Understanding the accommodation requirement
Applicants for a Portuguese residency visa must demonstrate that they have adequate accommodation arranged in Portugal prior to relocation. This requirement exists to ensure that the applicant—and any accompanying family members—will live in conditions that meet the standards of dignified housing and that the cost of accommodation does not jeopardize the requirement of sufficient financial means.
Because this document is submitted at the moment of the visa application, not after arriving in Portugal, it is often one of the elements that causes the most uncertainty and delay.
When must the accommodation be available?
A frequent misunderstanding concerns the effective availability of the accommodation.
The law does not require that the accommodation be available on the date the application is submitted. However, it must be available by the time the visa becomes valid.
In practical terms, the visa cannot start before the start date of the accommodation, meaning the Consulate cannot issue a visa that becomes effective before the applicant has a place to live.
Suppose an applicant files for a residency visa in November 2025 and submits a lease that begins on 1 January 2026. Even if the Consulate approves the application, the visa cannot start before 1 January 2026. It will then carry the usual four-month validity.
However, if too much time passes between the submission and the moment all requirements are satisfied — including the accommodation becoming available — the Consulate may refuse the application for failure to meet the requirements.
This is why timing and planning — preferably with the support of a portuguese immigration lawyer — are essential.
What types of accommodation are accepted?
Portuguese Consulates generally accept three forms of proof:
1. Residential Lease Agreement (minimum 12 months)
A rental contract is the most commonly submitted document. To be considered valid for immigration purposes, it should have a minimum duration of 12 months, so it qualifies as a residential lease under Portuguese law; comply with all requirements of urban tenancy legislation; be considered adjusted and have the necessary conditions to the family applyig for residency.
It is highly advisable that the lease agreement is reviewed before signing, as many foreign applicants unknowingly enter into contracts that conflict with Portuguese legal standards.
2. Property Ownership
If the applicant owns a property in Portugal, a title deed, registry certificate, or equivalent documentation may serve as proof of accommodation.
3. Term of Responsibility (“Termo de Responsabilidade”)
A third party — typically the owner, usufructuary, or legitimate tenant (with specific prior authorization from the owner) — may declare responsibility for hosting the applicant. This document must have the signature notarized, and be accompanied by documents proving the signatory’s rights over the property.
Temporary accommodation options: a warning
While some Consulates once accepted Airbnb or short-term rentals, this is now a high-risk strategy that frequently results in visa refusal. Applicants should avoid relying on temporary arrangements that do not meet the legal standards of residential housing.
Timing your move to Portugal
Applicants often use temporary accommodation solutions (such as a Term of Responsibility) while looking for a long-term home. This is possible, but timing is critical — particularly regarding the AIMA appointment, when the residency visa is converted into a residency permit.
Moving to your “permanent home” in Portugal before the AIMA appointment provides several advantages:
- The residency card is delivered to an address where the holder actually resides, reducing the risk of postal delays or loss;
- It avoids the need to request a new card shortly after issuance, since the law requires the holder to update their registered address.
Accommodation requirements at renewal stage
Accommodation also plays an important role during the renewal of the residency permit. Recently, AIMA has frequently requested a notarized statement from the landlord, even when tenants already have a fully compliant and tax-registered lease agreement.
Legally, a tenant with a properly registered contract with the Portuguese Tax Authorities should not be required to provide additional notarized documents. In practice, however, inconsistencies occur, and legal representation can be crucial to ensure that the law is correctly applied.
This context reinforces the importance of ensuring that all rental contracts are formally registered with the Portuguese Tax Authority.
However, the declaration would make sense in case you are under a “borrowers agreement” or a similar situation. Those cases should be properly assessed by a qualified professional before the submission of your renewal’s process.
Final Considerations
The “proof of accommodation” requirement is straightforward in theory but often complex in practice. The timing of contract start dates, the type of housing selected, and the planning of the physical move to Portugal all influence the success of the visa and residency permit renewal processes.
Because these requirements interact with other elements — namely proof of economic means, visa timing, and AIMA procedures — many applicants benefit from legal guidance to avoid common pitfalls.
Disclaimer
This article is not legal advice and does not replace consultation with a qualified professional. Each case depends on its own specific facts, documents, and eligibility conditions. Families should always seek authorized legal guidance to confirm that all legal requirements are met before submitting any application.
Raquel Matos Esteves | Partner at RME Legal
Get personalized legal advice for your situation from RME Legal.