A New Decree Puts a Twenty-Day Clock on BUPi Boundary Corrections, and Silence Now Snaps Your Land to the Public Domain

Nine days before free registration of rural land closes, the government has rewritten the rules that govern how a plot gets onto the map. Decreto Regulamentar n.º 8/2026, published in Monday's Diário da República (Official Gazette) and in force from Tuesday, puts firm deadlines into a process that previously ran without many, and adds a provision that should concentrate the mind of anyone whose boundary brushes against public land: miss the twenty-working-day window to correct an overlap, and the system corrects it for you, by moving your line to meet the state's.

The decree is the third amendment to Decreto Regulamentar n.º 9-A/2017, which regulates the simplified cadastral information system and the Balcão Único do Prédio (Single Property Desk, BUPi), the platform through which owners of rustic and mixed properties identify, delimit and then register their land. It was needed because Decreto-Lei n.º 87/2026 of 15 April had already changed the two underlying statutes, Lei n.º 78/2017 and Lei n.º 65/2019, leaving the regulation out of step. It was put out to public consultation and the Associação Nacional de Municípios Portugueses (National Association of Portuguese Municipalities), the Associação Nacional de Freguesias (National Association of Parishes) and the Comissão Nacional de Proteção de Dados (National Data Protection Commission) were all heard.

The georeferenced map becomes the gateway

The central change is one line in article 2. In municipalities without a predial cadastre, carrying out the representação gráfica georreferenciada (georeferenced graphic representation, RGG) is now a precondition not only for the special registration and justification procedures for rustic and mixed properties, but also for the special procedure to merge rustic properties. Merging two adjoining plots without first mapping them is no longer an option.

Around that sits a set of clocks that did not exist in the same form before. An RGG submitted through BUPi goes electronically to a qualified technician who must validate it within 20 working days of submission. If the technician finds the submission needs correction or completion, the applicant is notified electronically, or by registered post where that is impossible, and has 20 working days to make good, failing which validation is refused with written reasons. At the registry end, article 18 gives the registry office 30 days for its preliminary analysis of the documents, and gives the applicant 10 days to remedy any defect that is not a ground for outright refusal and cannot be fixed by the service pulling the information from another public database.

The automatic correction

The sharpest new provision concerns the public domain. Public bodies holding the relevant data must publish their geographic layers in BUPi with the limits of public-domain assets marked, and must update that information within 30 working days of whatever event changed it. Where a submitted polygon overlaps one of those assets, the Centro de Coordenação Técnica (Technical Coordination Centre) notifies the promoter or the interested party, with information identifying which public-domain assets are in conflict, and gives 20 working days to have the RGG corrected by a qualified technician.

Paragraph 8 then supplies the consequence. If that period passes without correction, the RGG "is automatically rectified, making all bordering boundaries coincide with the limit of the public-domain assets". There is no hearing in that sentence and no discretion. An owner who does not open the letter, or who is abroad when it arrives, finds the boundary redrawn against the state's line. Article 4 separately bars validation where a polygon overlaps public-domain assets whose limits are already geometrically defined in BUPi, or where the conflict is visible from the orthorectified imagery the platform provides, save where the law expressly permits it.

Neighbours are handled differently. Under the rewritten article 10, an RGG can be treated as validated where all the neighbouring plots capable of being georeferenced already exist in BUPi without conflicting shared boundaries; where a neighbouring property cannot be georeferenced through the platform, a declaration of acceptance signed by that owner is required instead.

A conciliation procedure with a hearing at the end of it

Article 16, which handles overlapping polygons that the system will not adjust automatically, has been rebuilt. Conciliation can now be opened on the initiative of the Technical Coordination Centre or the conciliator, or at the request of any interested party, though a party's request has to be made in person. Once a request arrives, the conciliator has 10 working days to create the procedure on the platform and may reject it summarily, with reasons, if essential elements are missing.

Interested parties who are not the applicant are then given 20 working days either to correct their own boundaries or to reach an agreement. If overlaps survive that, the conciliator must convene a conciliation hearing to be held within the following 20 working days, warning the parties that failing to agree means the RGGs for the properties in conflict stay validated with a reservation. The hearing may be held by audio and video link once the conditions allow. Partial agreements are formalised and written into the maps; what remains unresolved is closed off, and the parties are pointed to the julgado de paz (justice of the peace court), to the arbitration provided for in article 20 of Lei n.º 78/2017, or to the ordinary courts.

Article 17 keeps the sanction that sits behind the whole exercise. Where properties are not described in the registry, or are described but carry no current registration of acquisition, recognition of ownership or mere possession, the Instituto dos Registos e do Notariado (Institute of Registries and Notaries, IRN) notifies the holders of the tax entry, at their tax domicile, and gives them 90 days. If the notified party does nothing, the procedure for recognising a property without a known owner under Decreto-Lei n.º 15/2019 begins.

Annexes I to IV of the 2017 regulation are revoked; the forms and responsibility statements they contained will now be approved by order of the Technical Coordination Centre and published on the BUPi site. The decree was approved in the Council of Ministers on 30 July, promulgated by President António José Seguro on 11 September and countersigned on 14 September.

What this means for you

• The free window has not moved: BUPi's own frequently asked questions still state that identification and registration are free until 30 September 2026, and that registration may carry a cost after that date. The rule change does not extend it.
• Keep an address the state can reach: the twenty-working-day correction notice and the ninety-day IRN notice both go to an electronic address or, failing that, the post, and the IRN one goes to your tax domicile. For owners living outside Portugal, an out-of-date domicílio fiscal is the single most expensive detail here.
• If your land touches a river, a road, a path or the shoreline, look now: those are the public-domain layers the platform checks against. Finding the overlap yourself is far better than being told about it with a clock already running.
• A reserva de geometria is not a rejection: an RGG validated with a geometry reservation still exists and still supports registration. It marks an unresolved boundary, and conciliation, the julgado de paz or arbitration are the routes out of it.
• Planning to merge two plots: both now need an RGG in place first in municipalities without a cadastre. Build that into the timetable rather than discovering it at the counter.
• Background reading: our guide to registering rural land on BUPi sets out the steps and the documents, and we covered the extension of the free period in April.

BUPi exists because Portugal does not know who owns a large part of its own countryside, and the state has spent nine years coaxing owners onto the platform with free registration and gentle deadlines. Monday's decree is the point at which the coaxing acquires teeth. The deadlines are short, they are counted in working days, and for the one category of dispute where the other party is the state itself, letting the clock run out is now a decision with a map attached.