Guest reporting in Portugal: who files it and by when

This is the obligation most owners overlook, precisely because it shows up nowhere until something goes wrong. This guide answers the three questions that matter: who files, by when, and what to keep.

Who has to report guests?

The holder of the alojamento local registration. That is the owner listed on the Registo Nacional de Alojamento Local, not the company that does the cleaning, the check-in or the listing management.

This is frequently misunderstood when a management company is involved. It can collect the data at check-in and enter it in the system on the owner's behalf, using access the owner grants. What does not happen is a transfer of responsibility: in law, the registration holder answers for it.

Which guests are covered?

Foreign nationals. Guests holding Portuguese nationality are not subject to the reporting duty.

In practice we recommend logging every guest internally, Portuguese ones included. Not as a legal duty, but because that record is what lets you answer a neighbour complaint, a council query, or a platform dispute about the real number of occupants.

By when?

Within the statutory deadline, counted from the guest's arrival. That is why the moment to collect the data is check-in, not the end of the stay: collecting at the end means filing late.

If you use a key box rather than in-person check-in, collection has to be arranged another way — a pre-arrival form, or collection through the platform where that is available. There is no in-person check-in without a chance to collect, but there are plenty of key boxes with no collection at all. That is where the gap appears.

What data to collect

Date of birth serves two separate obligations worth keeping apart: guest reporting, and calculating the municipal tourist tax, whose minimum age varies by municipality — 13 in Almada and Sesimbra, 19 in Setúbal. See the guide on tourist tax south of Lisbon.

How this sits with the GDPR

Guest data is personal data. Three simple rules:

1. Collect only what is needed. A full passport scan kept indefinitely is not proportionate.
2. Keep it only as long as needed to meet the legal obligation and the applicable accounting duties, and no longer.
3. Do not share it with third parties for any other purpose — not with the cleaning company, and not for marketing.

What to check today

1. Confirm that the registration holder is who you think it is, and that the registered address is correct.
2. Check that data collection happens on arrival, not on departure.
3. If you use a key box, confirm a collection mechanism exists before arrival.
4. Keep proof of each filing wherever you keep the RNAL registration and the insurance certificate. In an inspection, all three are asked for together.