation facilities or the CITRA (Regional Tourist Identification Code for Apartments) for Aaut. Since 2024, this regional system has been accompanied — not replaced — by a national level: the National Identification Code (CIN), managed through the National Database of Accommodation Facilities (BDSR) of the Ministry of Tourism.
The legal basis is clear and dates back to the so-called Decreto Anticipi: the BDSR is the platform through which the electronic procedure for issuing the National Identification Code (CIN) is managed, introduced by article 13-ter of decree-law October 18, 2023, no. 145, converted by law December 15, 2023, no. 191. The detailed scope of application was then defined by a specific implementing provision: the objective scope of the regulation was defined by the decree of the Minister of Tourism June 6, 2024 prot. 16726/24 (so-called interoperability decree) and by the related annexes that form an integral part thereof.
The key dates are equally clear. According to the official FAQ of the Ministry, the date of effective application of the national CIN regulation is November 2, 2024, while sanctions are applicable from January 2, 2025. An important clarification concerns those who already have a regional code: many Genoese property owners, having already obtained the CITR or CITRA, thought they were automatically compliant. This is not the case: the obligation to possess and display the CIN is generalized and does not provide for exceptions, even for those who already have a regional/provincial identification code. In practice, two codes coexist in Genoa today: the regional CITR/CITRA and the national CIN, and the Liguria Region explicitly confirms this on its portal, explaining that once the CITR/CITRA is obtained, it is necessary to access the BDSR and request the CIN, since the BDSR requires the insertion of the CIR, which corresponds to the regional CITR/CITRA obtained.
Who needs to do all this? The scope is broad and includes practically anyone renting a property to tourists in Genoa, even if only for a few weeks a year: owners or managers of tourist accommodation facilities, hotels and non-hotel structures, lessors of real estate units destined for rental contracts for tourism purposes, and lessors of real estate units destined for short-term rentals pursuant to article 4 of decree-law April 24, 2017, no. 50. There are no minimum activity thresholds: even the owner of a single two-room apartment in the caruggi, rented for a couple of weeks a year, falls within the obligation.
Liguria’s Snapshot: Who Is Compliant and Who Isn’t
How far advanced has regularization been in Genoa, concretely? The most precise available data dates back to late 2024, in the weeks immediately preceding the implementation of sanctions, when the Ligurian situation was still in the adjustment phase. According to data from the Ministry of Tourism, in Liguria 44.15% of short-term rental facilities had already obtained the mandatory CIN code, just days before the new decree law was scheduled to take effect on January 1, 2025.
Photo by Annika Wischnewsky on Unsplash
“The Liguria Region introduced the regional tourist identification code CITRA with Regional Law 32/2014, with operational activation of the platform for code assignment and publication obligation from August 1, 2019.”
— Luca Lombardi, Tourism Assessor of the Liguria Region
Assessor Lombardi, in commenting on end-of-2024 data, framed the situation as a transitional phase to be managed, recalling that the CIN obligation applies to all properties intended for short-term rentals, which must request it through the Ministry of Tourism’s BDSR platform, display it on the property, and include it in every published listing. More than a year later, the national picture shows substantial but not yet complete progress, with a significant increase in regularized facilities compared to late 2024 levels — progress that plausibly also affects the capital, though without precise confirmation of the most recent Genoese numbers.
For property owners, this means one simple thing: a significant portion of Genoese landlords, at the end of 2024, risked heavy sanctions simply for not completing an administrative procedure. It is a margin of risk that today, with automated platform controls, has narrowed but has certainly not disappeared.
The Crackdown from Platforms: What Changes from May 20, 2026
The real qualitative leap in controls came with the implementation of Regulation (EU) 2024/1028, the first EU regulation dedicated to the transparency of short-term rentals intermediated by digital platforms. The regulation is not a directive to be transposed: being a regulation rather than a directive, it does not require national transposition, the obligations are directly operational. After a two-year transition period from its adoption, from May 20, 2026, member states, digital platforms, and landlords face a harmonized system of registration, identification of accommodations, and data transmission to competent authorities.
Photo by ready made on Pexels
In practice, for Airbnb, Booking.com, Vrbo and other OTAs this translates into two concrete obligations. The first is automatic verification of the identification code before publication: platforms remove listings lacking a CIN upon notification by authorities, and from May 20, 2026 they carry out code verification automatically, before even making the listing visible. The second is periodic transmission of booking data: from May 20, 2026, the obligation for online short-term rental platforms — Airbnb, Booking.com, Vrbo and similar — to transmit monthly booking data to the competent national authorities came fully into effect; in Italy, this is the Ministry of Tourism.
The major OTAs have moved ahead of schedule to avoid being caught unprepared: the main platforms operating in Italy adapted in advance of the May 20 deadline; Airbnb updated its onboarding system by making CIN entry mandatory when creating new listings, while Booking.com implemented automatic verification of code validity through an API connected to the BDSR. For owners, this means that a listing with missing, incorrect, or inconsistent CIN relative to the actual cadastral address risks immediate suspension, without the tolerance margin that characterized manual or report-based checks in the past.
There is also a significant tax impact: greater visibility of booking data to the Revenue Agency. Monthly data transmission by platforms will make short-term rental income fully visible to the Revenue Agency, with potential pre-loading in the pre-filled tax return in subsequent years. Anyone who has so far managed short-term rentals with some discrepancy between what they declare and what they actually receive from platforms will have much less room for maneuver going forward.
Penalties, risks and practical implications for those renting in Genoa
The penalties provided for by regulation are not symbolic, and their amount is calibrated to the severity of the violation. For those renting without a CIN, the penalty provided for in Article 13-ter of D.L. 145/2023 ranges from €800 to €8,000; those who fail to meet safety requirements, such as gas detectors and fire extinguishers, risk a penalty of €600 to €6,000; those who lease more than two apartments in the short term, thus falling under the presumption of business activity from the third property onwards, without having filed the SCIA risk a penalty between €2,000 and €10,000. In addition, there is a specific penalty for failure to display or indicate the code in listings: failure to display or indicate the code in a listing is punished with a penalty of €500 to €5,000, with removal of the listing.
Beyond the fine, for an owner living off short-term rentals there is often a more immediate and concrete damage: the disappearance of the listing from the market, with consequent loss of bookings in the days or weeks needed to regularize their position. In a seasonal market like Genoa’s, where a significant portion of annual turnover is concentrated between spring and autumn, a block of two or three weeks due to incomplete administrative procedures can weigh disproportionately on the year’s bottom line.
It should also be noted that the regulatory context in Liguria continues to evolve, in a debate fueled also by data on the local real estate market that signals tensions in residential rents and a significant number of vacant homes in the city. At the same time, the economic weight of the tourism rental sector remains significant for the Ligurian economy. This dual track — housing pressure on one side, economic value on the other — is the framework in which any future regulatory intervention, regional or municipal, on the sector will be inserted.
For those who own a property in Genoa and are considering putting it to income with short-term rentals, or already do so, the correct operational sequence today requires three mandatory steps: first the SCIA or notification to the competent Municipality, then the request for CITR or CITRA through the Ross1000 regional portal, finally access to the BDSR via SPID or CIE to obtain the CIN, to be displayed physically on the property and reported in each individual listing, on any platform. It is a process that requires attention to technical details — starting with the property’s cadastral data — and which, if handled carelessly, exposes you to concrete risks both in terms of penalties and operational continuity of the listing.
genovabb.it manages over 35 residences in the heart of Genoa, and this type of compliance is part of the ordinary management of every property in our portfolio. For those approaching this market for the first time, or for those already managing independently and wanting to verify they are fully compliant, understanding the logic of the CIN-BDSR-EU Regulation system is the first step to avoid surprises: the regulation is complex, but it is not impossible to navigate with the right information.
Processing of public data and sources. genovabb.it is not a news publication. The data reported have been collected from sources considered reliable but their accuracy is not guaranteed.
