Programa de Apoio ao Arrendamento Runs Seven Years Without IHRU Inspections — Tax Exemptions on Roughly 1,000 Active Contracts Sit Unchecked as the Simplified Accessible Rental Regime Takes Over From the 2019 Scheme on 1 September 2026

An external evaluation commissioned by the Instituto da Habitação e da Reabilitação Urbana (Institute for Housing and Urban Rehabilitation, IHRU) and surfaced in Público on Monday 8 June 2026 lands a hard finding on the central instrument of Portugal's 2019 affordable-rental architecture: the Programa de Apoio ao Arrendamento (Rental Support Programme, PAA) has run for seven years without IHRU ever auditing the contracts it certifies. The evaluators' phrase is blunt — "there is no control of non-compliance" — and the universe at stake is unexpectedly small: roughly 1,000 active contracts in the entire country.

What the PAA actually does

The PAA, created by Decreto-Lei n.º 68/2019, gives landlords full IRS and IRC exemption on rental income from contracts where the rent is set at least 20% below the municipal market reference for the property's typology and area. The trade is straightforward: take the haircut on rent, hand the tax back to the landlord, route a discounted unit to a tenant inside the income brackets the regulation defines. The administrative entry point is the IHRU, which validates the contract and issues the certificate the Autoridade Tributária e Aduaneira (Tax and Customs Authority, AT) reads when processing the landlord's annual IRS or corporate IRC return.

The audit gap

The evaluators' point is that the certificate is the end of the process, not the beginning. The IHRU has neither the personnel nor the protocol to check, after the fact, that the tenant continued to meet the eligibility ceilings, that the rent stayed inside the 20%-below-market band, or that the unit was actually occupied as a permanent residence. AT, for its part, applies the exemption on the basis of the IHRU certificate without conducting its own substantive review. The result, the evaluators write, is that the state cannot say whether the foregone tax revenue ever landed in the policy bucket it was designed for. With ~1,000 contracts on the books, the absolute exposure is modest in fiscal terms — but the audit-trail vacuum applies equally to the architecture, not just the volume.

Why uptake stalled at ~1,000 contracts

The 2019 design was supposed to mobilise the private rental stock at scale. Seven years in, the take-up tape sits well below initial projections — a function of paperwork friction at the IHRU validation step, landlord wariness about being locked into below-market pricing for the contract term, and the parallel availability of the Alojamento Local (short-term rental) circuit which paid better in tourist-heavy zones for most of the same window.

The September replacement: RSAA

The PAA does not survive the year. The Regime Simplificado do Arrendamento Acessível (Simplified Accessible Rental Regime, RSAA), part of the housing-tax package the government published on 20 May 2026, takes effect on 1 September 2026 and replaces the 2019 scheme. The headline mechanics: full IRS and IRC exemption on rental income for contracts priced at no more than 80% of the median square-metre price reported by the Instituto Nacional de Estatística (National Statistical Institute, INE) for the property's freguesia, with a three-year minimum term for permanent-residence occupation. The validation moves to an electronic platform the IHRU will run, with automated communication to AT — the gap the PAA evaluators flagged.

The supervision architecture, this time

The RSAA's monitoring regime is supervised by the IHRU in collaboration with AT, Segurança Social (Social Security) and INE. The legislation pencils an interim report due by end-2028 and a final evaluation by end-2030. Whether the four-agency coordination produces the audit cycle the PAA never had is the question the 2030 report will be expected to answer — by which point the volume of contracts under the new rules, and the size of the IRS hole they cut, should be on a different order of magnitude than the 2019 instrument's thousand-line ledger.