Who must file with IMPIC
Any entity carrying on a real-estate activity in Portugal must file with IMPIC, regardless of size and whether or not it is a licensed estate agency.
The activities covered
- Estate agency (mediação imobiliária).
- Buying, selling, buying to resell or exchanging property on one's own account.
- Property development for sale.
- Letting property, within the rent threshold below.
Article 4(1)(d) of Law 83/2017 covers entities carrying on "any real-estate activity", which is deliberately broad: buying to resell counts even without an agency licence. Tenancies are only filed at a monthly rent of 2 500 € or more; sales have no threshold. Financial institutions with real-estate activity follow a different regime.
The compliance officer duty
Separately from the transaction filings, an entity with more than five staff in commercial or administrative roles must appoint a compliance officer (RCN) and notify IMPIC within 60 working days of the appointment. Failing to appoint one is an especially serious offence, so its maximum fine is not halved.
Source: Law 83/2017, articles 4, 16 and 46, as amended by Law 58/2020, and information published by IMPIC. Always confirm on the IMPIC website. Mandatory Communications on the IMPIC website ↗