SIBA applies to every foreign guest, children included: what the law actually requires

One of the most persistent myths in the Portuguese short-term rental world: "the accommodation bulletin is only needed for some foreign guests."

It's easy to see where the confusion comes from. The historical context of accommodation bulletins is rooted in border control and the identification of foreign nationals. So it is tempting to assume that only some foreign guests count. But the law makes no such exceptions, and assuming exemptions without checking them can be an expensive habit.

Where the myth comes from

The obligation to collect and report guest data has its roots in immigration and internal security legislation. For years, the practice — and the perception — was that registration existed mainly to track people entering the country from abroad.

When the system was digitalised and SIBA (Sistema de Informação de Boletins de Alojamento) was formally introduced, reporting moved online. The problem is that many hosts settled on their own idea of who has to be reported — and never checked it.

What the law actually requires

SIBA reporting applies to every foreign guest, of any age (children included).

That means a couple from Madrid, a French family with two children and a Brazilian tourist all have to be reported — being an EU citizen, or a minor, creates no exemption. Portuguese nationals, on the other hand, are not reported to SIBA.

The data you're required to collect includes, among other things, guest identification, check-in and check-out dates, and the number of a valid identity document — whether that's a passport, an EU national identity card, or another valid travel document.

A note on accuracy: The precise technical specifications of SIBA — mandatory fields, submission deadlines, receiving authority — are subject to change. SIBA runs on the official platform siba.ssi.gov.pt, within the domain of Portugal's Internal Security System (SSI) — always check it for the version currently in force. What doesn't change is the principle: every foreign guest, with no exceptions for age or country of origin.

Why the mistake keeps spreading

There are a few practical reasons the myth survives:

• Not every foreign guest expects to be registered — travellers from within the EU, or families with children, rarely ask about the bulletin.
• Platforms like Airbnb don't make this distinction explicit for the host — the responsibility to submit the bulletin is always yours.
• Nobody told you otherwise — and in the absence of visible enforcement, the wrong habit quietly takes hold.

The risk of skipping any foreign guest

Failing to submit accommodation bulletins — for any foreign guest, adult or child — is a legal breach. The consequences can include fines and, if an inspection occurs, it can open your AL registration to broader scrutiny.

This isn't meant to alarm you. It's to make one thing clear: "I've never been caught" is not the same as "I'm compliant."

Keeping the process manageable

The good news is that this doesn't have to be complicated. A few practices that help:

Treat every foreign guest the same way

Whether they're from Madrid or Luanda, adults or children, your check-in flow should always include collecting the data needed for the bulletin. Standardise the process and you eliminate the risk of making exceptions you'll later regret.

Automate where you can

AL management tools — including ALerta — let you centralise bulletin submissions without logging into the portal manually for every booking. Less friction, less room for error.

Keep a local record

Beyond submitting to SIBA, it's good practice to maintain your own log of submissions made. If a question ever arises, you have proof of your compliance.

Stay on top of updates

Portugal's short-term rental regulatory framework has been evolving. What's true today may have nuances tomorrow. Follow reliable sources — official bulletins, AL associations — so you're not caught off guard.

The bottom line

SIBA doesn't pick and choose between foreigners. The obligation to submit accommodation bulletins applies to every foreign guest who stays with you, of any age, full stop. If your current process leaves out EU citizens or children, now is the time to fix it.

This isn't bureaucracy for its own sake — it's what the law requires, and in practice it's a habit that becomes effortless once you have the right system in place.