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Compliance • Self check-in • Public safety
Remote de visu verification in check-in: what the Council of State says (Judgment 9101/2025) and how to do it correctly
The judgment clarifies that de visu verification can also be carried out using video conferencing tools, but only if they are suitable for verifying hic et nunc the correspondence between guest and document.
In brief
The Council of State (Sec. III, judgment 21/11/2025 no. 9101) reiterates the obligation of de visu verification and clarifies that it can also be carried out remotely using suitable tools (video conferencing) capable of verifying hic et nunc the correspondence between guest and document.
- It is not enough to receive a photo of the document.
- A real visual check at the time of check-in is required.
- Technology is acceptable, but only if designed for genuine identification.
Why "de visu verification" is central to check-in
In the hospitality world, the point is not to "collect a document," but to ascertain that the person staying matches the document and then manage the required formalities. This is a matter of public safety and traceability: anyone entering the facility must be correctly associated with a verified identity.
What judgment 9101/2025 says (operationally)
Three clear messages:
De visu verification is part of the compliance.
The operator must visually verify the correspondence between the person and the document (at least compared to the photograph).
The operator must visually verify the correspondence between the person and the document (at least compared to the photograph).
"Remote check-in" without visual feedback is not sufficient.
Only sending the document + code/key does not provide guarantees on location, time, and visual correspondence at the time of access.
Only sending the document + code/key does not provide guarantees on location, time, and visual correspondence at the time of access.
Technology is allowed if suitable.
Verification can also take place via video conferencing, provided it allows for a hic et nunc verification.
Verification can also take place via video conferencing, provided it allows for a hic et nunc verification.
"Remotely" yes, but not improvised
❌ Risky approaches
- Document sent via channels not designed for identification.
- Access granted with code/key without video verification.
- No "here and now" verification before entry.
In these cases, identification risks being reduced to a mere data collection, without real visual feedback.
✅ Correct approach
- Real-time visual verification (video) before access.
- Document available during verification, within the same operational flow.
- Standardized, traceable, and replicable process.
How Grisup's FaceCheckin works
FaceCheckin (written as one word) is designed to make remote check-in a structured digital de visu verification:
Secure document upload
The guest uploads the document in a dedicated environment, avoiding improvised channels.
The guest uploads the document in a dedicated environment, avoiding improvised channels.
OCR and data pre-filling
An OCR extracts data and reduces manual errors, preparing for verification.
An OCR extracts data and reduces manual errors, preparing for verification.
Integrated video call with document on screen
The operator verifies the person in real time and, on the same screen, compares face and document.
The operator verifies the person in real time and, on the same screen, compares face and document.
Objective: to allow for real and immediate visual feedback (hic et nunc), consistent with the principles referred to in the judgment.
FAQ
Can de visu verification be done remotely?
Yes, if the procedure uses suitable tools (e.g., video conferencing) that allow for a real and immediate visual verification (hic et nunc) between guest and document.
Is sending a photo of the document enough?
Generally no: without visual feedback at the time of check-in, you risk reducing everything to data collection without true person-document correspondence.
Is self check-in prohibited?
It's not a "yes/no" in abstract: what matters is how you implement the procedure. If a robust and consistent de visu verification is missing, the model may not be considered adequate.
Do you want a remote check-in that is truly "inspection-proof"?
Grisup's FaceCheckin combines secure document upload, OCR, and integrated video calling with on-screen document, for a structured and replicable digital de visu verification.