New AL regime for condominiums

… changes are already in effect

New AL post November 15
New AL post November 15, 2023

More than a week ago I promised to post an update to the new AL legislation in respect of its impact on condominiums. I attempted this but held back from publishing it immediately as if became apparent that there were a number of possible interpretations and incorrect advice could mislead apartment owners. Having researched it further, the summary below reflects the current state of play, as of today, with a deadline looming:

At the moment the registration of all AL properties is suspended at the national level, with the exception of the Autonomous Regions of Madeira and the Azores. If in doubt go to the City Hall in Funchal and ask to AL team there for advice – they are a friendly and helpful bunch.

Changes in detail

Changes to the Local Accommodation regime came into force on October 7th this year, particularly referring to AL Units within the context of condominiums. Whilst this will be of little or no interest to visitors to the archipelago, it is of vital importance to a significant number of readers who are actively involved in the holiday rental marketplace locally.

Below are some of the changes to the regime for AL establishments in autonomous units: This summary actually came from Castelogest, who, in my experience of nearly 20 years in the holiday rentals market, has consistently been one of the better condominium companies operating in Madeira.

At the outset, it is best to define what constitutes an AL rental unit in condominiums: this literally translates an “autonomous fraction allocated for habitation in a building subject to horizontal property”.

New Local Accommodation applications:

Registration must be accepted by existing condominium members. The decision is made with the agreement of all condominium owners, including hostels, which are cropping up more around Funchal in particular;

The registration of a local accommodation establishment lasts for five years, renewable for equal periods thereafter. The AL licence is not transferrable to a subsequent purchaser of the property.

A condominium can decline a new AL application

The assembly of condominium owners, by decision of at least two-thirds of the permilation of the building, can oppose the exercise of the accommodation activity location in a fraction, until otherwise decided, except when the constitutive title expressly provides for the use of the fraction for local accommodation purposes or has there was an express decision by the assembly of condominium owners to authorize the use of the fraction for that purpose (i.e. prior approval);

Cancellation of existing AL registrations:

For the purposes of cancelling a registration, under the new AL rules, the condominium assembly gives knowledge of its deliberation to the president of the territorially competent municipal council, taking effect within 60 days after sending of the deliberation, determining the immediate cessation of exploration of the this establishment;

Local accommodation records issued on the date of entry into force of this change, will be reviewed during 2030.

Existing AL licences

Existing AL licences (other than those opening for premises within the confines of the holder’s existing home for less than 120 days per year) within two months of the date above (i.e. of December this year) must register with the municipal authorities to provide proof that are still conducting the activity. Non-compliance will mean that the existing licence is cancelled and the owners will be conducting an illegal activity.

Other changes:

The assembly of condominium owners may determine, by deliberation approved by majority of votes representing the invested capital, WHICH establishments of local accommodation have a permanent telephone contact number emergency, which must be provided to other condominium owners; This is normally done by a prominent sign just inside the entranceways to condominiums.

Owners of local accommodation establishments installed in fractions of autonomous buildings constituted on horizontal property must post signs showing the times set out in the General Noise Regulations on a clearly visible place inside the establishment.

Registration on the new platform

New AL regime for condominiums 1

Registration on the new RNAL platform, under penalty of registration expiry due to inactivity, is required, as outlined above, by Dec 7th this year. The website address is https://eportugal.gov.pt/entrar

Some owners may choose to ask their property management company, accountant or solicitor to do this on their behalf, as not all have the necessary access with a Cartão de Cidadão


An extraordinary contribution was created on the apartments and accommodation establishments integrated into an autonomous building fraction in local accommodation (CEAL), but the revenue reverts to the Tax Authority. For the condominium, the previous rules remain the same!

More information

New AL regime for condominiums 3

More information, which is being widely replicated on other websites, and be found on the ALEP website here

2 thoughts on “New AL regime for condominiums”

  1. Admin, a very nice, detailed post. There are far too many AL rentals on the market, and I would imagine many will go into long-term rental in the near future.

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