EU Short-Term Rental Regulation 2024/1028 in Portugal: What Applied on 20 May 2026 and What Did Not Change

What applied on 20 May 2026, and what applied in 2024

Regulation (EU) 2024/1028 on data collection and sharing relating to short-term accommodation rental services was adopted on 11 April 2024 and published in the Official Journal on 29 April 2024 (EUR-Lex). Article 19 says it enters into force on the twentieth day after publication and applies from 20 May 2026. That puts entry into force on 19 May 2024, a date we derived because the text states none. A corrigendum was published in the Official Journal on 22 September 2026 (OJ L 2026/2099). Its content sits behind a paywall and we have not read it, so the article numbers below are subject to that check.

The second point of precision is scope. The Regulation is opt-in at Member State level. Registration is required only where a Member State has a registration procedure, and the Commission's own notice of 20 May 2026 says Member States "are not obliged to apply it" (European Commission). Press reports that it is "in force across Europe" overstate that. Portugal has a procedure, the national register for local accommodation known as RNAL, so the platform duties apply to listings in Portugal. Hotels and campsites are outside the definition of a rental unit.

The third point is a deadline that fell on the same day. Article 15(4) obliged Member States to adopt and publish their penalty rules by 20 May 2026 and notify the Commission. We found no Portuguese act that does so, and the Commission has published no country-by-country readiness list. Airbnb said on 4 May 2026 that it "is ready to comply" but is concerned that not all Member States are, and that it has invested in national registration schemes in Spain, Italy and France only (Airbnb Newsroom). Portugal is not named in that statement.

What Portugal already had

RNAL dates from Decree-Law 128/2014. A host files a prior communication on the Balcão Único Eletrónico, the municipality has 60 or 90 days to object, and the number issued is the only valid title to operate. The number must appear in advertising and on platforms, and offering an unregistered listing is prohibited. When a municipality cancels a registration, the host has 10 days to tell the platforms. All of this is described in the Turismo de Portugal guide of January 2025. The regime has been amended by Decree-Law 63/2015, Law 62/2018, Decree-Law 9/2021, Law 56/2023 and Decree-Law 76/2024, published on 23 October 2024.

Two other pieces of machinery were also in place. Platform income reporting to the tax authority runs through Law 36/2023, which transposes the EU's DAC7 directive (Madeira Corporate Services). Enforcement of the register belongs to ASAE and the municipalities, with the tax authority covering tax. The insurance rule from Decree-Law 76/2024 is the legal ground Lisbon used to cancel 6,765 registrations in February 2026, as we set out in our licence purge analysis.

Fines are less clear than they should be. The Turismo de Portugal guide tabulates serious offences at €650 to €1,500 for individuals and €1,700 to €24,000 for companies, and light offences at €150 to €500 and €250 to €12,000. An English-language guide for foreign owners quotes fines of up to €40,000 for operating without registration. We could not trace that figure to the Diário da República, so we treat the ranges as unresolved. No new Portuguese penalty regime for the Regulation was found.

What is genuinely new: monthly data and random checks

The new layer sits on the platforms and on the state. Under Article 7, a platform must ask each host to declare whether registration applies, display the registration number on the listing and run reasonable random checks. Article 9 requires the platform to send activity data to the national single digital entry point every month, machine to machine: the number of nights, the number of guests, the registration number, the address and the listing URL. A platform that averaged fewer than 4,250 listings in the previous quarter may report quarterly and, if national law allows, manually.

Article 10 obliges each Member State with a registration procedure to build that entry point, with an application programming interface that also supports the random checks. Under Article 6 the competent authority can verify a registration at any time, suspend or withdraw a number, and order a platform to remove the listing, after a hearing. Article 12 names the national entity that passes activity data on to Eurostat for statistics. Under Article 15, the Digital Services Act enforcement regime covers the platforms' duties to display numbers and check declarations, while the authority designated for the entry point enforces the rest.

For a host in Lisbon or Albufeira this changes little on day one. For the state it changes who knows what. Today a municipality knows how many registrations exist and, after the 2026 clean-up, which ones carry valid insurance. It does not know which of them host guests, or for how many nights. Lisbon's containment ratios in our containment-zone explainer are built from registrations over dwellings, so a registered unit that never takes a guest counts exactly like one that is let every night. The Regulation lets authorities check activity against registrations. It does not tell municipalities what to do with the result.

The gateway nobody has announced

We searched for a Portuguese act designating the entry point, the competent authorities, the monitoring authority or the Eurostat entity, and found none. Decree-Law 151/2026 is not that act, despite appearing in some searches on the topic. It was dated 29 July and published on 30 July 2026 in Diário da República n.º 146/2026, Série I (LexPoint). It lets municipalities with more than 1,000 AL registrations at 31 December 2025 decide until 31 December 2026 whether to use their regulatory power under article 4(6) of Decree-Law 128/2014, and extends or adds suspensions of new registrations under article 15-B(2) to no later than the same date. According to Imojuris it does not change the AL regime, has no retroactive effect and does not touch existing registrations. We read summaries rather than the Diário text.

The only trace of the gateway is a procurement listing. An aggregator, Mercell, shows a Turismo de Portugal tender for development, maintenance and support of an "SDEP" platform required under the Regulation: published 17 September, closing 12 October 2026, valued at €380,000 over 24 months (Mercell listing). We could not confirm it on the EU's TED portal or on base.gov.pt, and the year is inferred from the listing. If it is accurate, the platform was still being contracted five months after the application date. A 24-month support contract does not by itself fix a go-live date, and we draw no conclusion about one.

Nor is Portugal visibly alone. A search of the Commission's June and October 2026 infringement packages found no entry on Regulation 2024/1028, although we read only part of the October summary and a July page was paywalled, so we do not assert that none exists. The Commission has published a 20 May press item and no readiness list. The Regulation has its own review clock: Article 18 sets a Commission evaluation by 20 May 2031, which is to consider whether an EU-level central entry point is needed.

The data the gateway will replace

Today's platform data come from Eurostat's experimental series. Airbnb, Booking.com and Expedia supply it under agreements dating from 2020, Tripadvisor left after the end of 2024, and Eurostat's metadata page states only that the Regulation "applies from May 2026" without giving a first release date for Regulation-sourced data (Eurostat metadata). Quarterly national figures arrive about a quarter after the period and regional figures later. The latest regional values for Portugal are for the first quarter of 2026 (Eurostat news, 2 October 2026).

Three readings stand out. Portugal's platform nights rose 59.4% between 2019 and 2025, and the Algarve's rose 67.5%, so the Algarve now holds 27.0% of the national total (derived). The Lisbon metropolitan area, which Eurostat codes PT170, grew only 12.1% between 2019 and 2024 and has no 2025 value in the extract we pulled. That fits the plateau we describe in our Lisbon statistics article and sits against the regional picture in the Algarve edition. Foreign guests accounted for 42,491,886 of the 49,503,189 nights in 2025, or 85.8% (derived).

Portugal's first-quarter 2026 platform nights were 6,646,773 against 6,337,309 a year earlier, up 4.9% (derived from the monthly series). A secondary aggregator reports 14,013,636 nights and growth of 2.6% for the second quarter. We could not confirm that on Eurostat's own page and treat it as unverified. Eurostat's 2 October 2026 release puts the EU second quarter at 258.8 million nights, up 5.3%. The Commission and secondary reports put the EU's 2025 total at 951.6 million nights, which would make Portugal 5.2% of it (derived, using the secondary EU figure).

These platform counts cannot simply be set beside INE's. INE counted 11,977,521 nights in alojamento local establishments with 10 or more beds in 2025, 14.6% of the nights in tourist accommodation, as we report in our AL versus hotels analysis. Dividing platform nights by that figure gives 4.1 times (derived), but Eurostat warns the two series cannot be added or compared directly. Platform nights include hotels listed on Booking.com and small units that INE does not survey. The Regulation's data will be the first to attach nights to individual registration numbers, which would settle how much of the platform total is registered AL. Scope traps of this kind recur in the islands. In the Madeira edition the regional statistics office counts 3.8 million AL nights against INE's 1.00 million.

The register the gateway will check against

The register has been shrinking since the end of 2025, and the sources do not reconcile. Press reports put it at about 125,000 in October and November 2025 and about 126,000 at the end of the year. Our earlier series carried 126,320 for December 2025, a figure we could not find in any source and now drop. Idealista reported in April 2026 a fall from about 126,000 to about 119,000 by March (idealista). Diário de Notícias then gave 119,147 active registrations in June 2026, after 10,324 cancellations by municipalities (DN, ECO). Subtracting 10,324 from 126,000 gives about 115,700, so roughly 3,500 registrations (derived) are unexplained by either series.

The cancellations are concentrated. Lisbon cancelled 6,765 registrations, 35.6% of about 19,000 (derived) and not the 40% in some headlines. Lagos cancelled 1,548 of 6,071 (25.5%), Porto 1,413 leaving 10,821, and Lagoa 598 of 3,755. Those four councils sum exactly to the 10,324 national total, so there is no published count for Albufeira, Loulé, Portimão, Faro, Funchal, Cascais or Sintra. The grounds were insurance and inactivity, depending on the report. The association ALEP says more than 37,000 active registrations had not yet submitted insurance proof and expects about 30,000 further cancellations, leaving 88,000 to 93,000. Those are projections, not measurements.

A cancelled registration is not a closed business. The residents' association Vizinhos em Lisboa cross-referenced the register with the 2021 Census and counts 11,704 Lisbon registrations in October 2026, down 37%, with 332 new units since 2023 (Opção Turismo/Lusa). Its booking tests found that at least 4% of analysed units kept taking guests after cancellation. It is an advocacy count, but it points at the gap the gateway is supposed to close. Our licence purge analysis reaches the same conclusion from platform data: Grande Lisboa platform nights fell only 3.1% in the first quarter of 2026 after the register lost more than a third of its Lisbon entries.

How Portugal compares

Portugal's position is unusual. Its register is old, large and recently cleaned, and its gateway is unannounced. Most peers have the reverse: a gateway or registry under construction on a newer foundation. The comparison below uses the status as of 24 October 2026 and counts only what a named source published.

Spain is the cautionary case. Its national Registro Único de Arrendamientos, created by Royal Decree 1312/2024 and mandatory from 1 July 2025, was annulled by the Supreme Court on 19 May 2026, the day before the Regulation applied, in judgment 620/2026. The court upheld the digital single window (Cuatrecasas). Spain's removal figures also need care. The Ministry of Consumer Affairs said in July 2025 that Airbnb withdrew about 65,000 listings and that another 54,728 were flagged without a number (El Salto). The Housing Ministry separately ordered 53,876 withdrawn in September 2025, although the body text of the Hosteltur report says 53,786, and 53,786 does equal 20.3% of 264,998 applications. These are two actions and should not be added together.

The registry's first months showed how many hosts fail a registration test. Of 68,594 applications in July and August 2025, 34,529 were revoked, or 50.3% (derived), per a Forbes España report of 2 September 2025. Italy's national identification code has been mandatory since 1 January 2025, with fines of €800 to €8,000 for operating without it, and 447,000 codes were issued by 31 December 2024, about 78% of a roughly 570,000 base. France plans a national registration service for the fourth quarter of 2026. Croatia has no EU-style number in the 2026 season. Ireland postponed its register to open on 1 December 2026, and the Dutch implementing act of 8 July 2026 takes effect on a date to be set by royal decree.

The ratio column deserves a caution. Platform nights divided by survey nights is 55.4% for Portugal, 45.1% for France, 44.3% for Croatia and 25.9% for Italy on our reproduction of the Eurostat data. It is a measure of how much platform activity exists relative to the surveyed stock, not a market share, because the two sources overlap. Spain's 36.9% and Greece's 33.4% come from our earlier series and could not be reproduced in this round.

Dates and signals to watch

Several clocks run through the end of the year. Municipalities above the 1,000-registration line have until 31 December 2026 to use their regulatory power under Decree-Law 151/2026. Ireland's register opens on 1 December. France's national service is due in the fourth quarter. The Commission proposed an Affordable Housing Act on 9 September 2026, to which ALEP replied that restricting AL "does not solve the lack of homes". The proposal is separate from Regulation 2024/1028 but will shape what authorities do with the data the Regulation produces.

Four signals would change our assessment. The first is an award notice for the SDEP tender on TED or base.gov.pt. The second is a Diário da República act designating the entry point, the competent authorities and the Eurostat entity, together with Portuguese penalty rules. The third is a platform help page stating that monthly transfers to Portugal have started. The fourth is a first Eurostat release that cites the Regulation as its data source.

What this means for travellers, businesses and analysts

Travellers. Every legal AL listing in Portugal already carries an RNAL number, and asking the host for it is a reasonable check. We found no published evidence that guest bookings were cancelled because of the Regulation, and no evidence that it changed prices. Where the register shrank, as in Lisbon, the legally registered stock is smaller, which matters most in the central parishes covered in our Lisbon accommodation guide.

Tourism businesses and investors. Hosts should assume that once the gateway runs, nights per registration number will be visible to authorities, so insurance proof, tax declarations and booking records need to agree. For underwriters, the sequence matters more than any single rule: the register clean-up has so far been reported for only four councils, municipal decisions fall due on 31 December 2026, and the first national data transfer has no date. Containment ratios and licence values in Lisbon, Porto and the Algarve could move when activity data replace registration counts. The alternative reading is that nothing changes until the entry point is live, and that is what the evidence supports today. This article is not legal or tax advice.

Journalists and analysts. Safe to cite: the Regulation was adopted on 11 April 2024, published on 29 April 2024 and applies from 20 May 2026; Portugal's platform nights were 49,503,189 in 2025 (Eurostat); RNAL held 119,147 active registrations in June 2026 (DN); and four councils cancelled 10,324 registrations. Do not repeat that the Regulation "took effect" on 20 May 2026, that it introduced a registration number in Portugal, that Portugal now has a single national register under it, that Decree-Law 151/2026 implements it, or any count of listings removed by platforms in Portugal because of it, since none has been published. The series finding this article adds is a new kind of gap: a data channel that exists in law, has a procurement trace and has no published operator.