Planning & Design

01Legal update — August 2026#

Portugal's urban-planning framework is currently in a period of legislative transition.

Decree-Law 108/2026, of 29 May, introduces substantial amendments to the Portuguese Legal Framework for Urbanisation and Building, commonly known as the RJUE. Its general entry into force was subsequently postponed to 1 October 2026 by Decree-Law 155-B/2026, of 31 July.

Accordingly:

• procedures submitted before 1 October 2026 remain subject to the legislation applicable at the relevant date;
• procedures submitted from 1 October 2026 must be reviewed under the amended RJUE;
• transitional rules may apply to procedures already in progress;
• municipal platforms, forms and procedural practice may require adaptation;
• and the correct regime should be confirmed immediately before any application or communication is submitted.

The previously announced automatic repeal of the General Regulation for Urban Buildings, known as the RGEU, was also changed. The RGEU is now intended to remain applicable until the entry into force of the future legislation establishing the replacement technical building rules. See Decree-Law 108/2026 and Decree-Law 155-B/2026.

02Start with a written development brief#

Before the design team produces a concept, the developer should issue a coordinated development brief.

The brief should define the project's:

• Strategic purpose — build-to-sell, build-to-rent, hotel or tourism operation, serviced apartments, student accommodation, senior living, healthcare, offices, logistics, retail, mixed-use or another operating model.
• Target market — intended buyers or users, target price or rental range, expected unit mix, minimum product standards, accessibility requirements, service expectations and relevant international or operator standards.
• Development parameters — permitted use, construction area, footprint, height, number of floors, number of units, parking, external areas, landscaping, common facilities, technical areas, infrastructure and development phasing.
• Commercial parameters — target saleable or lettable area, target revenue, maximum construction cost, professional fees, planning and infrastructure costs, contingency, finance assumptions, target completion date and minimum return.
• Sustainability and performance — energy performance, water consumption, embodied carbon, operational carbon, materials, resilience, mobility, landscape, biodiversity, waste, building certification and long-term maintenance.
• Operational requirements — for an operating asset, the requirements of the intended operator, manager, franchise or brand, which may affect room or unit sizes, circulation, kitchens, back-of-house areas, servicing, loading, staff facilities, fire strategy, security, acoustics, technical systems and maintenance access.

A brief that is not commercially and operationally validated can produce a licensable project that does not support the investment case.

03Build the right project team#

The required team depends on the scale, use, complexity and location of the project.

Key roles include:

• Developer or project owner — defines investment objectives, approves the budget and makes the principal project decisions.
• Development manager — coordinates the business plan, design, licensing, procurement and delivery strategy.
• Project manager — controls programme, responsibilities, deliverables, meetings, decisions, dependencies, reporting and change management.
• Lead architect — develops the architectural concept and coordinates its integration with planning, engineering and operational requirements.
• Planning and legal advisers — assist with interpretation of territorial plans, urban-planning procedures, administrative precedents, title and development rights, municipal requirements, external consultations and contractual appointments.
• Engineering team — structural, water and drainage, electricity, telecommunications, gas, mechanical systems, HVAC, energy and thermal performance, acoustics, fire safety, lifts and vertical transport, roads and infrastructure, and specialist installations.
• Survey and investigation team — topographical surveyor, cadastral specialist, geotechnical engineer, environmental consultant, structural surveyor, utilities surveyor, archaeologist and contamination specialist.
• Cost consultant — tests the design against the approved budget at every stage.
• Landscape architect — affects planning integration, open space, water management, fire resilience, biodiversity, visual impact and value.
• Sustainability consultant — translates environmental objectives into measurable design requirements and assesses cost and operational consequences.
• Operator and commercial advisers — hotels, tourism, healthcare, senior living, logistics and other operational developments should involve the operator or specialist adviser early.

04Establish the verified project baseline#

The design team should not begin from unverified drawings or seller information.

The baseline should include, as applicable:

• current land registry information;
• tax registration information;
• confirmed site boundaries;
• topographical survey;
• cadastral information;
• existing building surveys;
• the last valid municipal record;
• approved drawings;
• use titles or other evidence of lawful use;
• existing licences, communications and prior information decisions;
• applicable territorial plans;
• allotment or subdivision documents;
• easements and public-law restrictions;
• infrastructure records;
• utilities capacity;
• geotechnical information;
• environmental constraints;
• heritage and archaeological information;
• operator requirements;
• and the acquisition assumptions.

Discrepancies should be resolved before they are incorporated into the design. An inaccurate boundary, incorrect building record or invalid assumption about the lawful existing condition can affect the entire project.

05The planning and design sequence#

The phase moves from a written brief through constraints, concept, validation, planning strategy, architectural and specialist development, and finally into detailed design and procurement information.

06Request for Prior Information — PIP#

A Request for Prior Information, commonly called a PIP, asks the municipality to provide a formal position on the feasibility or applicable conditions of a proposed urban operation.

A PIP can be particularly valuable when:

• the planning interpretation is uncertain;
• the acquisition remains conditional;
• the project involves material planning risk;
• the land is being marketed on the basis of unconfirmed development capacity;
• external authorities must be consulted;
• the project is intended to be sold before full licensing;
• or the investor requires greater certainty before committing further capital.

07Licensing, prior communication or exemption?#

The Portuguese RJUE establishes different procedural routes for urban operations.

Architecture approval is not construction approval. A municipal decision approving the architectural project generally confirms only the matters legally assessed at that stage. The developer may still need to complete specialist projects, external consultations, sector-specific approvals, municipal fees, infrastructure arrangements, contractor appointment, construction-professional appointments, commencement information, insurance, guarantees and other statutory requirements. Do not instruct a contractor to mobilise solely because the architecture has been approved.

08Specialist engineering projects#

Depending on the development, specialist projects may include structural stability, excavation and retaining structures, water supply, wastewater and stormwater drainage, electricity, telecommunications, gas, mechanical ventilation, heating and cooling, thermal and energy performance, acoustics, fire safety, lifts and vertical transport, roads, parking systems, landscape irrigation, waste systems, renewable energy and external infrastructure.

Under the simplification measures introduced in 2024, municipalities do not generally perform prior technical approval of the internal specialist engineering solutions in the same manner as the architectural and planning assessment.

Specialist projects are supported by responsibility declarations signed by qualified professionals. This does not reduce the obligation to comply with the applicable legislation. It also does not eliminate professional liability, external approvals legally required for particular systems, certification, inspections, contractor responsibility, municipal enforcement or the developer's need for independent quality control.

The absence of detailed municipal technical review should not be treated as proof that the specialist design is correct or coordinated.

09External consultations and sector-specific approvals#

A municipal procedure may require input from external authorities because of the project's location, use, environmental impact, heritage context, infrastructure, road access, proximity to water, protected landscape, aviation constraints, tourism classification, fire risk, healthcare use or other regulated characteristics.

Relevant entities may include, depending on the project:

• territorial coordination authorities;
• environmental authorities;
• heritage authorities;
• road authorities;
• water and utilities entities;
• tourism authorities;
• civil-protection or fire-safety authorities;
• health authorities;
• and infrastructure concessionaires.

Some consultations are promoted within the municipal procedure. Others may have to be obtained directly by the applicant or through a separate legal procedure. The team should establish which entities must be consulted, who initiates each consultation, what information is required, whether the opinion is binding, its validity period and whether a project amendment requires renewed consultation.

10Design for planning, construction and operation#

A successful project must satisfy three different tests.

The project must pass:

• Planning compliance — can the project be lawfully approved or carried out under the applicable planning framework?
• Construction viability — can the project be built safely, efficiently and within the approved budget and programme?
• Operational and commercial performance — will the completed development meet the requirements of buyers, tenants, operators, lenders and investors?

A project that passes only one or two of these tests is not ready to proceed.

11Area definitions must be controlled#

Development projects frequently use multiple area measurements. These may include site area, footprint, total construction area, gross floor area, saleable area, lettable area, private area, common area, technical area, external covered area, balconies and terraces, and areas counted differently for planning, tax, valuation or sales purposes.

The project should maintain a controlled area schedule defining:

• each measurement;
• the applicable standard;
• included and excluded areas;
• source drawing;
• design version;
• and responsible person.

Planning area, construction area and saleable area should never be assumed to be identical. An error in area definitions can affect planning compliance, purchase price, construction cost, revenue, finance, valuation, marketing and sale documentation.

12Existing buildings and rehabilitation projects#

Projects involving existing buildings require additional investigation. Confirm the lawful existing condition, the last valid municipal record, authorised use, historic alterations, unlicensed works, structural condition, heritage restrictions, retained façades or elements, party walls, existing easements, access, fire strategy, accessibility, seismic requirements, energy performance and the technical feasibility of the proposed use.

Do not assume that the building's physical condition corresponds to the approved municipal drawings. Where discrepancies exist, determine whether they can be:

• accepted as lawful;
• documented;
• corrected;
• licensed;
• legalised;
• demolished;
• or incorporated into the new project.

A new project should not be designed on top of an unresolved unlawful condition.

13Tourism and hospitality projects#

Hotels, tourist apartments, resorts and other tourism developments require coordination between urban planning, tourism legislation, classification requirements, operator standards, fire safety, accessibility, health and hygiene, food and beverage, leisure facilities and operational licensing or registration.

The intended tourism category and operating model should be defined before the design is fixed. Late operator involvement can require expensive changes to:

• room dimensions;
• back-of-house areas;
• kitchens;
• staff circulation;
• lifts;
• plant;
• storage;
• waste;
• loading;
• reception;
• leisure facilities;
• and fire compartmentation.

Urban permission to construct a building does not, by itself, confirm that the completed asset can lawfully operate under the intended tourism model.

14Loteamento and urbanisation works#

Larger developments may require an allotment or subdivision operation, urbanisation works or another territorial implementation mechanism. These can involve creation of plots, roads, pedestrian areas, parking, public spaces, green areas, utility networks, municipal transfers, infrastructure reinforcement, compensation payments, guarantees, public consultation and phased reception of works.

The development model should establish:

• which land remains private;
• which areas are transferred;
• which infrastructure is built by the developer;
• who owns and maintains it;
• the applicable guarantees;
• completion and reception procedures;
• and the effect of phasing on building construction and sales.

Infrastructure cost and timing can materially change the feasibility of the entire project.

15Design coordination#

Every project should have a documented coordination process.

16BIM and digital coordination#

Building Information Modelling can assist with multidisciplinary coordination, clash detection, quantity extraction, change control, asset information and construction sequencing.

BIM does not correct an incomplete brief or unclear contractual responsibility. The required models, detail levels, ownership, permitted uses and delivery formats must be defined in the appointments.

17Cost control during design#

Cost planning should run in parallel with design. At each stage, compare the project against approved construction cost, infrastructure cost, professional fees, municipal charges, finance cost, contingency, revenue and return.

Value engineering should improve the balance between cost, function, quality and risk. It should not be a late exercise that removes essential performance or creates licensing and coordination problems.

18Design changes#

Every material change should be assessed for its effect on planning compliance, existing approvals, external consultations, structural design, fire safety, accessibility, energy, acoustics, infrastructure, construction cost, programme, procurement, finance, operator requirements and sales commitments.

Changes to an approved or submitted project may require:

• a revised municipal procedure;
• an amendment;
• prior communication;
• further information;
• updated responsibility declarations;
• renewed external consultation;
• or post-completion legalisation.

A change is not legally immaterial merely because it appears minor from a commercial perspective.

19Preparing for procurement and construction#

Before the project enters procurement or construction, confirm that the documentation is sufficient for the chosen delivery model. The package may need to include coordinated architectural drawings, coordinated engineering drawings, specifications, schedules, finishes, performance criteria, scope boundaries, employer's requirements, interface matrix, quantity information, construction programme assumptions, phasing, logistics, temporary works requirements, quality-control procedures, mock-ups, commissioning requirements, completion deliverables and as-built information requirements.

Unresolved design should be identified expressly. If part of the design is delegated to the contractor, define:

• the delegated scope;
• performance standard;
• approval procedure;
• design liability;
• professional qualifications;
• insurance;
• coordination responsibility;
• and ownership of the resulting documents.

20Planning and design cost categories#

The budget may need to include architects, engineers, planning consultants, legal advisers, project management, development management, cost consultancy, topographical survey, cadastral work, geotechnical investigation, environmental studies, structural surveys, heritage and archaeological studies, fire engineering, accessibility advice, sustainability consultancy, operator or sector consultants, BIM management, models and visualisations, municipal fees, external authority charges, infrastructure studies and contingency for design changes.

Professional fees should be linked to:

• scope;
• deliverables;
• project stages;
• programme;
• number of revisions;
• meetings;
• coordination duties;
• submission responsibility;
• construction support;
• and completion documents.

A low initial fee may become expensive if the appointment excludes essential coordination or construction-stage services.

Indicative timing#

Planning and design periods vary significantly by project. As an initial planning assumption:

Typical durations include:

1. 1project brief and team mobilisation: 2–4 weeks;
2. 2surveys and baseline investigations: 3–10 weeks;
3. 3concept and massing: 4–10 weeks;
4. 4feasibility validation: 2–4 weeks;
5. 5PIP preparation: 4–12 weeks;
6. 6municipal PIP procedure: several months, depending on consultations and complexity;
7. 7architectural project: 3–8 months;
8. 8municipal licensing procedure: dependent on the procedure, completeness and external consultations;
9. 9specialist engineering: 2–6 months;
10. 10detailed design and procurement information: 3–8 months.

These activities may overlap. Statutory municipal decision periods are not equivalent to the total end-to-end programme. The programme must also allow for preparation, surveys, external consultations, corrections, public consultation, fees, project-team responses, finance, procurement and transitional legislative requirements.

Common planning and design mistakes#

1. 1Designing before verifying the planning framework — an attractive concept has limited value if it conflicts with the applicable plan, restrictions or infrastructure capacity.
2. 2Maximising area without testing commercial efficiency — more construction area can produce higher cost, inefficient layouts, increased parking and infrastructure obligations, or lower product quality.
3. 3Treating a PIP as a generic confirmation — a favourable PIP only protects the parameters and proposal actually assessed within its legal scope and validity period.
4. 4Assuming architectural approval allows construction to begin — further projects, documents, fees, titles and commencement requirements may remain outstanding.
5. 5Assuming that specialist projects are approved by the municipality — professional responsibility and technical compliance remain with the qualified project authors and other responsible parties.
6. 6Ignoring the legislative transition — the applicable RJUE procedure may depend on whether the submission occurs before or after 1 October 2026.
7. 7Assuming that the RGEU has been repealed — its repeal has been deferred until the replacement technical building legislation enters into force.
8. 8Appointing disciplines too late — late structural, fire, mechanical, operator or cost input can require substantial redesign.
9. 9Using inconsistent area definitions — different area measurements can distort planning, cost, valuation, finance and revenue assumptions.
10. 10Failing to verify the lawful existing condition — physical construction does not prove that an existing building or alteration is legally authorised.
11. 11Submitting an uncoordinated project — conflicts between architecture and engineering create delays, variations and construction claims.
12. 12Freezing the commercial model too late — changes to unit mix, operation or specification after planning submission may require redesign or procedural amendments.
13. 13Leaving design responsibility unclear — missing or overlapping responsibility creates gaps that often emerge only during construction.

Frequently asked questions#

Official sources and further reading#

• RJUE — Legal Framework for Urbanisation and Building
• Decree-Law 10/2024 — urban-planning simplification measures
• Decree-Law 108/2026 — revision of the RJUE
• Decree-Law 155-B/2026 — postponement to 1 October 2026
• Portaria 71-A/2024 — documents required for RJUE procedures
• Law 31/2009 — qualifications of project and construction professionals
• Law 3/2026 — amendment to the professional qualification framework
• General Regulation for Urban Buildings — RGEU
• RJIGT — territorial management instruments
• National Territorial Information System — SNIT