On 5 December 2025, Notice no. 29926-A/2025 was published, introducing the second amendment to the Lisbon Municipal Regulation on Local Accommodation (Regulamento Municipal do Alojamento Local de Lisboa – “RMAL”), effective as of 6 December 2025.
The amendments introduce a new model for the territorial regulation of local accommodation (“AL”) in Lisbon, with a direct impact on the admissibility of new registrations, the transfer of properties operated as AL, and the future management of existing registrations.
The RMAL will now adopt the scales of municipality, parish and neighbourhood to monitor the pressure of AL, based on the ratio between AL establishments and dwellings intended for permanent housing, distinguishing between:
- absolute containment areas, where the ratio is equal to or greater than 10%;
- relative containment areas, where the ratio is between 5% and 10%.
This geographical classification is decisive for the admissibility of new registrations and for the transferability of existing registrations.
In absolute and relative containment areas, the possibility of obtaining new AL registrations is, as a general rule, excluded, being permitted only in exceptional and duly substantiated situations, subject to assessment by the Lisbon City Council.
These exceptions include, namely, deep rehabilitation works of vacant or degraded properties, as well as projects which, by their nature or context, are deemed to be of significant interest to the city, including initiatives with a social, cultural or affordable housing component.
In relative containment areas, registration in the “bedroom” modality is still permitted, provided it forms part of the holder’s permanent residence and within the applicable legal limits.
In all circumstances, properties which have been subject to a residential lease agreement within the previous five years are excluded from access to a new registration, except for the lease agreement that served as the basis for the existing registration, where the new application is submitted by the tenant.
One of the most significant changes concerns the transfer of AL registration.
In absolute or relative containment areas, the transfer of ownership of the property results, as a rule, in the expiry of the AL registration in the “apartment” and “house” categories, even where the registration has been in place for several years.
In practical terms, this amendment means that:
- the purchase and sale of properties operated as AL now involves an effective risk of losing the registration;
- the value of the property may be significantly affected if operation as AL cannot be maintained;
- transfer transactions should be preceded by a prior analysis of the applicable geographical and regulatory framework.
The RMAL also allows for the temporary suspension of AL operations for a period of up to five years, provided the property is allocated to urban residential letting. Any subsequent reactivation of the registration will depend on the territorial conditions in force at the time of the request and, in containment areas, may be subject to quotas or waiting lists, with automatic reactivation not being guaranteed.
The possibility of cancellation of the registration by resolution of the condominium in cases of repeated disturbance is also maintained, with municipal inspection powers and ongoing compliance requirements being reinforced.
In summary, these amendments do not result in the automatic expiry of existing registrations, but they introduce significant limitations on transfers, the obtaining of new registrations and the future strategy for operating AL in Lisbon, making it essential to analyse each situation on a case-by-case basis.
