In what is the first move of its kind, officers from the Civil Guard detained the pair on suspicion of encouraging holidaymakers to make dishonest compensation claims.
The two, who have not been named, are believed to be linked to a firm that offers no-win, no-fee solicitors to those who claim, once they have returned to the UK, that they were too sick to leave the hotel room.
Last month Spain's hotel industry announced new measures to protect themselves against fraudulent food poisoning claims that cost the industry more than €60 million last year alone.
The head of the Spanish hotel owners association (CEHAT) announced that fake insurance claims by British holidaymakers on all-inclusive deals will now result in immediate prosecution.
The number of sickness claims rose by 700 per cent in 2016, the head of CEHAT Secretary General Ramon Estalella said on Tuesday at a meeting of the hotel sector at the Ministry of Tourism in Madrid, which included delegates from the Association of British Travel Agents (ABTA).
The scam that really hit Spain during the summer of 2016 involves British tourists claiming that they suffered food poisoning while eating at hotels in Spain in a bid to get their money refunded.
Typically the claims come from those who wait until they have returned to the UK – too late to obtain proof of the food poisoning from a local Spanish doctor – and then file cases with small claims courts or complain directly to their tour operators.
The behaviour has been actively encouraged by some unscrupulous no-win, no-fee solicitors who tout for business at popular tourist resorts across Spain's costas.
There have been reports of lawyers even operating mobile “claims clinics” in vans parked outside all-inclusive hotels.
Around 90 percent of all claims received by tour operators are thought to be false, but hotels have had no line of defence, until now.
Among the “stringent measures” to be implemented this year will be a ‘traceability' scheme that will see guests have their consumption of food and drink tightly monitored.
This will allow hotels to prove that details contained in the claims did not meet with the behaviour of the holidaymakers in Spain - effectively they can prove that when the holidaymaker claimed to be lying sick in bed, they were really still consuming meals and drinks on the premises.
Hotels will also start a campaign involving the distribution of leaflets explaining that false insurance claims constitute a ‘criminal offence' in Spain.
False claimants will potentially face jail sentences of six months to three years and steep financial penalties.
CEHAT claims that there the system is flawed because “according to the British officials themselves, it is cheaper to deal with the claims quickly rather than enter into expensive legal process,” the association said in a statement.
“Tour operators also use a dominant market position to impose contracts under which hoteliers become responsible for all types of claims.”