Section 2 · The 4 mandatory documents

What Each Document
Can Hide

4
documents, each concealing a different category of risk
1
IRN · Land Registry
Certidão Permanente
Land Registry Certificate
What it can hide
Active mortgage - an undischarged hipoteca the seller hasn't cleared before listing
Seizure orders - a penhora from unpaid tax that can freeze the sale entirely
Contested ownership - an acção judicial where a third party is legally challenging the title
Area discrepancy - registered m² differs from the Caderneta Predial, which can signal unrecorded changes
Exposure: depends on the charge
Can halt the sale entirely
RealOS Auto
2
AT · Tax Authority
Caderneta Predial Urbana
Property Tax Record
What it can hide
VPT gap - when the fiscal value is far below the purchase price, the AT can reassess upward post-sale, permanently increasing IMI
IMT exposure - transfer tax is calculated on whichever is higher: purchase price or VPT. A gap means you owe more than you budgeted
Undeclared area - registered m² smaller than physical reality, often because extensions were added without updating the tax record
IMI arrears - unpaid annual property tax which becomes your liability at completion
Exposure: a higher annual IMI
Permanent annual cost increase
RealOS Auto
3
Câmara Municipal
Licença de Utilização
Occupation License
What it can hide - critical under Simplex 2024
Unlicensed extensions - lateral or vertical additions to the original footprint not recorded in the municipal archive
Enclosed terraces - open balconies glassed or walled in after the original licence was issued, extremely common in Lisbon
Loft and garage conversions - habitable rooms created in non-licensed spaces, often marketed as "bonus rooms"
Active demolition order - a municipal enforcement action requiring removal of an unlicensed structure at the owner's expense
Typical legalisation: €5.5k - €7k
Or demolition if refused
RealOS Auto
4
ADENE · Energy Agency
Certificado Energético
Energy Performance Certificate
What it can hide - EPBD Directive 2024/1275
Class F rating - the lowest class on the current Portuguese scale (A+ to F); no Portuguese rule bans renting or selling it today
EPBD transposition - Portugal transposed part of Directive 2024/1275 through DL 11/2025; the rest is pending
Future national rules - minimum performance standards will be set nationally; none applies to a single home's sale today
Brown discount - energy-inefficient homes can sell at a discount; how much varies by market
Exposure: future efficiency work
No national deadline set yet
RealOS Auto
The pattern across all four
None of these problems are visible to the naked eye during a property visit - they only exist in the documents
Each document comes from a different authority and they don't automatically cross-reference each other
Under Simplex 2024, the licence is no longer checked at the deed, so check it yourself before the CPCV
All four must be verified before signing the CPCV - after it, walking away can cost you the deposit
Total financial exposure range
€22k
→ €347k+