Key figures — as of 2026-09-16: Decree-Law 97/2026 (published 20 May 2026) cut construction VAT from 23% to 6% and is already in force — but the Regime Simplificado do Arrendamento Acessível (RSAA), legally effective since 1 September 2026, still has no published rent-cap rules or working landlord platform — Housing Secretary of State Patrícia Gonçalves Costa said on 15 September the missing rule would land "nos próximos dias" — APPII estimates Portugal is short 150,000–200,000 homes against roughly 28,000 completions expected in 2026.
A law that's live but half-empty
Portugal's much-promoted housing tax package isn't stuck in a drawer — it was signed off months ago. Decree-Law 97/2026, published on 20 May 2026, cut VAT on residential construction and rehabilitation from 23% to 6% for qualifying projects, and that measure is already being applied. The problem foreigners renting or building in Portugal are running into now is narrower but just as consequential: the piece of the package aimed squarely at putting more affordable rentals on the market has a law but no instruction manual.
The Regime Simplificado do Arrendamento Acessível, or RSAA, was written into that same decree-law to replace the old rental support programme and let landlords who cap rents get an IRS or IRC exemption. The regime entered into force on 1 September, but the regulation indispensable to its application — namely the ministerial order defining maximum rent limits by property type — is still awaiting publication. The electronic platform on the Portal da Habitação, managed by the IHRU, where landlords and prospective tenants are meant to register for the RSAA, is also not yet active.
That's not a minor technicality. Knowing the maximum rent a property can charge under the scheme is essential information for owners deciding whether to sign up. Without it, landlords who might otherwise list a flat at a discounted, tax-exempt rent have no way to calculate whether the deal makes sense — so many are simply not listing at all.
The government's own deadline, missed
The decree-law itself set a target. It stated that by 1 September 2026 the electronic platform adaptations needed to apply the new rules — specifically for the Investment Agreements for Leasing and the RSAA — would be made available. That didn't happen. Asked by Lusa, the Ministry of Infrastructure and Housing said only that the missing order "is for publication," without clarifying when the IHRU platform would be operational.
By mid-September, the government put a softer timeline on it. Housing Secretary of State Patrícia Gonçalves Costa announced that the order setting maximum rent limits by property type would be published "in the coming days." She added that the platform "is already designed," with only the order missing to bring it into operation, because the legal changes required redesigning parts of the system that hadn't been anticipated. Landlord groups aren't impressed. The Associação Lisbonense de Proprietários criticised "the lack of essential regulation for owners to be able to join" the RSAA, arguing an electronic platform only simplifies anything once it actually exists and is ready to run.
Why the delay matters beyond one rental scheme
The stalled portaria sits inside a bigger supply problem the tax package was supposed to help fix. The Portuguese Association of Real Estate Developers and Investors (APPII) estimates Portugal is short between 150,000 and 200,000 homes, while roughly 28,000 new dwellings are expected to be completed this year — a fraction of the 100,000 a year built in the early 2000s. Labour shortages of up to 100,000 workers, a tax burden that can represent up to 40% of a project's final cost, and slow licensing keep dragging on the market's response. Developers themselves aren't fully sold on the fix. Many see the government's measures as ambitious but doubt their execution given how dependent they are on a fragile political cycle, with one landlord association head warning "É uma instabilidade muito grande."
There's also a design worry flagged by Parliament's own budget watchdog. The Unidade Técnica de Apoio Orçamental estimates the cost of three of the package's main measures at over €300 million, and cautions that setting the "moderate" rent ceiling at €2,300 — above the market median — could push prices up rather than contain them, letting landlords absorb the tax benefit rather than pass on savings.
GrowIN's read on the numbers: at the roughly 28,000 completions the sector is on track for in 2026, closing APPII's estimated 150,000–200,000-home gap would take somewhere between five and seven years of building at the current pace — before factoring in any extra demand from foreign residents still arriving under D7, D8 or work visas. The tax breaks may eventually widen the pipeline, but the maths shows why any single year's delay in getting incentives running compounds a shortage measured in years, not months.
What foreigners should watch
For now, the VAT cut on construction is real and usable for anyone building or renovating a qualifying primary home; the affordable-rent exemption for landlords is not, in practice, until the rent-cap order and IHRU platform appear. Foreign renters hoping cheaper, tax-favoured listings will show up this autumn should treat any promise of imminent supply with caution — check our tax and NIF hub for how the VAT and IMT changes apply to your situation, and expect the RSAA rollout to slip further before it works as advertised.
As GrowIN Portugal Editorial puts it: a decree-law with no rent-cap dial doesn't create a single new lease.
The next marker to watch is whether the Council of Ministers actually publishes the portaria this month, and whether the IHRU platform goes live in step with it — until then, the incentive exists mostly on paper.