Hotels with more than 25 beds fall under activity 66 of Annex I to Presidential Decree (DPR) 151/2011 and are therefore subject to fire prevention checks by the Corpo Nazionale dei Vigili del Fuoco (Italy’s National Fire and Rescue Service). The long-standing technical rule is Ministerial Decree (DM) 9 April 1994, alongside DM 14 July 2015 for existing accommodation businesses with up to 50 beds, and the fire prevention code. Below 25 beds, a property isn’t subject to these checks, but the general workplace safety obligations still apply.
What follows is an informational overview, useful for understanding the scope of the requirements and for talking knowledgeably with your own consultants. The fire safety design, the sworn technical statement (asseverazione) and the risk assessment remain the responsibility of a qualified professional registered with the Ministry of the Interior: no article can replace that signature.
Contents
The 25-bed threshold: who is covered and who isn’t
Activity 66 of Annex I to DPR 151/2011 sets out in detail which businesses are covered: hotels, guesthouses, motels, albergo villages, tourist residences, student halls, tourist villages, farm-stay accommodation, youth hostels, mountain refuges, bed and breakfasts, dormitories and holiday homes with more than 25 beds. Open-air accommodation businesses, such as campsites and holiday villages, are also covered when capacity exceeds 400 people.
The count is based on authorised beds, not rooms: a property with twelve double rooms plus a couple of extra beds goes over the threshold. This is a point that often catches out anyone considering extending a small property, because two extra beds change the administrative regime and, as a result, the management and design costs.
Below 25 beds, a property isn’t subject to Vigili del Fuoco checks, but it’s far from exempt from obligations. Legislative Decree 81/2008 on workplace safety still applies, along with the fire risk assessment under the criteria of DM 3 September 2021, the inspection and maintenance of fire safety systems under DM 1 September 2021, and staff training under DM 2 September 2021. In practice, what changes is the level of formal documentation, not the substance of the operator’s responsibility, which falls among the obligations of a hotel operator towards guests and staff.
Categories A, B and C: what changes in practice
DPR 151/2011 introduced three categories of increasing risk, which determine the administrative process. For accommodation businesses, the distinction is based on bed numbers.
| Beds | Category | Project review | Starting the business | Vigili del Fuoco inspection | Periodic renewal |
|---|---|---|---|---|---|
| Up to 25 | Outside activity 66 | Not required | No specific requirement | None | Not required |
| Over 25 up to 50 | A | Optional | Fire safety SCIA | Sample-based, within 60 days | Every 5 years |
| Over 50 up to 100 | B | Mandatory | Fire safety SCIA | Sample-based, within 60 days | Every 5 years |
| Over 100 | C | Mandatory | Fire safety SCIA | Mandatory technical inspection | Every 5 years |
Open-air accommodation businesses with capacity above 400 people fall into category B. The practical difference between categories mainly comes down to two points: in categories B and C, the project must be submitted for prior review by the local Comando (fire brigade command), with timescales that need factoring into the works schedule; in category C, the technical inspection isn’t sample-based but mandatory, and concludes with the issuing of the fire prevention certificate.
The technical rules: 1994, 2015 and the code
The main reference remains DM 9 April 1994, which approves the technical rule for the construction and operation of tourist accommodation businesses. It covers location, separation, fire resistance of structures, compartmentalisation, escape routes, systems, firefighting equipment, signage, safety management and the fire reaction of materials.
For existing properties with more than 25 and up to 50 beds, DM 14 July 2015 introduced simplified provisions proportionate to the smaller size, maintaining the safety level while avoiding disproportionate requirements for a building with just a few rooms. This is the rule that finally made it practical to upgrade many small historic hotels, often housed in listed buildings where traditional compartmentalisation was impossible.
Alongside this track sits the fire prevention code, approved by DM 3 August 2015, which since 2016 has included a vertical technical rule dedicated specifically to tourist accommodation businesses. It’s a performance-based approach: instead of imposing a single solution, it defines the performance levels to be achieved and allows for compliant or alternative solutions, provided they can be demonstrated. For complex buildings, deep renovations, and cases where the 1994 rule would require very invasive work, the code offers room for manoeuvre that’s worth the designer’s fee.
Fire safety SCIA, inspections and five-year renewal
The administrative process has three stages. Project review, required under Article 3 of DPR 151/2011, applies to categories B and C and to substantial changes: the Comando assesses the project before work begins. The fire safety SCIA (certified notification of start of activity), governed by Article 4, is submitted at the end of the works and before opening, through the one-stop shop for business activities: with the SCIA, the business can open immediately, supported by certifications and declarations of correct installation of systems and materials. Periodic renewal, required under Article 5, must be submitted every five years for accommodation businesses, with a sworn statement from a qualified professional confirming there have been no changes and that safety conditions remain in place.
Renewal is the requirement most often forgotten, because it falls due at a distance and comes with no automatic reminder. It’s worth adding it to the extraordinary maintenance calendar alongside periodic inspections of lifts and electrical systems, so that site visits can be grouped together during the low season.
Upgrading existing properties: the timetable
Hotels already existing when the 1994 technical rule came into force have followed, for thirty years, an extraordinary upgrade plan, reopened and extended several times. The latest legislative measure pushed the final deadline to 31 December 2026, with the fire safety SCIA to be submitted by the end of 2025, and raised the minimum technical requirements to be met in the meantime from six to eight. Because the deadlines have been changed almost yearly, the current date always needs checking with the appointed professional before scheduling the works.
Anyone still within the upgrade plan has a practical advantage: fire safety works almost always affect corridors, staircases, doors and compartmentalisation, the very same areas that a cosmetic renovation would have to revisit anyway. Hotel room doors are the clearest example: replacing them for fire resistance reasons and then redoing them two years later for appearance is a waste that’s avoided only by coordinating the two projects from the start.
Day-to-day management: emergency plan, team, logbook
Fire safety doesn’t end with the SCIA. The technical rule requires documented, verifiable management, built around a few concrete tools:
The inspection logbook comes first. It records periodic checks of systems, extinguishers, emergency lighting and fire doors, together with function tests, each with its own date and signature: a logbook filled in all at once the day before an inspection, in the same pen and the same handwriting, is spotted by anyone. Then comes the emergency and evacuation plan, with floor plans displayed on every floor and brief instructions in the room, also written in English. The emergency team must be present on every shift, and the shift that matters most is the night one, when guests are asleep, don’t know the building, and have only a few seconds to work out which way to go. Fire drills must be carried out at least every six months and recorded in writing.
Staff training follows DM 2 September 2021: level 2 for accommodation businesses with more than 25 beds, level 3 for hotels with more than 200 beds, with refresher training at least every five years. The count is based on beds, not rooms, a detail that catches out plenty of properties: a few extra beds sold to families in high season are enough to cross the threshold without anyone noticing.
The clarity of escape signage and the consistency of hotel room numbering aren’t cosmetic details: in a night-time evacuation, a disoriented guest needs to work out which way to go within three seconds, and staff need to be able to tell whoever is coordinating the rescue which rooms still need checking.
The role of furniture: fire reaction and Class 1 IM
The part of the regulations that most directly affects furnishing concerns fire reaction, meaning how materials behave once they’re already on fire. The 1994 technical rule sets different requirements by area and type: in escape routes, coverings must be largely non-combustible, permitted wall coverings are Class 1, curtains and suspended materials must be at least Class 1, while upholstered furniture and mattresses must be Class 1 IM. Lobby armchairs, upholstered headboards and breakfast room sofas fall into this category far more often than people realise.
Knowing what the fire safety regulations on furniture require avoids two opposite mistakes. The first is buying furniture without the right approvals, only to end up with a supply that fails at final inspection. The second is paying for requirements that aren’t needed across the whole supply, when the rule only calls for them in certain areas. Class 1 IM applies to the whole upholstered piece, not the fabric alone: an approved cover fitted over non-approved padding doesn’t make a compliant upholstered item.
On the documentation side, the file needs to be built alongside the supply. The fire-resistance certificate for furniture must state the approval number, the material it refers to and its correspondence with what’s actually installed, and must be accompanied by a declaration of correct installation. The choice of contract fabrics needs to be made upfront, when the specification is defined: changing an upholstery fabric once production has started almost always means redoing the approval process for the whole piece.
In upgrade projects, this is where the supply chain makes the difference. We build made-to-measure furniture by coordinating a supply chain of selected Italian workshops, with a single point of contact from survey to final testing: the fire reaction certificates arrive together with the furniture, already prepared for the file the professional will attach to the SCIA, without having to chase different suppliers once the work is finished. For anyone still weighing up the initial investment, fire safety is one of the costs that weighs most heavily in the process of opening a hotel and should be estimated in advance, not once the site is already open.
Frequently asked questions
What changes above 25 beds? Above 25 beds, a property falls under activity 66 of Annex I to DPR 151/2011 and becomes subject to Vigili del Fuoco checks. From that point, the fire safety SCIA is needed before opening, along with compliance with the applicable technical rule and periodic renewal every five years. Below the threshold, the obligations to assess fire risk and train staff under workplace safety regulations still apply.
What is the fire safety SCIA and how often is it renewed? The fire safety SCIA is the certified notification the owner submits to the one-stop shop at the end of the works and before opening, together with certifications for systems and materials. It allows the business to open immediately, subject to subsequent checks by the Comando. For accommodation businesses, the periodic fire compliance renewal is submitted every five years, sworn to by a qualified professional.
Is a fire prevention certificate needed for a B&B? A bed and breakfast with up to 25 beds isn’t among the businesses covered and so doesn’t submit a fire safety SCIA. If it exceeds 25 beds, it falls under activity 66 exactly like a hotel, with the same requirements for the corresponding category. Extinguishers, gas and carbon monoxide detectors required for non-hotel accommodation, and staff training, are always required regardless.
Who checks fire safety in a hotel? Institutional oversight belongs to the provincial Comando of the Vigili del Fuoco, which carries out sample-based checks on category A and B businesses and mandatory technical inspections for category C. In the event of an accident or fire, workplace safety authorities and the judiciary may also become involved. Day-to-day responsibility for management, periodic checks and the logbook, however, remains with the owner or operator of the property.
