AIMA and AT are stepping up AL inspections: what you need to have in order

Enforcement of short-term rental rules in Portugal has shifted from background noise to something hosts are actually encountering. AIMA — which took over from SEF on immigration control — coordinates operations with the PSP and GNR, while the Tax Authority (AT) increasingly works by cross-referencing what hosts declare with data it receives directly from booking platforms. The practical upshot: it's easier than ever to be flagged as non-compliant, even if no one has ever knocked on your door.

No need to panic. But there is every reason to get your house in order.

What's changing in enforcement

The transition from SEF to AIMA wasn't just a rebrand. It brought a reorganisation of responsibilities and, with it, tighter coordination between agencies. The PSP and GNR still carry out on-the-ground checks — they can show up at a property and ask for documentation on the spot. AT, meanwhile, is increasingly data-driven: platforms are required to report host revenues, and that data-matching makes it straightforward to spot gaps between what was declared and what was actually received.

The risk profile has also broadened. It's no longer just the operator with no registration. It now includes the registered host who slips on the operational details — a missing complaints book, a guest not reported to SIBA, an expired insurance policy.

The essential checklist

1. Registration in the RNAL

The National Local Accommodation Register is the starting point. Without a valid registration number, nothing else matters — and the fine for operating without one is among the heaviest in the regime. Check that your registration is active, that the category is correct (villa, apartment, guesthouse or room), and that the number appears on all your platform listings.

If you've changed property, category or titleholder, the registration needs to be updated. An outdated registration can be treated the same as no registration at all.

2. Guest reporting to SIBA

This is the most common failure — and, paradoxically, one of the easiest to fix. SIBA is the SEF/AIMA platform where you must report the details of each foreign guest (and in some contexts, domestic guests too) within the legally required window after check-in.

The problem is that most hosts do this manually, which means one last-minute booking or a busy weekend is all it takes for the submission to slip. AIMA has access to these records and can check whether guests were staying without a corresponding report.

What you need in place:

• Active access to the SIBA portal
• A clear process for collecting guest data at check-in
• A habit — or automation — of submitting within the deadline

3. Civil liability insurance

Civil liability insurance is mandatory for all local accommodation properties. It's not optional, it's not replaced by a standard home contents policy, and its absence can be checked during an inspection.

Verify that your policy is current, that it specifically covers short-term rental activity, and that the minimum guaranteed capital meets the legal requirements. Keep a copy accessible — physically at the property and digitally in case you're asked to produce it.

4. Complaints book

Mandatory. It can be physical or electronic (the electronic version is accepted and, in practice, easier to manage). It must be available to guests on request, and a notice about its existence must be visibly displayed in the property.

An in-person inspection will check for this. It's a small detail, but it's exactly the kind of thing that generates an unnecessary infraction notice.

5. Mandatory information display

Inside the property, a set of information must be visibly posted: the RNAL registration number, maximum occupancy, emergency contact, and reference to the complaints book. Many hosts have their registration sorted but forget to display the required elements.

A laminated sheet at the entrance or in the kitchen solves the problem.

6. Income declaration to AT

AT cross-references platform data with IRS or IRC declarations. If you received AL income and didn't declare it — or declared a figure significantly different from what the platforms reported — you're exposed to an additional assessment, with interest and fines.

The tax treatment of AL has its own specifics (taxation coefficients, simplified regime versus organised accounting) that are worth reviewing with an accountant. What isn't worth doing is ignoring the declaration or understating income.

How to reduce the risk of gaps

Most irregularities don't happen through bad faith — they happen through distraction. You have bookings across multiple platforms, check-ins at different times, and the SIBA submission gets pushed to later. Later never comes.

A few simple habits help:

• Centralise your documentation in one place (a physical folder at the property plus a synced digital folder): RNAL registration, insurance policy, SIBA access, electronic complaints book.
• Build a check-in process that always includes collecting guest data and submitting to SIBA — ideally on the same day.
• Schedule an annual review to confirm your insurance hasn't lapsed, your registration is current, and no legislative changes affect your situation.
• Talk to your accountant before peak season, not after.

A note on the platforms

Airbnb, Booking and other platforms are required to report host data to tax authorities. That's not new, but many hosts still haven't fully absorbed what it means in practice: AT knows your AL income before you file your IRS return. The window for accidental — or deliberate — omissions is getting narrower.

That's not necessarily bad news. It means that hosts who are compliant have nothing to worry about. But it does mean that compliance needs to be genuine, not just formal.

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Enforcement has intensified, but the rules haven't changed dramatically. What has changed is the capacity to detect who isn't following them. For hosts already operating properly, that's a good thing — it levels the market. For those with gaps, this is the right moment to close them.