Guest registration: the accommodation bulletin

The accommodation bulletin (boletim de alojamento) is the report that anyone providing paid accommodation, from hotels to short-term rentals, must send to the authorities when a foreign citizen stays with them. It is a security and border-control requirement: the State wants to know who is staying in the country and where.

The obligation is not specific to short-term rentals, and it is not new. Its legal basis is Law no. 23/2007 of 4 July (the law on the entry, stay, exit and removal of foreign nationals), articles 15 and 16. Article 16 is clear: companies running hotels, complementary accommodation or tourist complexes, and anyone else who provides accommodation for payment, must report the stay of foreign citizens.

Keep one point in mind from the start: the obligation applies to foreign guests. Guests with Portuguese nationality are not reported through this channel. According to most sources, "foreigner" includes citizens of the EU and the Schengen area, not only people from outside Europe. If you are unsure about a particular nationality, check the official source before assuming a guest is exempt.

Paper bulletins are a thing of the past. Ordinance no. 287/2007 of 16 March created SIBA (Sistema de Informação de Boletins de Alojamento), the online platform where accommodation providers submit their bulletins. It is the official channel, and you need to register on it before you can start reporting.

To use SIBA, the establishment must first be registered as a user. After that, for each foreign guest you create and submit a bulletin with the required identification details (name, ID document, nationality, arrival and departure dates, among others). The system keeps a record of each report.

In practice there are two ways to do it. You can enter each bulletin by hand on the SIBA portal, or connect SIBA to your property management system (PMS) or channel manager so it sends the data without you typing it all again. If you have many guests or several units, the automatic route saves time and reduces mistakes, but the legal duty to report is still yours, whatever tool you use.

The legal deadline is three business days. Business days exclude weekends and public holidays, so in practice you may have a little longer than three calendar days. Don't count on it, though: report early.

Many operators miss one detail: the law also requires you to report the departure. Under article 16, the foreign guest's stay is reported within three business days and, once they leave, the departure is reported within the same deadline. In SIBA, you add the departure date to the same bulletin on the day of check-out.

A habit that works is to report on the day of check-in, using the details you collected when the guest booked. You never have to remember it days later, and this is where having the guest's details in advance makes the biggest difference.

For years, bulletins went to SEF (Serviço de Estrangeiros e Fronteiras, the former Immigration and Borders Service). SEF was dissolved in 2023 by Decree-Law no. 41/2023, and its powers were split between other bodies. This is the part that causes the most confusion, so it helps to take it one piece at a time.

Powers over foreign nationals and migration went to AIMA (the Agency for Integration, Migration and Asylum), which is why you will hear people talk about the "AIMA bulletin". SIBA did not move to AIMA, though. Since SEF was dissolved on 29 October 2023, SIBA has been run by the UCFE (the Coordination Unit for Borders and Foreigners), part of the Internal Security System (SSI), and that is where bulletins are sent. The law says the report goes to the GNR or the PSP, the two national police forces (article 16 of Law no. 23/2007).

For an AL operator, the key point is simple: the system (SIBA), the duty and the deadline are all the same. The move from SEF to the UCFE did not change when or how you report. Because agencies and portals can change name or address, always check the current channel on the official SIBA portal before you register.

Skipping the report is not a harmless slip. Failure to report a stay is an administrative offence under Law no. 23/2007, punishable by a fine, and the fine generally applies per missing bulletin. In a property with many guests, that adds up quickly.

The actual amounts depend on the rule that applies, on whether you are an individual or a company and on the degree of fault, and they can be updated, so we don't quote a figure here as definitive. According to sources that cite the regime, fines range from a few hundred to several thousand euros per missing bulletin, and they are higher for companies. Check the rules and current amounts at the official source or with a lawyer.

Data cross-checking has also raised the risk. The authorities increasingly compare SIBA data with the RNAL (Registo Nacional de Alojamento Local, the national register of short-term rentals) and with the invoices reported to the Tax Authority. An active AL that issues invoices but has no bulletins on record is an easy inconsistency to spot. Enforcement has become more systematic: complying was never optional in law, and in practice it no longer is either.

The best way never to miss a bulletin is to stop relying on memory. If you already have the guest's details before they arrive, reporting to SIBA takes a minute instead of becoming a race against the deadline.

This is where direct bookings have a practical advantage. When guests book on your own website, you can collect the details you need at that point (name, nationality, ID document, dates) instead of chasing them by email later. The details stay organised and ready for the bulletin.

Bookings from OTAs (online travel agencies such as Booking and Airbnb) often arrive without some of these details, so you have to ask the guest for them later, which means more back-and-forth and more chance of forgetting. The routine we recommend: collect the details as early as possible (ideally when the guest books), confirm them on arrival, and submit the bulletin in SIBA straight after check-in, within the 3 business days. The earlier you collect the data, the easier it is to comply. This guide is for information only and is not legal advice.