AL check-in compliance — guest ID, minors, remote arrivals and the SIBA link (2026)
The complete guide to running a legally-compliant check-in for Alojamento Local — which IDs are valid, how to handle minors and mixed nationalities, self check-in and remote arrivals, record-keeping, and how everything connects back to your SIBA submission within 3 days.
Check-in is where AL compliance either works or falls apart. Get the identification right and SIBA, INE and the tourist tax all flow from a clean dataset. Get it wrong — a missing passport number, an unrecorded minor, a self check-in with no ID capture — and every downstream obligation inherits the mistake.
This pillar is a working operator's guide to legal check-in for Alojamento Local in 2026: who has to be identified, which documents count, how to handle minors, mixed-nationality couples, remote arrivals and lockboxes, and how each piece of data lands in your SIBA return within the 3-day window.
The legal basis in one paragraph
Every AL operator in Portugal is required to identify every foreign guest aged 16 or over and transmit the identification data to SEF/AIMA through the SIBA portal within 3 working days of check-in (Decreto-Lei 128/2014, art. 16, updated by DL 9/2021). Portuguese nationals are not required to be reported to SIBA — but you still need their basic booking data for INE, invoicing and the tourist tax. Failure to communicate a foreign guest is punishable by fines of €100–€2,000 per guest, and repeat failures can trigger the suspension of the AL license.
Who has to be identified at check-in
The 16-year threshold is the single most misunderstood rule in AL. Under-16s are not reported to SIBA — but their presence still has to be recorded in your internal registry and it still affects tourist-tax exemption calculations (most municipalities exempt children under 12 or 13, not under 16).
Which documents are legally valid
SIBA accepts three document types:
1. Passport — the default for non-EU guests. Always accepted, no exceptions.
2. EU/EEA/Swiss national ID card — accepted for EU citizens instead of a passport. Must be a machine-readable card, not a paper certificate.
3. Portuguese residence permit (título de residência) — for third-country nationals legally resident in Portugal. Includes the number printed on the card.
Documents that are not accepted by SIBA: driving licences, health cards, expired passports, photos of documents that don't show the MRZ (machine-readable zone), and any document where the nationality field is unreadable.
Practical rule: if the document doesn't show a nationality code and a document number in a machine-readable format, ask for a different one. A driving licence at check-in is a red flag that will cause a SIBA rejection three days later.
The mandatory data fields
For each foreign guest 16+ you must capture and transmit:
- Full name (as it appears on the document)
- Date of birth
- Nationality (ISO 3-letter code — PRT, BRA, GBR, USA...)
- Country of residence
- Document type and number
- Document issuing country
- Date of entry into Portugal (for non-EU/Schengen guests)
- Check-in and check-out dates
- Place of previous stay (optional but strongly recommended)
Missing any one of these will cause the SIBA line to be rejected. The most common rejection: nationality code entered as "British" instead of GBR, or "Brazilian" instead of BRA.
Minors, mixed nationalities and family groups
Minors under 16: don't send a SIBA line, but keep an internal record with document type, number and the name of the accompanying adult. This matters for tourist tax exemption (under-12 / under-13 depending on municipality) and for the police in case of a runaway/incident.
Mixed-nationality couples: each adult is reported on their own SIBA line, with their own nationality and document. Do not report a couple as one line even if they share a surname and a booking.
Family with children: parents each get a SIBA line (if foreign, 16+). Children under 16 are recorded internally under the parent booking. Children 16–17 travelling with parents still need a SIBA line if they are foreign — the "minor" exemption is under 16, not under 18.
Group bookings with a lead guest: SIBA is per-guest, not per-booking. A group of 8 foreign adults on one booking is 8 SIBA lines, not one. This is the single most common reason for a rejected SIBA transmission.
Self check-in and remote arrivals
Self check-in — lockboxes, smart locks, code-based entry — is fully legal for AL in Portugal, but the identification obligation does not go away. If you're not physically present at check-in, you need a documented process that captures the same data before the guest gains access. In practice this means:
1. Pre-arrival ID upload. A secure form (not WhatsApp, not email) where each guest 16+ uploads a photo of their document at least 24 hours before arrival. Chave AL's guest portal does exactly this — one link per booking, one form per guest, data encrypted at rest.
2. Verification before access code is released. The lockbox code or smart-lock invitation should only be sent after the ID data is captured and validated. This is your legal proof that you didn't hand over the property to an unidentified person.
3. A recorded audit trail. Timestamps of when the data was captured, who accessed the property, and when SIBA was submitted. In an inspection, this trail is what protects you.
If a guest refuses to provide ID before arrival, you have the legal right to cancel the reservation. AIMA has confirmed in guidance that identification is a condition of stay, not a courtesy.
The 3-day SIBA window
SIBA data has to be transmitted within 3 working days of check-in. Working days exclude Saturdays, Sundays and Portuguese national holidays. A Friday check-in gives you until Wednesday. A check-in on the day before a public holiday gives you an extra day.
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