Regulation (EU) 2024/1028 of the European Parliament and of the Council, of 11 April 2024, on data collection and sharing relating to short-term accommodation rental services, enters into application on 20 May 2026. The Regulation does not create a new licensing layer. It standardises the data infrastructure through which Member States enforce the licensing rules they already have, and from 20 May the platforms Airbnb, Booking.com, Vrbo and others within scope, operate on the same data-collection, validation and reporting obligations across all 27 Member States. For Portuguese alojamento local, the practical consequence is that an unregistered or improperly registered listing becomes systematically removable at the platform layer, not only at the level of municipal enforcement. This note sets out what changes, who carries the obligation, and the operational checklist a Portuguese alojamento local (AL) operator, resident or non-resident, should run before the date.
What the Regulation actually does
The Regulation builds a common data architecture on top of the national licensing regimes Member States already operate. Three building blocks are decisive.
First, the registration number. Every short-term rental unit must be registered under the relevant national procedure and obtain a registration number. In Portugal, the procedure remains the Registo Nacional de Alojamento Local (RNAL) operated by Turismo de Portugal, with the regional implementing rules in the Autonomous Region of Madeira run through the Direção Regional do Turismo and the competent municipal authority. The Regulation does not change the substance of national licensing, it makes the registration number the operative identifier on which the rest of the system runs.
Second, the platform’s verification and display duty. Online short-term rental platforms must collect the registration number for every listing, display it publicly on the listing page, conduct random validity checks against the national register, and suspend or remove listings where the number is invalid, missing or fraudulent. Platforms that fail to operate the validity-check protocol are themselves exposed to enforcement by the competent national authority.
Third, the Single Digital Entry Point. Each Member State must establish a Single Digital Entry Point (SDEP), the gateway through which platforms transmit activity data to the competent national authority. Large platforms (4,250 listings or more in the relevant jurisdiction) transmit monthly; smaller platforms quarterly. The data transmitted includes the registration number, the URL of the listing, the address of the unit, the number of nights rented and the number of guests per night. The SDEP automatically routes the data to the competent enforcement authority. Member States must, by the same 20 May 2026 date, eliminate any duplicative national registration channels that the Regulation displaces.
Where Portugal sits at the date
The Portuguese RNAL framework, governed by Decree-Law 128/2014 as amended (including by Law 56/2023, the Mais Habitação package, and subsequent amendments), continues to set the substantive licensing rules: the conditions under which a property may be registered as AL, the contention-zone restrictions in Lisbon, Porto and other municipalities, the categorisation (estabelecimento de hospedagem, moradia, apartamento, quartos), the obligations of the operator. Madeira’s regional regime applies in parallel within the Region’s competence. The Single Digital Entry Point and the platform-side validation duty operate on top of all of this.
For non-resident owners operating Portuguese AL units, two further national-level conditions remain: a Portuguese fiscal number (NIF) and, where the owner is a third-country resident outside the EU/EEA, a fiscal representative under Article 130 of the CIRS and Article 19, no. 6 of the LGT. Both are conditions of holding a tax-side compliant AL operation, and both are relevant to the platforms’ validity check, which is keyed to the registration record at Turismo de Portugal (and in the Madeira case, to the regional authority’s records).
The tax-side coordination
The data flowing into the SDEP from 20 May 2026 does not stop at the Single Digital Entry Point. Two parallel reporting streams are already in operation and will increasingly cross-reference each other:
- Council Directive (EU) 2021/514 (DAC7), transposed in Portugal by Lei n.º 36/2023, of 26 July, has required platform operators since 1 January 2023 to report sellers’ income from short-term rentals (and other in-scope activities) to the Autoridade Tributária. The first reporting cycle ran on 31 January 2024.
- Council Directive (EU) 2020/284 (CESOP), in force since 1 January 2024, requires payment service providers to transmit cross-border payment information to a central EU-level system. CESOP is keyed on the payment leg, DAC7 on the platform leg; from 20 May 2026, EU Regulation 2024/1028 adds the registration-and-activity leg.
The practical implication is that, for any Portuguese AL operator using one of the major international platforms, a discrepancy between the platform-side activity report, the DAC7 income report, the CESOP payment report and the Portuguese AT filings (Modelo 3 with Anexo B for Category B residents, Modelo 30 and Modelo 39 for non-resident withholding) becomes mechanically detectable. The defensible position before 20 May is one in which all four data sources align.
The Madeira angle
Alojamento local is a material activity in Madeira‘s residential property market, particularly in Funchal, Calheta and Santa Cruz, and a significant share of the regional AL stock is held by non-resident owners. For Madeira-based AL operations, the operational considerations at 20 May are the same as on the mainland, with two regional specificities to verify. First, that the RNAL entry and the regional Direção Regional do Turismo records are mutually consistent, the platforms validate against the national RNAL, and a properly opened regional file should be reflected there. Second, that the IMI / AIMI / IMT reporting on the underlying property is itself current, given that the platforms’ activity transmissions to the SDEP will be available to AT through the standard inter-administrative cooperation channel and any property-side anomaly is straightforwardly cross-referenced.
The operational checklist before 20 May
For an AL operator, resident or non-resident, the position to be in tomorrow is one in which the registration record is current, the platform listing carries the correct registration number, and the tax-side reporting reconciles to platform-reported activity. Concretely, this means:
- verify the validity of the RNAL number (or the regional Madeira equivalent) on the Turismo de Portugal portal;
- confirm that the registration number displayed on each platform listing matches the registration record exactly;
- confirm that the title holder, the operator and the NIF on the registration are consistent with the operator profile on the platform; for non-resident owners, confirm that the fiscal representative appointment (where required) is current at AT; and reconcile the 2024 and 2025 Modelo 3 / Modelo 30 / Modelo 39 filings against the underlying platform-side income reports, rectifying any gap before the platforms start cross-feeding 2026 data to AT in the routine course.
Where MCS can assist
MCS can assist Portuguese alojamento local operators, resident and non-resident, mainland and Madeira-based, with the pre-application operational review, with the tax-side reconciliation of platform-reported activity to AT filings, and with the structuring decisions that often surface when these reviews are done (operating in personal name versus through a Portuguese company, the choice between Category B / transparent regime / company form for the income, the IMT and IMI implications of any restructuring). For non-resident operators considering Madeira incorporation as the holding structure for AL real estate, MCS can assist with the comparative analysis of mainland ordinary regime versus MIBC-eligible structures, subject to the territorial scope of the MIBC benefit and to engagement scope.
The 20 May 2026 date does not, in itself, change a properly registered, properly listed and properly reported AL operation. What it changes is the cost of any pre-existing gap between the registration, the listing and the AT filing. The post-20-May enforcement layer is mechanical, and a discrepancy is easier to detect at the SDEP than at municipal level. The disciplined operational position is to confirm the alignment now, not after a platform-side suspension or an AT cross-reference notification has issued.
This note is provided for general information purposes only and reflects a high-level understanding of the legal and tax framework applicable as at the date of publication. It does not constitute, and should not be construed as constituting, legal, tax, regulatory, accounting, investment or other professional advice.
The matters addressed herein are necessarily subject to the specific facts and circumstances of each case, including the location of the property, the legal status of the operator, the relevant municipal or regional rules, the applicable tax residence position, the platform used, and the operator’s existing compliance history. No action should be taken, or omitted, solely on the basis of this note without first obtaining specific professional advice.
Although reasonable care has been taken in preparing this note, no representation or warranty, express or implied, is made as to its completeness, accuracy or continued applicability. Legislative, regulatory, administrative and platform-level requirements may change, and their interpretation or implementation by the competent authorities may differ from the position described herein.
The publication of this note does not create a client relationship, mandate or duty of care between Madeira Corporate Services and any reader. Madeira Corporate Services accepts no liability for any loss, damage, cost or expense arising from reliance on, or use of, the information contained herein, except where expressly agreed under a separate written engagement.
Miguel Pinto-Correia holds a Master Degree in International Economics and European Studies from ISEG – Lisbon School of Economics & Management and a Bachelor Degree in Economics from Nova School of Business and Economics. He is a permanent member of the Order of the Economists (Ordem dos Economistas)… Read more
