AIMA: an address is no longer just an address

 

In residence permit applications and renewals in Portugal, proof of accommodation has become one of the most sensitive points — and often one of the least properly prepared.

For a long time, many cases were handled with a very simple logic: there was an address, there was a declaration, perhaps even a parish council certificate, and the matter seemed resolved.

Today, that is no longer enough.

AIMA now requires the declared address to be supported by clear documentation explaining the legal basis on which the foreign citizen occupies that property.

In other words: it is not enough to say “I live here”.

It is necessary to show in what legal capacity the applicant lives in that property: as owner, usufructuary, tenant, subtenant, borrower under a loan-for-use agreement, or another legitimate situation.

What should be presented?

As a general rule, there must always be a sworn statement from the applicant, indicating the address where they live and the legal situation that justifies their use of the property.

Then, depending on the case, supporting documents must also be provided.

If the applicant is the owner or usufructuary, they should present the permanent land registry certificate or the respective access code - Certidão Permanente do Registo Predial properly up to date (valid only for 6 months).

If the applicant is a tenant, they should present a rental agreement showing their identification, as well as the rent receipt for the previous month.

If the applicant lives in the property under a loan-for-use arrangement, meaning the property is being provided free of charge, they should present a loan-for-use agreement and a valid permanent land registry certificate (Certidão Permanente).

As far as I know, AIMA has also been requiring that co-renters/proprietors, even though their name(s) are stated on the relevant documentation, also must show proof of residence by presenting an utility service bill on their name(s)...

What if the applicant is not named in the contract?

This is probably the most important point — and the one most likely to create problems.

When a foreign citizen actually lives in a property but is not identified in the rental agreement or loan-for-use agreement, AIMA may require additional documentation.

In such cases, the applicant must present their own sworn statement, under criminal liability for false declarations, confirming that they actually reside at that address. This statement must also include the land registry description number of the property, the basis on which they reside there, and the full name and NIF/NIPC of the owner who granted them the use of the property for housing.

In addition, a certificate issued by the Portuguese Tax Authority must be provided, showing the applicant’s tax domicile. This certificate must have been issued less than 30 days before the appointment.

In plain English: living “at someone’s place” or at an address where your name does not appear in the contract is no longer something that can easily be solved with a simple informal declaration.

Be careful with parish council certificates

AIMA expressly states that, for these purposes, certificates issued by parish councils are not accepted as proof of accommodation.

This is very important, because many foreign citizens still believe that a parish council certificate is enough to prove their address. In this specific context, it is not.

The address must be real, verifiable and supported by documents proving the right to use the property.

What does this mean for landlords?

For landlords, this practical change is also relevant.

A properly drafted rental agreement, registered with the Portuguese Tax Authority, with rent receipts issued and the tenants correctly identified, has become even more important.

This is no longer just a tax or contractual formality. For many foreign tenants, the rental agreement can be an essential part of their residence process in Portugal.

When the contract does not correctly identify the people living in the property, additional documentation may be requested, including declarations, proof of ownership, landlord identification, NIF/NIPC, and consistency between the contract, rent receipts, tax domicile and declared address.

For this reason, both landlords and tenants should avoid improvised solutions, convenience addresses or declarations that do not correspond to reality.

AIMA will analyse the number of residents per accommodation

Another relevant point is that AIMA states it will analyse the number of residents declared per accommodation.

This is a clear sign of tighter control over artificial situations, overcrowded addresses, unclear contracts or residence declarations that do not reflect the actual occupation of the property.

For the applicant, poorly documented accommodation may result in delays, additional notifications or even the risk of refusal.

For the owner or landlord, signing declarations without proper care may create unnecessary responsibility.

Students: specific rules may apply

In cases involving students living in accommodation connected to educational institutions, specific documents may be accepted, such as a rental agreement signed by the school with a private entity, a certified statement from the educational institution, or a certificate from a university residence confirming the right to accommodation.

Here too, the central idea is the same: the residence must be individualized, documented and legally explained.

The key point

For AIMA purposes, an address is no longer just an address.

It is necessary to show that there is a real, legal and documented connection between the foreign citizen and the property where they declare they live.

A verbal agreement, a borrowed address, a parish council certificate or a poorly prepared declaration may not be enough.

In an increasingly demanding rental market, this reinforces the importance of well-drafted contracts, issued rent receipts, properly identified landlords, updated tax domicile and organized documentation before the appointment.

At U C HOMES, we assist foreign clients, landlords and property owners with this type of process, helping to prepare rental contracts, accommodation documentation and communication between the parties, always with transparency, accuracy and respect for Portuguese law.

Because a home is not just an address.

It is also the starting point for a legally secure life in Portugal.