PIP deadlines in Portugal: how the days are counted and what to do if the council is late

The PIP is governed by Articles 14 to 17 of the RJUE (Regime Jurídico da Urbanização e Edificação, Decree-Law 555/99), Portugal's main planning and building law. Since October 1, 2026, the date set by Decree-Law 155-B/2026, the wording introduced by Decree-Law 108/2026 applies to requests filed from that day and to older ones still at the initial check stage (Article 12 of Decree-Law 108/2026). If you are not yet sure what a PIP is or how a simple PIP differs from a full one, start with our guide to the prior information request.

The 25- and 40-day deadlines quoted in some articles have no basis in the law, and the 20- and 30-day decision deadlines belong to the previous regime. Today's timeline has three stages: the initial check, outside consultations when the project requires them, and the decision. Each has its own deadline and its own consequence if missed.

Within 20 days of filing, the mayor, or whoever holds delegated authority, reviews the formal side of the request. The council can ask you to correct or complete it when the applicant, the request or the location is not identified, or when an essential document is missing that the council cannot obtain itself; it can reject outright a request that plainly breaks the applicable rules; and, for a full PIP, it can give notice of an extension of the decision deadline on grounds of special complexity (Art. 11(2)).

If you are asked for corrections, you have 10 days to respond, and the initial check clock stops until you file the documents or the 10 days run out (Art. 11(3)). Do not miss that deadline: the consequence is preliminary rejection. If the council says nothing within the 20 days, the request is deemed properly filed and the decision deadline can no longer be extended (Art. 11(5)).

This is the stage where a well-prepared request saves weeks. For a simple PIP, Portaria 320/2026/1 (the government order on application documents) requires only a few items, and the council may ask for others only if it cites the rule that requires them; see the list in documents for a PIP. Our PIP service prepares the filing and follows it through to the decision.

When the project depends on an opinion, authorization or approval from national agencies because of where it is, for example land in the National Ecological Reserve (REN), the National Agricultural Reserve (RAN), the public water domain or the protection zone of a listed building, the consultation goes through the regional coordination and development commission (CCDR). The case manager sends the request to the CCDR before the initial check ends, and the CCDR identifies the agencies and consults them all at once within 5 days (Art. 13-A(1) and (2)).

Each agency has 20 days to respond and may, within the first 5, ask once for additional documents, which the applicant files within 10 days; meanwhile the opinion clock stops (Art. 13(5)). If the opinion does not arrive in time, the agency is deemed to agree with the request (Art. 13(6)). If the agencies disagree, the CCDR brings them and the applicant together and issues a single overall decision, which adds a few days to the timeline (Art. 13-A(6) and (7)).

In these cases, the PIP decision deadline runs from the last opinion received or from the end of the period for issuing it, whichever comes first (Art. 16(2)). You can shorten this stage: the law lets you attach location-related opinions obtained directly from the agencies, as long as they are less than two years old or the underlying facts have not changed, and then there is no new consultation (Art. 13-A(16)).

Once the initial check is over, or the opinions are in, the council decides in 15 days on a simple PIP, filed under Article 14(1), and in 30 days on a full PIP, filed under Article 14(2), or in 45 days when the full PIP concerns a land subdivision (loteamento) (Art. 16(1)). The law provides for these two types only; there is no "paragraph 3" PIP.

For a full PIP, the mayor may extend the deadline once, for the same period, on grounds of the project's special complexity, for example a subdivision that includes infrastructure works. The extension must be notified to the applicant before the initial check ends (Art. 16(7)). The law does not provide for a general suspension of the decision deadline to ask for clarifications; the exception is a suspension of the procedure when the decision depends on a matter for another public body or a court (Art. 11(7)).

A favorable decision always states which procedure comes next (Art. 16(4)); an unfavorable one states how the project could be revised (Art. 16(5)). The outside agencies' opinions are notified together with the decision and form part of it (Art. 16(3)).

The RJUE does not say whether its deadlines are in business days or calendar days, but it falls back on Portugal's Code of Administrative Procedure (CPA, Art. 122 of the RJUE). Article 87 of the CPA does not count the day of the event that starts the clock, stops the count on Saturdays, Sundays and public holidays and, if the last day falls on a day the office is closed, moves the deadline to the next business day. In practice, the PIP's 20, 15, 30 and 45 days are business days.

In calendar weeks, with no consultations or correction requests, a simple PIP gets a decision, or tacit approval, about seven weeks after filing (20 + 15 business days), and a full PIP about ten weeks (20 + 30). Public holidays, outside consultations and any extension push that out.

An illustrative example, with no consultations or corrections and counting only Portugal's national holidays: a PIP filed on Monday, November 2, 2026 completes its initial check on November 30. Leaving out the December 1 and December 8 holidays, the 15-day deadline for a simple PIP ends on December 23, 2026; the 30-day deadline for a full PIP, on January 15, 2027. Always check the filing date on your receipt and the municipality's local holidays.

If the decision deadline passes without a decision, the PIP is tacitly approved (deferimento tácito, Art. 16(6)). You do not need to apply for anything for this to happen. The PIP title then consists of the completed request form, which contains a summary of the project, proof of fee payment and the filing receipt (Art. 16(8)(b)).

To prove tacit approval to third parties, the RJUE points to the CPA and to the certification scheme for tacit approvals in Article 28-B of Decree-Law 135/99 (Art. 111(c) of the RJUE). The gov.pt portal lets you request a certidão de deferimento tácito, a certificate of tacit approval valid for one year. Banks and notaries may also ask for written confirmation from the council, and it is worth requesting.

Tacit approval gives you a title, but it does not make a project that conflicts with the plan compliant: a PIP that breaches the municipal master plan (PDM) is void (Art. 68), and some municipalities take the view that a later express decision can prevail. Before buying or commissioning a design on the strength of tacit approval, have someone confirm that the project meets the rules and, if the council later issues an unfavorable decision, get legal advice before responding. The 2-year validity also runs from that date, as explained in PIP validity.

A late council should not stall your plans, but first confirm that the deadline really has passed. The court order to compel the council to decide, which the RJUE used to provide in former Article 112, has been repealed: with tacit approval, silence already has a favorable effect, and your job is to document it. Follow these steps.

• Rebuild the timeline: filing date, end of the initial check, any corrections, outside consultations and any extension notice. Many apparent delays are deadlines still running.
• Check the case on the council's online portal: there may be a decision or an electronic notice you have not seen yet.
• If the deadline has passed, put together the tacit approval title: request form, proof of payment and filing receipt.
• Ask the council in writing to confirm the tacit approval, and consider requesting the certificate of tacit approval.
• If fees are due after the decision, check the municipal regulations to see whether you can self-assess and pay them (Art. 117(5)).
• Record the date tacit approval took effect: the 2-year validity starts there.

The official sources are in Portuguese. Check the version in force before preparing a notice, project or application.

Want to find these guides more easily when you search on Google? Add Apto Group as a preferred source.