Section 3 · Buyer liability window
The Nullity Window: 10 Years, Now 3
Until 30 September 2026 an unlawful licensing act could be declared null for up to ten years from its issue. From 1 October 2026 the period is three years (RJUE Art. 69.º n.º 4), counted from 1 October 2026 for acts already issued. The clock runs from the act, not from your escritura.
Inspect OS PROPERTY INSPECTION
Day 0
Escritura
Ownership transfers
Any time
Câmara may inspect
Inspection is not time-barred
1 Oct 2026
New regime
3-year nullity clock starts for existing acts
+3 years
Nullity window
Open for acts already issued, unless the old 10 years ends sooner
Before 1 Oct 2026
Old regime
10 years from the act
Embargo
Immediate suspension of use of illegal construction
RJUE
Demolition Order
Order to demolish unlicensed structures at owner's expense
RJUE
Use Cessation
Prohibition on using the property or part of it
RJUE
Fines
Administrative fines for occupying without valid licence
€499–€99,759 · RJUE Art. 98
"The nullity clock runs from the licensing act, not from your purchase."
RJUE Art. 69.º · Sérvulo & Associados legal analysis · MATLAW urban planning analysis 2024