Portaria 320/2026: what changes in applications to the municipality from 1 October
Since 1 October 2026, applications to municipal councils are submitted on new forms. Portaria n.º 320/2026/1 (a ministerial order), published on 31 July, came into force together with the revision of the Regime Jurídico da Urbanização e da Edificação (RJUE, the Portuguese legal regime for urbanisation and building) and replaces Portarias 71-A/2024 and 71-B/2024. It sets out the application form, the documents to be submitted, the file format and the professionals’ statements of responsibility.
This article deals only with what changes in what is submitted to the municipality. For the timeline of the reform, see the new RJUE on 1 October; for the substantive changes to the law, the five changes in the new RJUE. It was written with the text of the portaria and of Decree-Law n.º 108/2026 in front of us.
The essentials in 30 seconds
- A single application form for planning permission, prior notification and PIP, which is also used to perfect the application, add documents and submit the specialist designs.
- The summary filled in on the application form becomes part of the title for the works: the areas and uses must match the final design.
- Files: PDF/A with a qualified digital signature; only the site plan also goes in DWG, now georeferenced; IFC is optional.
- New statements of responsibility: the design author’s statement now states the estimated total cost of the works and includes a table that refers each parameter to the page of the design statement and the drawing number.
- The municipality can only request documents not listed in the portaria by citing the legal provision, and the coordinator can justify in writing the absence of an unnecessary element.
What Portaria 320/2026/1 is
It is the portaria that regulates the new RJUE as regards the preparation of applications. It has five articles and seven annexes and approves the application form for planning permission, prior notification and prior information request (PIP), the form for notice of the start of works, the form for prior notification of use or change of use and the notices to be displayed on site. It also sets the supporting documents (what is submitted), the submission conditions (in what format) and the templates for the statements of responsibility.
It revokes Portarias 71-A/2024 and 71-B/2024, of 27 February. Portaria 71-C/2024, on the site logbook, and Portaria 75/2024, on the sizing of green spaces and infrastructure, remain in force. It was published on 31 July, but Article 5 makes its entry into force coincide with that of Decree-Law n.º 108/2026, which Decree-Law n.º 155-B/2026 postponed to 1 October to give municipalities time to adapt their IT platforms.
The seven annexes of the portaria
Annex I
Application form
planning permission, prior notification and PIP, with the summary of the operation (I-A to I-D) and the list of specialist designs (I-E)
Annexes II and III
Works
notice of the start of works and notices to be displayed on site
Annex IV
Use
prior notification of use or change of use
Annexes V to VII
Application file
documents to be submitted, file format and statements of responsibility
Before and after: what changes in the submission
| Portarias 71-A and 71-B/2024 (until 30 September) | Portaria 320/2026 (since 1 October) | |
|---|---|---|
| What the portaria approves | The forms for the permit and for the response to prior notification, issued by the municipality | A single application form, filled in by the applicant, for planning permission, prior notification and PIP |
| Drawing files | PDF/A, and all architecture and specialist drawings also in DWFx, DXF or DWG | PDF/A; only the site plan also in DWG, georeferenced; IFC as an optional complement |
| Design author’s statement of responsibility | Declaration of compliance with the rules, with the insurance policy | Adds the estimated total cost of the works and a verification table, parameter by parameter |
| Colour code | Red, yellow, black and blue | Unchanged |
| Written documents | A4, with a paginated index; table of planning indices in a spreadsheet | Unchanged |
In short, what changes is more what is declared than what is drawn.
The single application form and the title for the works
Annex I is a single form for the three prior-control routes. It includes the summary of the operation, by type: subdivision (I-A), urbanisation works (I-B), building or demolition (I-C) and land remodelling and other land uses (I-D), plus the identification of the specialist designs (I-E). The same form is used to respond to a request to perfect the application, to add documents at the prior hearing and to submit the specialist designs.
The substantive change lies in Article 4-A of the RJUE. The permit is now evidenced by the last application form submitted, with the summary of the operation, by the proof of payment of the fees and by the notice of approval, or by the proof of submission if approval is tacit. Each new application form submitted in the procedure updates the summary.
In practice
The areas, uses and number of dwellings written in the summary are the ones that go into the title for the works. They must match the final design, and it is worth reviewing them at every submission with the same care you would give a contract.
Article 2(1) makes the application form (Annex I), the prior notification of use (Annex IV) and the notices (Annex III) mandatory. The form for notice of the start of works (Annex II) is not on that list, although the completion guide of the Portuguese Order of Architects (Ordem dos Arquitectos) presents it as mandatory. We recommend using it anyway: it costs nothing and avoids disputes.
The new statements of responsibility
Annex VII has six templates: I, author of the lead design (usually the architecture); II, authors of the specialist designs; III, design coordinator; IV, works director or site supervision director; V, assumption of the role of works director or site supervision director; VI, professional qualified to author architectural designs, in prior notification with a time limit for use or change of use.
Template I still declares that the design complies with the applicable rules and identifies the professional liability insurance. It adds two things: the estimated total cost of the works, to which the insurance relates, and a mandatory annex, the table verifying compliance with the legal, regulatory and planning framework.
The verification table in the design author’s statement
Planning historyPlot areaDwellings and usesFootprint areaFloor area by use and by storeyHeights and number of storeysVolumeOpen space and permeable areaPublic and private parkingDemolitionsPDM and other plansLand cessionsFavourable prior informationRGEUAccessibilityFire safetyEnergy performance
On each line: Yes, No or N/A, with the page of the design statement and the number of the drawing where compliance is justified.
For anyone commissioning a design, this has two consequences. The design statement can no longer stay silent on any topic: if parking does not apply, the table says why and where. And a realistic cost estimate is needed early on, because the professional declares it in the statement.
Declaração de Rectificação n.º 29-A/2026 (an official correction notice) added another responsibility. In prior notification with a time limit for use or change of use without works, the statement of responsibility must now be signed by a person qualified to author architectural designs (Article 63(2) of the RJUE). Anyone who wants to change the use of a unit without works therefore needs a professional qualified to sign architectural designs.
Files and presentation
Annex VI sets the format of everything that is submitted. Almost all of it was already the case; what is new is the georeferenced site plan and the end of the obligation to submit the remaining drawings in an editable format.
Checklist before submitting
Signature
Qualified digital signature: Citizen Card, Chave Móvel Digital (the Portuguese digital mobile key), with professional attributes (SCAP) where applicable, or recognised European means
Documents
PDF/A, dated and signed; IFC as a complement; written documents in A4 with a paginated index
Site plan
Also in DWG, georeferenced; the summary table in ODS, XLS or XLSX
Drawings
Title block with applicant, location, number, scale, date, document and author; dimensions always; colours: red to build, yellow to demolish, black to keep, blue to legalise
Municipalities that do not yet process applications electronically may request paper copies until the electronic platform provided for in Article 8-A of the RJUE is in place. There is no BIM obligation: IFC is optional.
What the municipality can, and cannot, request
Under Article 2 of the portaria, the municipality may only require documents not listed in the annexes when they are provided for in the RJUE or in special legislation, or when they are strictly indispensable to verify spatial planning instruments, and it must justify the request by citing the specific provision. The applicant may add any documents they consider useful. Conversely, the design coordinator may justify in writing that a document is unnecessary in that particular case, and the municipality assesses that justification at the preliminary check.
Article 9(12) of the RJUE also prohibits requesting, among other things: certification of signatures, copies of documents the municipality already holds, the property tax record (caderneta predial), copies of permanent land registry certificates (the access code is enough), the health and safety plan, the scanned site logbook and copies of the Citizen Card or of professional licences.
Two points to watch
The portaria asks for the property tax record when the property is not recorded in the land registry and, for building permission and the full PIP, a study of compliance with the Regulamento Geral do Ruído (the General Noise Regulation) accompanied by the professional’s statement of responsibility. The RJUE prohibits requiring the tax record and that statement. Until a settled reading emerges, we check with each municipality before submitting.
I have an application under way: what happens now?
Article 12 of Decree-Law n.º 108/2026 applies the new regime to procedures started after its entry into force, on 1 October 2026, and also to those which, started earlier, are still at the preliminary check and screening stage. In that case, the applicant may take the steps needed to adapt the application. If that stage has already passed, the application continues to the end under the old rules.
The portaria has no transitional rule on statements of responsibility and nothing requires those already submitted to be replaced. But statements issued since 1 October exist only in the new template, and if a submission of additional documents changes the design, the old statement certifies a version that no longer exists. In those cases, we issue the statement in the new template.
What we recommend to anyone submitting an application now
Confirm your municipality’s channel
Entry into force was postponed so that municipalities could adapt their platforms. In the first few weeks, confirm the form and the submission channel before submitting.
Before submitting
Gather what is yours early
The permanent land registry certificate code, the owners’ identification and a realistic estimate of the cost of the works, which now appears in the professionals’ statements.
Building owner
Review the summary like a contract
It is what goes into the title. Areas, uses, dwellings and storeys must match the final design at every submission.
In every application
Still to buy the plot?
Start with feasibility and, if it makes sense, with a prior information request, which also uses the new form.
Before buying
If you do not yet know whether your project requires planning permission or prior notification, see planning permission or prior notification; for the full journey, the building permitting guide.
Frequently asked questions
What is Portaria 320/2026?
It is Portaria n.º 320/2026/1, of 31 July, which approves the single application form for planning permission, prior notification and prior information request, the forms for use, start of works and notices, and sets the documents to be submitted to the municipality, the file format and the statements of responsibility under the new RJUE.
When does Portaria 320/2026 come into force?
On 1 October 2026, the same date as Decree-Law n.º 108/2026. It was published on 31 July, but Article 5 links its entry into force to that of the decree-law, which Decree-Law n.º 155-B/2026 postponed to October.
Which portarias are revoked?
Portarias 71-A/2024 (supporting documents) and 71-B/2024 (permit forms and notices). Portaria 71-C/2024, on the site logbook, and Portaria 75/2024, on green spaces and infrastructure, remain in force.
Where can I find the template for the architectural design author’s statement of responsibility?
In Annex VII of Portaria 320/2026/1, published in the Diário da República (the Portuguese official gazette): it is template I, which includes the insurance policy, the estimated total cost of the works and the compliance verification table.
Do drawings still have to be submitted in DWG?
Only the site plan, which must now also be submitted in georeferenced DWG. The remaining documents are submitted in PDF/A with a qualified digital signature; IFC may be added as a complement.
Does an application submitted before 1 October have to be redone?
No. If on 1 October it was still at the preliminary check and screening stage, it moves to the new regime and can be adapted; if it had already passed that stage, it continues under the old rules. No provision requires the statements of responsibility already submitted to be replaced, but if the adaptation changes the design it is advisable to issue them in the new template.
Submitting an application to the municipality?
Tell us what stage you are at: plot not yet bought, design under way or application already submitted. We explain what changes in your case and prepare the application file in the new format.
Official sources: Portaria n.º 320/2026/1 · Decree-Law n.º 108/2026 · Declaração de Retificação n.º 29-A/2026 · Decree-Law n.º 155-B/2026.
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