Portugal's Simplex Urbanístico: what Decree-Law 10/2024 changed and what the 2026 revision reversed

Decree-Law 10/2024 was adopted under the legislative authorization in Law 50/2023 of August 28 and delivers a reform set out in Portugal's Recovery and Resilience Plan. Its preamble frames it as part of the SIMPLEX program, with a "zero licensing" approach: abolishing unnecessary permits, authorizations and administrative acts, making procedures uniform across municipalities, and making new housing faster and cheaper to deliver.

It is not a standalone regime. It is a decree-law that amended other laws: mainly the RJUE (Decree-Law 555/99), but also the RGEU (Regulamento Geral das Edificações Urbanas, the 1951 general building regulation), the Portuguese Civil Code, the framework law on land use and planning, the rules on planning instruments (RJIGT), the urban regeneration regime and the rules on heritage protection zones. That is why the question "is the Simplex still in force?" has to be answered measure by measure.

The rules in force since October 1, 2026, procedure by procedure, are in the guide on the RJUE in 2026. This guide covers the sequence: what the Simplex did, when, and what happened to it in the revision.

The Simplex did not take effect all at once. Article 26 of Decree-Law 10/2024 set several dates, and the 2026 revision added more. The date that matters for most building work is March 4, 2024; for the deed, January 1, 2024.

For building work and municipal procedures, these were the 2024 measures with the most practical effect:

• More exempt work: rebuilding and extensions that did not raise the façade height, even if they added floors and usable area, no longer needed a permit or prior notice; the same went for interior work affecting the structure, with a professional's statement of responsibility, and for replacing window frames with more efficient ones that look the same from outside (RJUE Articles 6(1)(b) and (e) and 6-A(1)(j)).
• Prior notice made mandatory: if a project fell under comunicação prévia you could no longer opt for a permit, and execution units with certain parameters also qualified for comunicação prévia (Article 4).
• Tacit approval of permits: the câmara municipal (municipal council) was given an overall deadline of 120 days (up to 300 m² of gross floor area), 150 days (up to 2,200 m² and listed buildings) or 200 days (larger projects, subdivisions and infrastructure works), counted from filing, after which the permit was tacitly approved (Article 23).
• No more paper permits: a permit was evidenced by the fee payment receipt, and a prior notice by proof of filing (RJUE Article 74 and Decree-Law 10/2024, Article 21).
• PIP: a favorable PIP (pedido de informação prévia, a binding prior information request) became valid for 2 years, plus 1 year with a confirming declaration, and a PIP that assessed the items in Article 14(2), or covered an area with a detailed plan or subdivision, exempted the work (Article 17).
• Less review and less paperwork: the council stopped reviewing building interiors and engineering designs, and could no longer ask for documents not listed in the ministerial order, such as the caderneta predial (property tax record) or copies of documents it already holds (Articles 3, 9(12) and 20).
• Completeness check: if the council did not ask for corrections or reject the application outright, it counted as complete and could not be refused for missing documents (Article 11(5)).
• No mandatory police presence: police supervision could no longer be required at works, even when a street was closed (Article 40-A).

Beyond building work, the Simplex changed rules that matter to anyone buying, selling or changing the use of a property:

• Use after building work: the use permit was replaced by filing the statement of responsibility from the site manager or supervising engineer and, if the design had changed, the as-built drawings; the building could be used immediately and the filing could not be refused (RJUE Article 62-A).
• Change of use without work: handled through a comunicação prévia com prazo (prior notice with a waiting period), with use allowed 20 days after filing unless an inspection was ordered (Articles 62-B, 63 and 64).
• The deed: from January 1, 2024, the use permit and the home's technical file no longer had to be shown; whoever executed the deed only warned the buyer that the property might lack planning titles (Decree-Law 10/2024, Article 19).
• RGEU: a bidet was no longer mandatory, a shower was allowed instead of a bathtub, and kitchens could be merged with other rooms, except bathrooms, as kitchenettes, cupboard kitchens or walk-through kitchens (RGEU Articles 66 and 68). The RGEU itself was set to be repealed on June 1, 2026.
• Condominiums: changing a unit's use to housing no longer needed the other owners' approval (Portuguese Civil Code, Article 1422-B).
• Land: fast-track procedures were created to reclassify rural land as urban for industry, logistics or housing (RJIGT Articles 72-A and 72-B), since amended, as explained in the guide on rural land that can become urban.

Decree-Law 108/2026 did not repeal the Simplex. Its preamble acknowledges that the 2024 reform ran into problems of implementation and consistency, and presents the revision as an adjustment of its measures, to simplify with more legal certainty. Still in force, among others:

• Tacit approval of permits, now at each stage of the procedure (RJUE Articles 20(12) and 23(1)).
• No option to choose a permit when the work falls under comunicação prévia (Article 4(6)).
• The 2-year validity of a favorable PIP, plus 1 year with a declaration that the underlying facts and rules still hold (Article 17(5) to (7)).
• The end of paper permits: references to alvarás now read as references to the operation's title (Decree-Law 108/2026, Article 9(3)).
• The end of council-issued use permits, now complete: building use is always covered by a notice (Decree-Law 108/2026, Article 9(2)).
• The list of documents councils cannot require, such as the caderneta predial or copies of documents they already hold, and the rule that interiors and engineering designs are covered by the professionals' statements of responsibility, without prior review (Articles 9(12) and 20(8)).
• The 2024 changes to the RGEU and the Civil Code rule on changing a unit's use to housing, which the revision left untouched.
• The requirement to file architectural designs in BIM from January 1, 2030 (Decree-Law 10/2024, Article 17(1)).

The preamble to Decree-Law 108/2026 explains the corrections. On comunicação prévia, it admits that it had stopped being real prior control, because the council only checked the paperwork formally during the completeness check; so it scrapped that stage and now requires the work to be in an area where the planning parameters are actually defined. On permits, it finds that deadlines tied to gross floor area did not reflect real complexity, and brings back stage-by-stage deadlines that can be extended for complex projects.

On titles, it takes the view that a payment receipt alone does not say what was authorized, and brings back a title that includes a summary of the operation, so that it holds up with third parties and in property transactions. On the deed, it seeks a balance between legal certainty and freedom to transact: you can still buy a property with no title, but the deed itself tells you so. And on the RGEU, it ties the repeal to the entry into force of new technical building rules, to be drafted with the professional bodies.

The table compares the measures that changed again. The right-hand column is the regime for procedures started on or after October 1, 2026, and for those still in the completeness check on that date.

The full regime now in force, with each stage's deadlines, is in the guide on the RJUE in 2026. If you have an application filed before October 2026, or work done under the Simplex rules, a prior information request gets you the council's written position under the current rules.

The revision does not undo what was done under the Simplex. The new rules apply to procedures started on or after October 1, 2026, and to those still in the completeness check on that date (Decree-Law 108/2026, Article 12); the new deadlines for lapse and nullity apply to everything, counted from that date, unless the old deadline ends sooner. That leads to a few typical situations:

• Exempt work done between 2024 and 2026, such as an extension that did not raise the façade: if it met the exemption's conditions and the PDM (Plano Diretor Municipal, the municipal master plan), it needed no title, and the RJUE treats as the last valid precedent an operation that needed no title when it was done (Article 2(r)). Keep proof of the date and, if you filed one, of the start-of-work notice. New work on the same building follows today's rules.
• Permit evidenced by a receipt: Decree-Law 108/2026 does not require those titles to be replaced. Keep the fee receipt with the decision or the proof of tacit approval, because that is what you will show at the deed or to the bank.
• Building use handled between 2024 and 2026: filing the Article 62-A documents, or a prior notice with a waiting period that met no objection, allowed the building to be used; keep the proof of filing. The habitation license guide explains how to put together a home's use title.
• PIP issued under the Simplex: valid for 2 years from the favorable decision, as explained in the PIP validity guide. If it exempted the work only because the site was in a detailed plan or subdivision area, check with the council whether the exemption still holds for work started after October 1, 2026.
• Sales: until September 30, 2026, the warning was enough; since October 1, 2026, the deed must state the planning title position, even if the property or the work is old.
• Work done without a title or differing from the design: the route is still building legalization, now with the fine for work without a title back in place.

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

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