AL licensing after Decree-Law 76/2024: what actually changed
Alojamento Local (AL) — Portugal's short-term rental framework — has been through significant regulatory turbulence since 2022. The "Mais Habitação" package and subsequent Decree-Law 76/2024 reshaped the rules around new licences, zone restrictions, transferability, and reporting obligations. If you're buying a property with short-term rental in mind, these changes directly affect your investment thesis.
This article unpacks what changed, what it means in practice for new buyers, and what due-diligence checks you should be doing before committing to a purchase.
Background: what is Alojamento Local?
AL is the legal framework for short-term accommodation in Portugal, regulated by RNAL (Registo Nacional dos Alojamentos Locais). To legally operate short-term rentals — whether via Airbnb, Booking.com, or direct — you need an active AL licence number, which must be displayed on all listings. Properties without a valid RNAL registration cannot legally host short-term guests.
Until 2022, Portugal operated a permissive regime: any property owner could register for AL with minimal requirements. This led to a rapid expansion of short-term rentals in Lisbon, Porto, and the Algarve, which in turn contributed to housing affordability concerns — the political backdrop for the subsequent restrictions.
What the Mais Habitação law changed (2023)
The Mais Habitação package (Lei n.º 56/2023) introduced several significant changes to the AL framework:
- Suspension of new AL licences in "contention zones" — municipalities could designate areas where new licences would not be issued. Lisbon, Porto, and parts of the Algarve designated large portions of their territory as contention zones.
- Non-transferability of AL licences on property sale — a key provision that sent shockwaves through the market. If you bought a property with an existing AL licence, that licence could no longer be transferred to you as the new owner.
- Increased tax on AL income — the special 35% flat IRS rate on AL income for residents was increased.
- New condo approval requirements — horizontal property buildings (condominiums) could vote to restrict or ban AL activity in the building.
The non-transferability rule was particularly damaging for buyers purchasing already-licensed properties with the intention of continuing AL operations. It effectively stranded the value of the licence with the departing seller.
What Decree-Law 76/2024 changed
Decree-Law 76/2024, published in November 2024, partially reversed the most damaging aspect of the 2023 restrictions: AL licence transferability was restored. Under the new rules:
- Existing AL licences can once again be transferred to new property owners on sale, subject to the licence being in good standing (no suspensions, no outstanding violations).
- The transfer must be formally registered with RNAL within a specified window after the escritura.
- Properties in contention zones retain their existing licence on transfer, but new licences in those zones remain suspended.
- The condo approval and restriction framework remains in place.
Current state: contention zones
As of early 2026, the contention zone map is complex and municipality-dependent:
- Lisbon municipality: the entire historic centre and most inner parishes are contention zones. No new AL licences are being issued. Properties with existing licences can transfer.
- Porto municipality: similar situation to Lisbon — most inner-city areas are designated contention zones.
- Algarve: situation varies by municipality. Lagos, Portimão, and Faro have designated some urban zones as contention areas. Rural and non-contiguous coastal zones remain open to new licences. Always check the specific câmara municipal's latest regulamento.
- Silver Coast, Madeira, Azores: generally more permissive, though individual municipalities are increasingly adopting their own restrictions.
Due diligence check: Before committing to a purchase with AL intent, ask your lawyer to verify: (1) is the property or zone designated as a contention area? (2) does the property have an existing, valid, transferable RNAL registration? (3) has the condo (if applicable) voted to restrict AL activity?
SIBA reporting: tightened obligations
One area where obligations have become stricter post-2024 is SIBA reporting — the guest registration requirement with AIMA (Agência para a Integração, Migrações e Asilo). Under the current rules:
- Guest details must be reported to AIMA within 3 working days of check-in for non-EU guests.
- The reporting must be done via the SIBA portal (Sistema de Informação de Boletins de Alojamento).
- Non-compliance is a regulatory offence with fines ranging from €2,500 to €30,000.
- Property managers running AL on behalf of owners inherit these reporting obligations.
This is not a new requirement — SIBA reporting has existed for years — but enforcement has tightened since 2023, and several property managers have been fined for systematic non-compliance.
VAT obligations for AL operators
Operating AL creates VAT (IVA) obligations, which are frequently overlooked by casual operators:
- Short-term accommodation services are subject to 6% VAT (the reduced tourism rate).
- If your AL turnover exceeds the VAT exemption threshold (currently €14,500 annual turnover for the simplified regime), you must register for VAT and file quarterly returns.
- Annual AL income must also be declared in your IRS (personal income tax) filing.
Tourist tax obligations
Several Portuguese municipalities charge a tourist tax (taxa turística) per guest per night, collected by the AL operator and remitted to the câmara. As of 2026:
- Lisbon: €4.00/person/night (max 7 nights)
- Porto: €3.00/person/night
- Madeira: €2.00/person/night
- Various Algarve municipalities have their own rates (typically €1.50–€2.50)
These amounts are collected from guests and reported/remitted monthly or quarterly depending on volume.
AL and mortgage banks
One frequently overlooked complication: Portuguese mortgage banks treat AL income inconsistently. Most banks discount AL rental income significantly for affordability calculations — some banks exclude it entirely, treating the property as a pure lifestyle purchase. If you're planning to fund a mortgage partly on the basis of AL rental income, discuss this upfront with your mortgage broker before getting too far into a purchase.
What to check during due diligence
If you're buying a property with AL intent, your due diligence checklist should include:
- Check RNAL registration status — verify the licence number, issue date, category (moradia/apartamento/estabelecimento), capacity, and any suspensions
- Check contention zone status with the relevant câmara municipal
- Request condo declaration confirming no AL restriction vote has passed (for apartments)
- Review the property's SIBA compliance history if taking over an operating AL
- Confirm the licence is in the property's name, not the seller's personal name (personal names cannot transfer)
- Verify energy certificate validity (required for AL registration)
- Confirm insurance requirements are met (specific AL insurance required for some configurations)
The bottom line for buyers
The 2024 reforms have created a two-tier market: properties with existing, valid, transferable AL licences command a meaningful premium — particularly in contention zones where new licences cannot be obtained. If AL income is part of your investment thesis, pay close attention to the RNAL registration number in the listing, and have your lawyer verify its status before the CPCV.
The Casa journey dashboard includes specific AL-related tasks for each relevant phase of the purchase process, and we track RNAL renewal deadlines (licences must be renewed every 5 years) in the post-purchase tax calendar.
Sources: Decree-Law 76/2024, Lei n.º 56/2023 (Mais Habitação), RNAL official portal, AIMA SIBA documentation, Sovereign Group AL guide. Regulations change frequently — verify current zone status with the relevant câmara municipal before any purchase decision.