Compliance in Türkiye

KBS staff notification: identity reporting for the people who work at a hotel

KBS staff notification covers employees, not just guests. This guide explains the 24-hour rule, Form 2 requirements, and how to assign ownership for seasonal hires and contractors.

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Contents

Key takeaways

  1. The Kimlik Bildirim Sistemi (KBS, guest identity notification) is operated by two authorities: the Emniyet Genel Müdürlüğü (General Directorate of Security, the police) for lodging facilities in police jurisdiction, and the Jandarma Genel Komutanlığı (Gendarmerie General Command) for facilities in rural, gendarmerie jurisdiction. Which portal and which contact point apply depends on where the facility is located. The police system, in service since 18 April 2017 for lodging facilities in police jurisdiction, holds the details of the people staying and the people working there (EGM, Kimlik Bildirim Sistemi, 2026).
  2. Article 8 of the regulation implementing Law No. 1774 requires the operator to record every person employed permanently or temporarily on two copies of the Employee Identity Notification Form, Form 2, and deliver them to the nearest competent law enforcement unit within 24 hours (Regulation, as amended 17 June 2022).
  3. The facility's authorized person enters KBS through e-Devlet and can give staff their own logins scoped to guests only, staff only or both (Jandarma Genel Komutanlığı, KBS Tesis 2 Bilgi Dokümanı, 14 November 2018).
  4. The 17 June 2022 amendment allows the same notifications to be made electronically, within the same time limits, by connecting to law enforcement's computer terminals.
  5. Joiners and leavers belong to HR, because the trigger is the employment record, not the shift roster.

KBS staff notification is the part of Türkiye's Kimlik Bildirim Sistemi (identity notification system) that covers the people who work at a lodging facility, not just the people staying. The operator records each employee on the Employee Identity Notification Form (Form 2) and delivers it to the nearest competent law enforcement unit within 24 hours.

A new hire signs a contract on Monday and works the first night shift on Friday. The front desk learns the name from the roster, and the staff identity notification, if anyone thought about it at all, is still blank. The gap is rarely laziness. It is that nobody was given the step. After reading this, you will know what the regulation asks for, who should own the step, and what to confirm with the authority before you change your process.

Does KBS cover hotel staff as well as guests?

Yes. The identity notification system used for lodging facilities holds the details of the people staying and of the people working there, and the staff side has its own rule in the implementing regulation.

The Emniyet Genel Müdürlüğü (Directorate General of Security) put the Kimlik Bildirim Sistemi into service on 18 April 2017 for lodging facilities in police jurisdiction, and registered facilities send their records through it instantly, according to the EGM's Kimlik Bildirim Sistemi page (opens in a new tab) (2026). Underneath the system sits the Identity Notification Law (Kimlik Bildirme Kanunu, Law No. 1774), which requires the responsible operator of every hotel, motel, pension, holiday village, campsite and similar lodging place to keep identity and arrival and departure records of everyone staying, local or foreign, day by day. An additional article of the same law requires lodging facilities to keep all records on computer and report them instantly to the general law enforcement by connecting to its computer terminals.

The staff duty sits in the regulation that implements the law, not in a separate statute. Article 8 covers people who work at the facility, permanently or temporarily. The law also lets the operator delegate these duties to a manager, and in that case both are jointly responsible. Delegation moves the work, not the liability.

So staff notification is not a second system to learn. It is the same duty applied to a second group of people, which is exactly why it gets forgotten. For the guest side of the same system, see KBS explained: guest identity notification for hotels in Türkiye.

Key pointOne system, two populations

KBS holds guests and staff. Guest notification is usually owned by the front desk; staff notification has no natural owner unless one is assigned.

Guests and staff in one system: separate logins, separate scopes

The facility's authorized person enters KBS through e-Devlet and can give other staff their own logins limited to guests only, staff only, or both.

This is described in the Gendarmerie General Command's KBS information document (opens in a new tab) (KBS Tesis 2 Bilgi Dokümanı, 14 November 2018), which is the clearest public description of how the roles work. The practical consequence is least privilege: a front desk agent needs guest records, an HR user needs staff records, and few people need both.

The same document describes a web service module for facilities that use hotel automation software. Data is entered in the hotel's own program and notified instantly, and each authorized user registers the hotel's fixed IP address and a KBS password, with identity number, password and IP checked together on every call. Treat the fixed-IP detail as a 2018 description, not a current rule. It may have changed, and it should be confirmed with the authority that receives your notifications.

Write the login list down and review it when someone leaves. A login that outlives the employment is the quiet version of an unclosed record.

RoleWhat the job needsSuggested login scope
Front desk agentGuest check-in recordsGuests only
Night auditorGuest records and correctionsGuests only
HR or personnel officerStaff recordsStaff only
General manager or ownerOversight of bothBoth
Software web-service userAutomated sending from the hotel systemScope set with the authority

How the notification itself reaches the system, through the web screen or your hotel software, is covered in how KBS notification works.

Who should own joiners and leavers?

HR should own it, because the trigger is the employment relationship that HR already records, and the front desk should never be the fallback.

The duty attaches to people employed at the facility, so the natural moment to act is the contract, not the first shift. The night shift meets a new name at 23:00 with no contract, no identity document copy and no authority to file anything. That is a structural failure, not a training problem.

Leavers matter as much as joiners: close the record and the KBS login on the last working day, in the same session as the payroll exit. Run one monthly cross-check: the payroll list against the staff records you have notified. Differences are usually seasonal hires and people who transferred between departments.

Keep the evidence of each notification with the personnel file, so a later question can be answered from the file rather than from memory.

ChecklistJoiner and leaver checklist

  • Contract signed, identity document seen
  • Staff record prepared on the current Form 2 version
  • Notification sent by the route your facility uses, paper or electronic
  • Evidence filed with the personnel file
  • KBS login created with the narrowest scope that fits the job
  • On exit, login closed and record updated on the last working day
  • Monthly payroll-to-KBS cross-check signed by the owner of the step

What does the regulation require for staff, and how long do you have?

Article 8 of the implementing regulation requires the operator to write the identity of everyone employed at the facility, permanently or temporarily, on two copies of the Employee Identity Notification Form (Çalışanlara Ait Kimlik Bildirme Belgesi, Form 2) and deliver them to the nearest competent general law enforcement unit within 24 hours.

The 24-hour limit is specific to lodging. The same article gives other commercial workplaces three days, which is why advice copied from a general HR blog is often wrong for a hotel. An amending regulation published on 17 June 2022 (Resmî Gazete No. 31869), in force the same day, replaced Form 1 and Form 2 with new versions and repealed Form 5, according to the Resmî Gazete text of the amendment (opens in a new tab). Older printed pads may be out of date.

The same amendment added to Article 8 that these notifications may also be made electronically, within the same time limits, by connecting to the general law enforcement's computer terminals. The route changed; the clock did not.

Form 1 and Form 2 are different forms under the same regulation; Form 2 concerns the people who work there. Confirm with the authority which form applies to your facility today, and keep the answer with your KBS file rather than in someone's inbox.

RouteWhat happensTime limitWhat to confirm
PaperTwo copies of Form 2 delivered to the nearest competent unit24 hoursCurrent form version; which unit is competent for your address
ElectronicNotification through law enforcement computer terminalsSame time limitsWhether your facility is enabled; who holds the credentials

Seasonal staff, interns and contractors: what should you ask?

The regulation covers people employed permanently or temporarily; where a particular arrangement falls is a question for the authority and your adviser, not something to settle from a blog.

Seasonal hires are the clearest case of temporary employment, and a hotel that runs a summer season should have a written routine for them rather than a yearly scramble. Interns raise a legal question: whether an internship counts as employment for this duty should be asked before the first intern arrives, not after. Contractors, the staff of an outsourced cleaning, security or animation company, are not your employees, but they work at the facility; ask whether, and how, they should appear. Event-day extras and day-rate staff raise the same question in a smaller form.

Write each answer down with the date and the person who gave it. A documented answer is worth more than a correct guess nobody recorded.

Watch outDo not copy deadlines and fines from blogs

Deadlines and fine figures you find online are not verified here. Ask the authority that receives your notifications, and your legal adviser, for your own case, and keep their answer on file.

Staff records are personal data: who inside the hotel should see them?

Staff identity records are personal data under KVKK (the personal data protection law), so access should follow the job, not the seniority.

The identity number, document details and employment record of an employee deserve the same care as a guest's. Keep the staff notification evidence in the personnel file, not on a shared drive that the whole front office can browse. Use the KBS login scopes described earlier as the technical expression of the same rule: the person who files staff records is the person who holds the staff login.

When someone leaves, close both the KBS login and any internal access in the same session. Two lists that drift apart are two ways in. If your hotel software holds the personnel data, review its user roles at the same time you review the KBS logins; a starting point is a PMS user roles and permissions setup checklist.

What should you confirm with the authority before you change your process?

Confirm the current form version, the receiving unit, the route and the treatment of temporary workers, and record the answers with a date.

Which law enforcement body receives your facility's notifications, police or gendarmerie, depends on where you are. Confirm it rather than assuming. Ask whether the electronic route is available to your facility and who holds the credentials. Ask for the current version of Form 2, since the 2022 amendment replaced the earlier forms. Ask how seasonal, intern and contractor arrangements should be handled in your case.

Leave penalties to your adviser: penalties were not verified for this article and should be confirmed with a legal adviser for your facility's own case. Keep one page with these answers, the date and the name of the person who gave them, next to your KBS file.

ChecklistConfirmation checklist

  • Competent law enforcement unit for this address
  • Current Form 2 version obtained
  • Paper or electronic route, and who holds credentials
  • Treatment of seasonal staff, interns and contractors
  • Who inside the hotel may hold a staff-scope login
  • Where notification evidence is filed
  • Date and source of each answer

What to do next

Add one line to the HR onboarding checklist, naming the person who prepares and sends the staff identity notification and the person who checks it, and give that step the same weight as the contract and the payroll entry. Guest notification and staff notification are the same duty applied to two populations, the regulation gives the staff side its own form and its own 24-hour clock, and the system itself already supports logins scoped to staff only. Once the step has an owner and a place in the file, the night shift stops being the place where identity records go missing.

Frequently asked questions

Is KBS staff notification the same as SGK registration?

No. They are separate duties with separate purposes. SGK registration is an employment and social security step handled by HR or the accountant, while KBS staff notification is an identity notification to general law enforcement under Law No. 1774 and its implementing regulation. Completing one does not complete the other, and this article states no SGK rules.

Do we have to notify for someone who works only one or two nights?

Article 8 covers people employed at the facility permanently or temporarily, which points toward yes for short engagements. The treatment of very short or informal arrangements should be confirmed with the authority and your adviser. Do not decide it from a blog.

Can our front office manager see staff records in KBS?

Only if the facility's authorized person gave that person a login scoped to staff or to both. The Gendarmerie's 2018 information document describes logins limited to guests only, staff only or both. Scope each login to the job and review the list when someone leaves.

What happens if a staff notification is late?

The amount and treatment of any penalty were not verified for this article and must not be quoted from memory. Ask your legal adviser or accountant for the figure that applies to your facility and date.

Does sending electronically replace the paper Form 2?

The 17 June 2022 amendment added to Article 8 that notifications may also be made electronically, within the same time limits, by connecting to law enforcement's computer terminals. Whether your facility is enabled for that route should be confirmed with the authority that receives your notifications.

Sources

  1. Kimlik Bildirim Sistemi (opens in a new tab)T.C. İçişleri Bakanlığı Emniyet Genel Müdürlüğüegm.gov.tr
  2. KBS Tesis 2 Bilgi Dokümanı (Sürüm 3, 14 Kasım 2018) (opens in a new tab)T.C. İçişleri Bakanlığı, Jandarma Genel Komutanlığıjandarma.gov.tr

AI Otel EditorialEditorial team

Drafted with AI assistance from AI Otel’s published fact base. Not yet reviewed by an editor.

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