Mandatory IMPIC filings
The practical guide to the mandatory real-estate activity filing (Law 83/2017): who files, what is required and how to prepare the file.
Real-estate agencies are required to report to IMPIC the elements of the transactions they broker, under anti-money-laundering and counter-terrorism-financing rules. The filing is made via an XML file imported into the IMPIC portal — and that is where ComunicaPro helps: it turns the deed or contract PDF into the XML ready to import, with mandatory human review.
Use cases
Sale
Property sales: parties, amounts and means of payment.
See guideLease
In preparationTenancy agreements: number, term and contract dates.
See guideExchange
In preparationProperty exchanges: both properties and the values assigned.
See guideGuides
Deadlines and frequency
When to file each quarter and the start-of-activity deadline.
See guideWho must file
Which entities file, the compliance officer duty and forms A and B.
See guideFines and consequences
What a missed filing costs and why a gap is now easier to spot.
See guideThe XML file
Structure, element order and the formats the portal accepts.
See guideWho must report
The obligation applies to entities carrying out real-estate activities: brokerage, development, purchase and sale, purchase for resale or exchange of property, and letting.
What data is required?
- Buyer and seller identification: name, tax number, nationality, ID document and, where represented, the representative's details.
- Transaction details: type, date, amount and means of payment (transfer, cheque or cash), with the account numbers used.
- Identification of each property: address, tax registration, land registry, parish (DICOFRE code), area and intended use.
Deadlines and frequency
Real-estate transactions are reported to IMPIC quarterly, by the end of the quarter following the one in which they took place:
- Q1 (January to March): by 30 June
- Q2 (April to June): by 30 September
- Q3 (July to September): by 31 December
- Q4 (October to December): by 31 March the following year
The start of a real-estate activity must be filed with IMPIC within 60 days of that date (article 46(1)(a)). IMPIC's own website states 60 working days, which is more generous: to be safe, count the 60 calendar days in the statute.
Not every tenancy counts: only contracts with a monthly rent of 2 500 € or more must be filed (article 46(3)).
Failing to file is an administrative offence punishable by a fine of 5 000 € to 500 000 € for companies and 2 500 € to 500 000 € for individuals (Law 83/2017, articles 169 and 170).
Source: Law 83/2017, as amended by Law 58/2020, and IMPIC General Guidance no. 1/IMPIC/2021. Always confirm the deadlines in force on the IMPIC website. Mandatory filings on the IMPIC website ↗
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