Guest registration: the accommodation bulletin

The accommodation bulletin (boletim de alojamento) is the report that anyone providing paid accommodation — hotels, short-term rentals, any establishment taking paying guests — must make to the authorities about the stay of foreign citizens. It's a security and border-control duty: the State wants to know who is lodged in the country and where.

This obligation didn't start with short-term rentals and isn't a recent invention. Its legal basis is in Law no. 23/2007 of 4 July (the legal regime for the entry, stay, departure and removal of foreigners), in its articles 15 and 16. Article 16 is clear: companies running hotel establishments, complementary accommodation or tourist complexes, as well as anyone providing accommodation for payment, must report the stay of foreign citizens.

Fix one idea from the outset: the obligation applies to foreign guests. Guests of Portuguese nationality are not reported through this channel. "Foreigner", according to most sources, includes EU and Schengen-area citizens — it isn't only people from outside Europe. If in doubt about a specific nationality, check the official source before assuming you're exempt.

Paper bulletins are a thing of the past. Since Ordinance no. 287/2007 of 16 March, there's SIBA — the Accommodation Bulletins Information System — the electronic platform where establishments submit bulletins. It's the official channel, and it's where you register to start reporting.

To use SIBA, the establishment must be registered on the platform as a user. Once that's done, for each foreign guest you create and submit a bulletin with the required identification data (name, document, nationality, entry and departure dates, among others). The system keeps the record of the report.

In practice there are two ways to do it: manually, on the SIBA portal, bulletin by bulletin; or automatically, connecting SIBA to your reservation management system (PMS / channel manager), which sends the data without re-typing everything. For those with many guests and several units, the automatic route saves time and cuts errors — but the duty to report is yours, whatever the tool.

The legal deadline to report is three business days. "Business days" excludes weekends and public holidays, so the real clock may be more generous than three calendar days — but don't rely on it and report early.

A detail many holders miss: beyond entry, some procedures also provide for recording the foreign guest's departure. Article 16 sets out reporting within three business days of entry. In day-to-day SIBA operation, entry and departure dates are usually recorded in the same bulletin; even so, confirm the platform's current procedure for your case.

A habit that works: report on the check-in day itself, with the data you collected at booking. That way you never depend on remembering days later — and this is exactly where having the guest's data gathered in advance makes all the difference.

For years, the bulletin was reported to SEF — the Foreigners and Borders Service. SEF was dissolved in 2023 (by Decree-Law no. 41/2023), and its powers were redistributed. This is the part that causes the most confusion, so it's worth separating the pieces.

Powers over foreign citizens and migration passed to AIMA — the Agency for Integration, Migration and Asylum. That's why you'll now hear talk of the "AIMA bulletin". Technical management of the reporting system was placed within the Internal Security System (SSI), and on-the-ground enforcement passed to the security forces and services — namely PSP, GNR and the Judicial Police, depending on the matter.

For the AL holder, the key point is simple: the system is the same (SIBA), the duty is the same, the deadline is the same. The shift in oversight from SEF to AIMA was largely administrative and didn't change the deadlines or required data. As bodies and portals may change name or address, always confirm the current channel on the official SIBA portal before registering.

Missing the report isn't a harmless slip. Failure to report accommodation is an administrative offence under Law no. 23/2007, punishable by a fine — and the fine applies, as a rule, per missing bulletin, which adds up fast in establishments with many guests.

The actual fine amounts depend on the applicable rule, on whether you're an individual or a company, and on the degree of fault, and they may be updated — so we don't state a figure here as absolute truth. The order of magnitude, according to sources citing the regime, ranges from a few hundred to several thousand euros per missing bulletin, higher for companies. Confirm the framework and current amounts at the official source or with legal support.

One more factor has changed the perception of risk: data cross-checking. Authorities increasingly cross SIBA data with the RNAL (National Register of Local Accommodation) and with invoicing reported to the Tax Authority. An active AL, invoicing, with no bulletins reported, is an easy inconsistency to spot. Enforcement has become more systematic — complying stopped being optional in practice, as it already wasn't in law.

The best way never to miss a bulletin is not to rely on memory. If the guest's data is already collected before arrival, reporting to SIBA becomes a quick gesture rather than a race against the deadline.

This is where direct booking has a concrete operational advantage. When the guest books on your own website, with a booking engine, you can collect the data you need right then — name, nationality, document, dates — instead of chasing it by email later. That data stays organised and ready for the bulletin.

With bookings from OTAs (Booking, Airbnb), some of this data doesn't arrive complete, and you have to ask the guest for it at a second stage — more friction and more risk of forgetting. So, recommended flow: collect the data as early as possible (ideally at booking), confirm on arrival, and report the bulletin in SIBA right after check-in, within the 3 business days. The earlier you collect, the calmer you comply. This guide is informative and doesn't replace legal advice.