The RJUE reform does not stand alone. Alongside Decree-Law no. 108/2026, Ordinance no. 320/2026/1 was published, approving the application and notification forms and identifying the documents required for urban-control procedures.
It looks like a technical instrument. In practice, it determines what you must file with the Municipality, on which form, and what the Municipality may (or may not) demand of you. Three changes have direct consequences.
1. Three single forms for the whole country
The Ordinance consolidates the forms and the list of required documents into one instrument. There will essentially be three forms applicable throughout the national territory, matching the three administrative stages of an operation: the design stage (single form for a licence application, prior communication and prior information request — article 4-A of the RJUE); the start-of-works stage (information on the commencement of works — article 80-A); and the use stage (prior communication of use or change of use — articles 62-A and 63).
The design-stage form also serves the improvement of an application, the filing of additional documents and the submission of specialist designs. Use of these forms is mandatory. The end of dozens of different municipal forms is in itself a relevant simplification for anyone operating across several municipalities — and the Ordinance prepares the transition to the future electronic urban licensing platform, interoperating with municipal systems.
2. The single form becomes sufficient title in property transactions
For real estate practice, this is the most consequential change.
The preamble identifies a serious problem of legal uncertainty, felt above all in cases of tacit approval: proof of payment of fees was insufficient to characterise the urban operation adequately, notably in property transactions and in notarial and land-registry acts. Anyone who has tried to complete a deed or a registration on the basis of a tacit approval knows the difficulty.
The solution adopted: the single form will incorporate a summary of the essential elements of the urban operation, as declared by the applicant (annexes I-A to I-D contain those urban summaries by type of operation: subdivision, infrastructure works, building or demolition works, land remodelling). Together with proof of payment of the fees and other charges due, it becomes sufficient title to evidence the lawfulness of carrying out the urban operation and for all other legal purposes, including in property transactions.
For buyers and sellers: there will be a standardised document characterising the operation and serving as title before notaries and registries. It does not remove the need for substantive verification — a title resting on the applicant’s own declarations remains, to a large extent, the applicant’s declaration — but it resolves a practical bottleneck that delayed and inflated the cost of countless transactions.
3. A brake on municipal demands for documents
The third change is the one that saves most time and money in real cases. Article 2 of the Ordinance sets clear rules on what may be required:
• Documents not listed in the annexes may only be required where expressly provided for in the RJUE, in special legislation, or where strictly indispensable to verify compliance with territorial planning programmes and plans (no. 3).
• And, crucially: any such requirement must be duly reasoned by the municipality, indicating the specific provision it relies on (no. 4).
In practice this gives applicants an immediate written argument against generic, repeated or unfounded requests for documents — one of the most common causes of delay in municipal proceedings. The burden shifts to the municipality: if it demands, it must say under which rule.
The converse is also provided for: the applicant may omit documents that are unnecessary given the specific application, provided the design coordinator justifies the omission in a reasoned, separate document — a judgement assessed at the preliminary examination stage (nos. 6 and 7).
Strengthened statements of responsibility
The Ordinance reformulates the statements of professional responsibility in line with Law no. 31/2009, of 3 July. Notably, the statement of the author of the lead design — typically the architectural design, or the subdivision design — must now expressly identify the applicable urban constraints and parameters, cross-referring to the written and drawn documents. The design coordinator’s statement is refined and the statements of the works director and supervision director are reintroduced. It is also clarified that the accessibility plan forms part of the lead design.
The flip side of simplification is familiar: less prior control means more responsibility for technicians and declarants, and greater exposure to subsequent enforcement. Careless declarations in an urban summary that now serves as title carry consequences.
What to do
If you have applications to file: assess whether it pays to file before or after 1 October, and prepare the submission using the new annexes, since the forms become mandatory from that date.
If you are buying: start requesting the single form and proof of fees as part of the property’s urban documentation, especially where the operation rests on tacit approval — and continue verifying substance, because the summary is declared by the applicant.
If you have a pending request for documents: assess whether the demand is reasoned with reference to a specific provision. From 1 October, if it is not, there are grounds to challenge it.
Do you have a municipal application pending, or about to file? Paulo Silva Silva, Lawyer, assists with the preparation of applications, responses to municipal demands and urban-planning verification on acquisitions. Book a meeting or contact geral@advpaulosilvasilva.com · +351 916 055 901.
This article is general in nature and does not constitute legal advice. The specific content of the required documents is set out in the annexes to the Ordinance and varies by type of urban operation; it should be confirmed in the version in force in the Diário da República before filing any application.