AL insurance in Portugal — mandatory liability cover, the Balcão Único 3-day rule, and what a valid policy looks like (2026)
A complete operator's guide to civil liability insurance for Alojamento Local — who has to have it, the legal minimums, the 3-day Balcão Único notification, what a compliant policy must cover, and what happens if you file late.
Civil liability insurance is the single most-overlooked legal requirement in Alojamento Local. Every registered AL — from a one-room apartment in Braga to a 20-unit villa in the Algarve — has to carry a valid multi-risk policy that covers guests, third parties and the property itself, and the certificate has to be filed with Balcão Único do Turismo de Portugal within 3 business days of the policy being issued or renewed. Miss the window and the AL registration can be suspended, regardless of whether the underlying cover is in force.
This guide breaks down the legal basis, the minimum coverage that actually holds up in a claim, the exact Balcão Único filing steps for 2026, and the mistakes we see hosts make every renewal cycle.
The legal basis in one paragraph
Decreto-Lei 128/2014, art. 13-A (introduced by DL 62/2018 and updated by the Mais Habitação package in 2023) requires every AL operator to hold a multi-risk civil liability policy covering damage to guests and third parties, fire, and structural damage to the building. Portaria 83/2019 sets the minimum insured capital at €75,000 per claim for civil liability and requires the policy to be renewed annually. Turismo de Portugal Circular 07/2019 requires the certificate of cover ("declaração de seguro") to be uploaded to the Balcão Único portal within 3 business days of issue or renewal. Non-compliance is a contraordenação grave punishable by fines of €2,500 to €30,000 for individuals and up to €50,000 for companies, plus suspension of the AL registration.
Who has to hold the policy
Every AL modality in the Registo Nacional de Alojamento Local (RNAL) is in scope:
- Moradia — standalone houses.
- Apartamento — apartments within a horizontal-property building.
- Estabelecimento de hospedagem — guesthouses, hostels and B&Bs registered as AL.
- Quartos — individual rooms rented under the host's own dwelling.
There are no exemptions for small operators, single-property hosts, or family-owned units. If you have an AL number, you need a policy. If you operate multiple units under separate AL numbers, each unit needs to be listed on the policy (or covered by a separate policy) and each has to be filed separately with Balcão Único.
What a compliant policy must cover
A generic home-and-contents policy is not enough. To satisfy DL 128/2014 the policy has to explicitly cover the AL activity and include, at minimum:
The policy schedule ("condições particulares") must name the AL activity explicitly — usually with the CAE code 55201 (Alojamento Mobilado para Turistas) — and list the AL registration number. A policy that only names the property as a "second home" or "primary residence" does not comply, even if the capital limits are correct.
The Balcão Único 3-day rule, step by step
The most common compliance failure isn't the policy — it's the filing.
1. Day 0 — insurer issues or renews the policy and emits the declaração de seguro (a one-page PDF certificate).
2. Within 3 business days — log in to Balcão Único do Turismo de Portugal with your NIF/user credentials.
3. Open the AL registration file (each AL number has its own record).
4. Under "Documentos" → "Seguro", upload the PDF and enter the policy number, insurer name, and expiry date.
5. Submit. Turismo de Portugal returns a confirmation number — save it with the policy.
"Business days" excludes weekends and national holidays. A policy issued on a Friday must be uploaded by end of Wednesday. Late uploads are logged automatically and are the number-one trigger for an ASAE inspection.
What happens if the policy lapses or the filing is late
- Late filing (up to 30 days) — usually a warning and a €500–€2,500 fine per AL number.
- Policy lapse (any period) — the AL registration is suspended until a new policy is filed. Any bookings that check in during the lapse are, technically, illegal and the ASAE can require you to refund them.
- Renewal without upload — the AL system flags the registration as "documentação em falta" 60 days after the previous certificate's expiry date, even if a new policy exists. The suspension is automatic; reinstatement requires opening a ticket with Turismo de Portugal.
The most common mistakes we see
- Multi-risk without the AL activity clause. The most frequent claim rejection: the guest slips in the shower, the insurer opens the file, sees the property is only insured as a "habitação própria", and voids the claim.
- One policy for six units, uploaded once. Each AL number is a separate record at Balcão Único. The certificate has to be filed against each one, even if the underlying policy is a single group contract.
- Renewal on the same policy number. Some insurers re-issue the same policy number every year with a new schedule. You still have to upload the new certificate — the system checks the expiry date, not the number.
- Uploading only the "recibo" (payment receipt). A payment receipt is not a declaração de seguro. The document must state the covered activity, the AL number, the capital and the validity dates.
- Trusting the property manager to file it. If a mandate isn't in place, the manager's Balcão Único login may not have access to your file. Check the "utilizadores autorizados" list every renewal.
How Chave AL helps
- Document Vault stores the current declaração de seguro per property with the exact expiry date and reminds you 60, 30 and 7 days before renewal.
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