Reporting guests: the accommodation bulletin and SIBA

Article 16, no. 1, defines the field deliberately widely: companies operating hotel establishments, complementary tourist accommodation or tourist complexes, as well as all those who provide, for payment, accommodation to foreign citizens, are obliged to report it.

The phrase that matters to a short-let host is the last one: all those who provide, for payment, accommodation to foreign citizens. You need not be a hotel, nor a company. Providing accommodation for payment is enough.

A registered short-let flat, a room let to tourists, a house rented by the week — all fall under the same rule. What triggers it is paid accommodation of a foreign citizen, not the legal form of whoever provides it.

The duty belongs to the host, not to the booking platform. A reservation made through a portal does not transfer the reporting duty to that portal.

Article 15, no. 2, is explicit about which guests: for each foreign citizen, including nationals of other European Union member states, a bulletin is filled in and signed in person.

That answers the commonest question: yes, EU citizens count. A Spanish, French or German guest generates a bulletin just as a guest from outside the Union does. Portuguese nationals are the ones left out.

No. 3 opens the only exception to filling one in individually: personal completion and signature is not required from both spouses and the minors accompanying them, nor from every member of a travel group, and the duty may be met by one of the spouses or by one member of the group.

• One bulletin for each foreign citizen accommodated.
• Nationals of other EU member states are included.
• Spouses, accompanying minors and members of a travel group may be covered by one of them.

The period is three working days. It is not 72 hours, and the difference is real: a weekend or a public holiday extends the period in calendar days without extending it in working days.

The report is made to the GNR or the PSP, by means of an accommodation bulletin (article 16, no. 1).

And there is a second report that is often forgotten. No. 2: after the foreign citizen leaves the accommodation, the fact must be reported, within the same period, to the same entities. So there are two reports per stay, not one.

The period runs per guest and per stay. In a property turning over weekly, a two-week lapse is not one breach: it is one for each missing bulletin — and that is how the fine is banded.

Article 15, no. 4, is the legal basis for electronic filing: with a view to simplifying the sending of accommodation bulletins, hotel and similar establishments must register with the Unidade de Coordenação de Fronteiras e Estrangeiros (UCFE) as users of the Accommodation Bulletin Information System, so as to be able to report electronically under secure conditions.

That article is where the name everyone uses comes from: SIBA, the Sistema de Informação de Boletins de Alojamento. Registration as a user is done with the UCFE, which sits inside the internal security system.

Registration is a prior step: anyone who has not done it has no way to report electronically, and the three working days keep running regardless. It is worth dealing with before the first booking, not after.

SEF was wound up in 2023 and its powers redistributed. The system did not pass to AIMA: user registration is with the UCFE, and the bulletin is filed with the GNR or the PSP under article 16, no. 1.

No. 5 fixes retention: the bulletins and their duplicates, as well as the substitute media referred to in the previous paragraph, are kept for one year counted from the day after the departure was reported.

The starting point is neither the date of the stay nor the date of arrival: it is the day after the departure report. One year runs from that day.

In practice this means keeping proof that the report was made, and not merely the guest data. In an inspection, what is demonstrated is that the filing happened within the period.

• Retention period: one year.
• Counted from the day after the departure report.
• Applies to bulletins, duplicates and substitute media.

Failure to report is an administrative offence, punished by article 203 of the same law. Under article 203 of Law 23/2007 the fine is banded by how many bulletins are missing: €100–500 (1 to 10), €200–900 (11 to 50) and €400–2,000 (more than 51); merely negligent lateness cuts both limits to a quarter.

Note the banding criterion: it is the number of bulletins, or of citizens whose registration is missing. It is not the size of the business, nor a split between natural and legal persons.

The rule covers two courses of conduct: omitting the electronic registration under article 15, no. 4, and not filing the bulletin under article 16, no. 1 or no. 2 — which includes failing to report the departure.

The dedicated guide to the fines walks through each band, explains the reduction to a quarter for negligent lateness, and deals with a known discrepancy between the statute and the printed paper form.