Negative impact on Spain's competitiveness of Royal Decree 933/2021

Since the start of this year, the Spanish Law Decree 933/2021 requires travel and tourism service providers to collect and report more client data than any other European country.

It harms competitiveness, adds friction within the value-chain and increases costs. Together with partners, HOTREC has made repeated representations to the relevant Ministries in Spain with no response. Due to concerns about the Decree’s compatibility with EU data protection regulation, the European Commission has been notified. This is serious, and it is also avoidable.

The impact is felt across the intra-European ecosystem of operators, DMCs, agents and hoteliers, as well as by those selling Europe in global markets. Business ranges from large B2B and B2C operators to FIT and niche specialists in small groups business delivering tourism across the continent throughout the year. Spain remains popular, but it is harder for operators to work with due to the extensive client data collection and reporting requirements imposed by the Decree.

For the domestic supply chain in Spain, especially small businesses, the Decree poses an impossible dilemma: risk non-compliance with EU regulation and consequent fines or comply with the exceptional demands of the Royal Decree. Regulation must be necessary, rational and proportionate. On current evidence, the decree is none of these and is harming a value-adding ecosystem that secures Spain value export revenue.

To illustrate the practical impact as 2025 progresses, below are some perspectives from Spain’s hoteliers, and from operators working with Asian and North American markets. For them, Spain is now an outlier in terms of business complexity. That is a risk. Where is the benefit?

Please find the joint press release under "Related documents".

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