Requirements for the digital registration form in Germany
The digital registration form has been approved by the German Federal Cabinet in 2019 and will digitize and simplify the guest registration process from 01.01.2020. But is the practical implementation of this legislative process in the hotel industry really realistic?
The registration process at the hotel reception can now be simplified due to digital registration forms
Sounds great?! But in most cases, the technical requirements have still to be created by the hotels themselves.
In addition to the upcoming
Kassensicherungsverordnung, the possibility of signing check-in forms digitally comes into force with 01.01.2020.
Up to now, guests arrive at the hotel and provide their personal details at the check-in counter. Since 2015, it is also possible to fill out some parts of the registration form digitally. This means that information can be requested and already filled in in advance (there are already different providers for this service). This already greatly simplifies and quickens the check-in process. Nevertheless, hoteliers were still obliged to print out the registration form and let the guest sign it by hand. After arrival, the registration forms must then be stored for one year and afterwards (at the latest after three further months) destroyed in accordance with the law.
Requirements
The law concerning the digital registration form from 01.01.2020 promises bureaucratic relief, avoidance of unnecessary printouts and cost reduction. For the actual implementation in the hotel, the previously manual signature can be exchanged with another procedure that is considered secure.
The current legal situation provides the following options for verifying:
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Payment transaction with Strong Customer Authentication (SCA):The SCA comes into force within the law of the PSD2 and requires a two-factor authentication of the customer (read more on this here).
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Electronic functions of the identity card:The latest ID cards are equipped with an eID-card whose data can be read using a special reader and by entering a personal PIN.
Note
The technical implementation of these methods can be complex and problematic for many hotels. In a lot of hotels, payment is often only made at checkout. In addition, hotel nights are sometimes also paid by another invoice recipient, e.g. for company stays or group bookings. In addition, the hotel program (PMS) must have an interface with the payment provider for legally correct processing.
Concerning the proof of identity on the basis of the identity card, this procedure is currently rather difficult since the number of cards with eID-card is currently still limited to very few. In addition, the installation of a special certified reader entails additional costs for the hotelier.
To store the data for one year, a secure storage location and encryption against unauthorized persons is necessary. This requires that the PMS stores the so-called token for the encrypted identification of users in the PMS for 12 months and keeps it available so that the user can be identified again at any time.
Conclusion
Currently, accommodation providers can decide for themselves whether they want to retain the manual signature in paper form or digitize the process as described above.
Get detailed information about your possible options and make sure that the offers are really legally compliant. Until you have found an adequate solution for yourself, you can continue to follow the procedure you are familiar with.
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