Guest records and SES.HOSPEDAJES: retention, queries and submission evidence
Reporting data to the Ministry and maintaining your own records are separate tasks. What to check about retention and queries without assuming SES provides downloads.
In this guide
Sending a report to SES.HOSPEDAJES and retaining the accommodation’s own records are separate tasks. To know what information to keep and how to find it, distinguish the guest record, the submitted report and evidence of its outcome. Having a booking in the calendar does not necessarily cover all three.
The property's own records
Property records
Reporting
Data sent to the Ministry of the Interior
Outcome
References and issues
Your own records and reports to the Ministry
| Item | Why it should be identified |
|---|---|
| Accommodation records | Locate the information you must retain for your activity. |
| Submitted report | Know what information was reported and which stay it relates to. |
| Submission outcome or reference | Check whether the process completed and investigate an issue. |
Use this distinction to review your procedure or the terms of the software you use. A screen showing a booking does not establish that it contains the required records or that the official submission completed successfully.
The three-year period and when it starts
Article 5.3 of Royal Decree 933/2021 sets a three-year retention period for computerised records, starting when the contracted service ends. The starting point matters: it is not the date the booking was created.
Paragraph 4 of the same article exempts those providing accommodation on a non-professional basis from the documentary record and retention obligations it regulates. Their reporting obligations remain. A single statement about retention therefore should not be applied to every operator.
To distinguish professional activity, question 6 of the Ministry’s FAQs refers to registration in the Censo de Empresarios, Profesionales y Retenedores, the Spanish register of business operators, professionals and withholding agents. Review that criterion before assuming that managing just one property amounts to non-professional activity.
If you manage several properties, check how each activity is classified before defining a shared archive. Also separate these records from documents kept for other reasons: an invoice or contract may have its own handling requirements and retention period.
Can SES.HOSPEDAJES provide a list?
Question 32 of the official FAQs, updated on 10 August 2026, states that lists of submissions made in the application cannot be produced or supplied. The Ministry explains this by reference to the public security purpose of its data processing.
This clarification concerns data in the Ministry’s application. It does not remove the accommodation’s own record-keeping obligations or establish that maintaining those records is prohibited. Before relying on a future SES download as your archive, review how you currently retain the information for which you are responsible.
Checklist for your archive
Locate the records
Identify where the records are kept and who can access them.
Link each stay to its records
Check that each stay can be linked to the relevant information and references.
Test a records search
Use a sample booking to check how an issue is located and its resolution documented.
Review the process for changing provider
Review access and data handover terms if you change provider or stop using the service.
Manage retention periods and access
Define a review of retention periods and access. Prevent a temporary working file from becoming an uncontrolled permanent copy.
These are organisational checks: they do not assume that a particular program provides exports, backups or any specific feature. Ask the provider to document what the service includes and compare it with your needs.
Retaining details does not mean keeping the entire identity document
Review what is retained
Review what you are archiving as well as for how long. The Spanish Data Protection Agency’s accommodation guidance rejects requesting copies of identity cards or passports to complete registration. Do not accumulate document images on the assumption that everything must be kept for three years.
To organise the whole process, review data collection before arrival and the checks made after each submission.
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