The electronic complaints book in local accommodation: what hosts need to know

The paper complaints book — that red-covered binder that had to be visible, accessible, and properly filled in — was a familiar headache for many hosts. The electronic version modernised the process, but it didn't make the obligation disappear. If anything, it extended it.

If you manage a local accommodation operation with a significant number of units, it's worth understanding whether you're already in scope — and if you are, how to comply without turning it into an operational burden.

What is the electronic complaints book?

The electronic complaints book (livro de reclamações eletrónico) is a platform managed by the Directorate-General for Consumer Affairs (Direção-Geral do Consumidor) that allows guests to submit complaints online, without needing to be physically present at the property. On the operator side, there's a management portal where you can monitor and respond to any complaints received.

The logic is straightforward: a guest visits the portal, identifies your establishment, and submits their complaint. You receive a notification, have a set period to respond, and the entire exchange is recorded — with visibility for the relevant regulatory bodies.

Who does it apply to in local accommodation?

This is the point that trips up most hosts: the electronic complaints book obligation doesn't apply to all AL operators in the same way.

Portuguese legislation sets a threshold based on the size of the establishment. For local accommodation, that threshold is linked to the number of accommodation units. Operators above that threshold are required to join the electronic system — and simply keeping a physical book alongside it may no longer be sufficient.

Important note: The legislation in this area has been evolving, and the exact thresholds can be updated. Before assuming you are — or aren't — covered, always confirm your situation directly with the Direção-Geral do Consumidor or a specialist lawyer. Don't rely on outdated articles or forum posts.

If you have a single apartment or a standalone villa, you're likely still in the physical book regime. If you operate a portfolio of units under the same RNAL registration or the same operating entity, the chances are higher that you're already within scope of the electronic regime.

How to register

Registration is done through the official portal at www.livroreclamacoes.pt. The general process runs as follows:

1. Entity registration — you'll need to identify your establishment using your RNAL details and the tax information of the operating entity.
2. Validation — the Direção-Geral do Consumidor confirms the registration.
3. Access to the management portal — from there, you can monitor complaints, respond within the legal deadlines, and keep your history organised.

The portal has improved over the years, but it's still a government interface — functional, not pretty. Set aside some time for the initial setup and to get familiar with where everything lives.

What do you need to communicate to guests?

Once registered, you're required to inform guests that the electronic complaints book exists. In practice, that means:

• Including a reference to the complaints book in your property information (guest manual, on-site notice, or digital communication).
• Providing the portal address www.livroreclamacoes.pt where guests can submit complaints.
• Keeping the physical book available if you're still required to maintain it in parallel — confirm this for your specific category directly with the Direção-Geral do Consumidor.

Fitting this into your day-to-day operations

The real risk isn't registration — it's forgetting about it. A complaint submitted and left unanswered beyond the legal deadline can have consequences with the regulatory authorities. And unlike the physical book sitting in a drawer, the electronic system generates notifications that need attention.

Practical habits to keep nothing slipping through

• Set up email notifications to an address you check daily — don't use a contact email you open once a week.
• Define a response process: who responds, within what timeframe, and in what tone. Even if you're managing everything yourself, having a basic response template saves time and keeps things consistent.
• Log complaints in your own system — whether that's a spreadsheet, a simple CRM, or a note in your property management software. Having your own organised record makes things much easier if you ever need to demonstrate your compliance history.
• Check the portal periodically, even when you have no pending notifications. Notification emails have a habit of ending up in spam.

What if you receive an unfair complaint?

It happens. The process allows you to present your version of events. Always respond with facts, without a defensive tone, and within the deadline. A well-structured response — even to a complaint you consider unfounded — demonstrates professionalism and stays on the record.

Keeping up as the rules evolve

Local accommodation regulation in Portugal has been in motion. Thresholds for mandatory compliance, response deadlines, and display requirements can all be adjusted by new legislation. The sensible approach is:

• Review your situation whenever you change scale — for example, when you add new units to your portfolio.
• Keep an eye on communications from the Direção-Geral do Consumidor and Turismo de Portugal.
• Don't assume that what was true two years ago still holds today.

The electronic complaints book is, at the end of the day, one more piece of the compliance puzzle that a professional AL operator has to manage. It's not complicated — but it does require attention and a minimum process to make sure deadlines don't slip past you.