Industrial Licensing: What You Need to Know Before Renting a Warehouse
Practical guide to the Sistema da Industria Responsavel (SIR): types 1, 2 and 3, documentation, timelines, costs and what to check in the warehouse before signing a contract.
- Industrial licensing is mandatory to carry out industrial activity in Portugal, even in a rented warehouse. The responsibility lies with the tenant, not the landlord.
- The SIR (Sistema da Industria Responsavel) classifies establishments into 3 types: type 1 (highest risk, ~2% of industries), type 2 (intermediate risk) and type 3 (lowest risk, majority of companies).
- Type 3 is the most common for logistics warehouses: a simple prior notification, immediate start of activity, cost of ~€95 or free in some municipalities.
- Types 1 and 2 require prior authorisation (10–110 days) and mandatory civil liability insurance (€150,000–€187,500).
- Before signing the lease, confirm that the warehouse has a use permit for industrial purposes and complies with the fire safety regulations.
- Fines for operating without a licence: €650–€24,000 for individuals, up to €44,000 for companies.
You have found the ideal warehouse, negotiated the rent and are about to sign the contract. But do you know whether you can carry out your activity in that space without legal risk? Industrial licensing is a mandatory step that many companies discover too late, after signing the contract, with the operation already starting up. This guide explains what you need to know before taking that step.
What Industrial Licensing Is and Why It Concerns You
Industrial licensing is the legal process that authorises a company to carry out industrial activity in a given space. In Portugal, this process is regulated by the SIR (Sistema da Industria Responsavel), created by Decreto-Lei 169/2012 and revised by Decreto-Lei 73/2015.
The most important point for anyone renting a warehouse: the responsibility for licensing lies with the industrial operator, that is, the tenant, not the property owner. The landlord provides the space, but it is the company occupying the warehouse that must ensure it holds the appropriate operating permit.
Starting operations without a digital operating permit is a serious economic offence. Fines range from €650 to €24,000 for individuals and from €4,400 to €44,000 for legal entities. Ancillary sanctions include closure of the establishment, forfeiture of equipment and loss of subsidies (Decreto-Lei 169/2012).
The 3 Types of Industrial Establishment: Which Is Yours?
The SIR classifies industrial establishments into 3 types, based on the degree of risk of the activity, not the building itself. The type determines the procedure, timelines and costs.
| Type | Risk | Who it applies to | Procedure | Timeline |
|---|---|---|---|---|
| Type 1 | Highest | Subject to EIA, IPPC, PRTR (~2% of industries) | Prior authorisation + mandatory inspection | Up to 110 days |
| Type 2 | Intermediate | ≥99 kVA, >20 workers, or >12×10⁶ kJ/h thermal | Prior declaration with consultations | 10–60 days |
| Type 3 | Lowest | All others (majority) | Simple prior notification | Immediate |
The classification is determined by the CAE (economic activity code) of the activity and the legal regimes that apply to it. The IAPMEI simulator automatically indicates the establishment type, procedure, coordinating entity, timelines and fee amount.
The first thing to do is access the SIR simulator on the IAPMEI website. Simply enter the CAE of your activity and the establishment parameters. In less than 5 minutes you will know the type, the procedure and how much it will cost.
Type 3 Industrial Licensing: The Most Common Case for Warehouses
If your company operates in logistics, warehousing, distribution or small-scale industry, it is very likely to fall under type 3. This is the lowest-risk category and covers the majority of Portuguese industrial companies.
The process is straightforward:
- Submit a simple prior notification on the SIR platform
- Pay the fee (approximately €95 for low risk, or free in some municipalities such as Lisbon)
- Receive the digital operating permit and you can start activity immediately
There is no public administration intervention in the procedure. The system is based on the industrial operator's accountability: the applicant signs a statement of responsibility (article 33 of the SIR) declaring compliance with all legal requirements.
The coordinating entity for type 3 is the municipal council of the warehouse's location. In Loures, for example, it is the Camara Municipal de Loures that coordinates the process.
Types 1 and 2: When the Process Is More Complex
If the activity involves significant environmental risk, high electrical power (≥99 kVA), thermal power exceeding 12×10⁶ kJ/h, more than 20 workers, or is subject to the EU ETS regime, the establishment will be classified as type 2 or type 1.
Type 2: prior declaration with consultations to sectoral entities. Timeline: 10 to 60 days. In Zonas Empresariais Responsaveis (ZER), the process may be free of charge.
Type 1: prior authorisation with mandatory inspection by central administration. Timeline: up to 110 days. It represents approximately 2% of Portuguese industries (chemicals, pulp and paper, cement).
Both types require mandatory civil liability insurance (Portaria 307/2015):
| Type | Minimum insurance capital |
|---|---|
| Type 1 | €187,500 |
| Type 1 (smaller scale) | €62,500 |
| Type 2 | €150,000 |
| Type 3 | Exempt |
The coordinating entity for types 1 and 2 in the Lisbon region is the CCDR LVT (Comissao de Coordenacao e Desenvolvimento Regional de Lisboa e Vale do Tejo).
What the Warehouse Needs to Have Before Signing the Contract
This is the point that no licensing guide explains clearly: what you should require from the landlord before signing the lease.
The warehouse must have:
- A use permit for industrial purposes, or a certificate of tacit approval, or a declaration of compatibility with industrial use from the existing use permit (gov.pt)
- Compliance with the Fire Safety Regulations (SCIE), governed by Decreto-Lei 220/2008
- Compatibility with the PDM (Municipal Master Plan): verify that the Plano Diretor Municipal allows industrial use at the warehouse's location
Before signing any contract, ask the landlord for the property's use permit and confirm that it allows industrial use. Without this document, you will not be able to complete the licensing process in the SIR. If fit-out works are needed, you must first obtain a building permit from the municipal council.
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Required Documentation: Checklist
The documentation varies depending on the establishment type.
For type 3 (simple prior notification):
- Registration on the SIR platform (authentication via Chave Movel Digital or Cartao de Cidadao)
- Completed classification form (simulator)
- Descriptive report (processes, machinery, waste treatment)
- Dimensioned and annotated drawings with factory layout
- Property use permit for industrial purposes
- Statement of responsibility (article 33 of the SIR)
- Environmental permit, where applicable
For types 1 and 2 (in addition to the above):
- Proof of favourable prior information
- Workplace safety documentation
- Detailed technical plans
- Documents for the applicable environmental regime
- Civil liability insurance
Step by Step: How to Obtain Industrial Licensing
The process is 100% electronic, carried out on the SIR platform via ePortugal:
- Check the CAE. Confirm that the activity is listed in Annex I of the SIR. The IAPMEI simulator performs this check automatically.
- Register on the SIR platform. Access via Chave Movel Digital or Cartao de Cidadao.
- Complete the Classification Form. The system indicates the type, coordinating entity, timelines and fee.
- Gather the documentation: use permit, descriptive report, drawings, statement of responsibility.
- Submit the Detail Form with all documentation.
- Pay the fee calculated by the system.
- Type 3: receive the digital operating permit immediately. Types 1/2: await the decision within the legal deadline.
- Start the activity.
CAE 52102 covers the warehousing of goods on behalf of third parties. If your activity falls under this code, it is subject to industrial licensing. Use the SIR simulator to confirm the type and applicable procedure.
Costs and Fees
Licensing fees are set by Portaria 280/2015 and updated annually by CPI. The formula is: base amount × size factor × service factor.
| Item | Type 3 | Type 2 | Type 1 |
|---|---|---|---|
| Licensing fee | ~€95 (free in some municipalities) | Variable (zero in ZER) | Variable |
| Mandatory liability insurance | Exempt | Minimum capital €150,000 | Minimum capital €187,500 |
| Timeline | Immediate | 10–60 days | Up to 110 days |
For the vast majority of logistics and warehousing facilities (type 3), the total licensing cost is under €100.
What Happens If You Operate Without a Licence
The penalties for operating without industrial licensing are significant:
- Fines: €650 to €24,000 (individuals) or €4,400 to €44,000 (legal entities)
- Ancillary sanctions: forfeiture of equipment to the state, loss of subsidies, suspension of the operating permit, closure of the establishment
- False declarations in the process may constitute a criminal offence
- Inspections: ASAE and municipal council (for type 3)
The system is based on the industrial operator's accountability. When you sign the statement of responsibility, you are declaring that you comply with all legal requirements. If that declaration is false, the consequences go beyond administrative fines.
ASAE and the municipal council can inspect type 3 establishments at any time. For types 1 and 2, inspections are carried out by the CCDR and sectoral entities. Do not assume that "nobody will check". The financial and operational risk is too high.
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Renting a Warehouse in Loures or Sacavem: Local Specifics
If you are looking for a warehouse in the Loures, Sacavem or Prior Velho area, the main logistics corridor of the Area Metropolitana de Lisboa, there are some specifics to bear in mind:
- Type 3: the coordinating entity is the Camara Municipal de Loures (contact: 211 151 013)
- Types 1 and 2: competence lies with the CCDR LVT (contact: sir.coordenadora@ccdr-lvt.pt)
- Type 3 inspections: ASAE and Camara Municipal de Loures
Durgesta warehouses in Loures and Sacavem have an industrial use permit, one of the key requirements to complete the licensing process in the SIR. With units from 750 to 14,000 m², it is possible to find the right space for your operation and start the licensing process with the property documentation already in place.
To understand the rental costs in the region, see our article Industrial Warehouse Prices in Greater Lisbon in 2026. If you need help calculating the ideal area for your operation, see How to Calculate the Warehouse Area Your Company Needs.
Frequently Asked Questions
The tenant. The landlord is responsible for providing a space with a use permit that allows industrial use, but the industrial licensing process in the SIR is the responsibility of the company carrying out the activity. It is the industrial operator who submits the prior notification or authorisation request, signs the statement of responsibility and obtains the operating permit.
Approximately €95 for low-risk industries. In some municipalities, such as Lisbon, the service is free. Fees are set by Portaria 280/2015 and updated annually by CPI. For types 1 and 2, there are additional costs for mandatory civil liability insurance with minimum capital of €150,000 to €187,500.
It depends on the type. For type 3 (majority of warehouses), operations can start immediately after submitting the prior notification and paying the fee. Type 2 takes between 10 and 60 days. Type 1 can take up to 110 days, as it requires prior authorisation with a mandatory inspection.
All activities whose CAE is listed in Annex I of Decreto-Lei 169/2012 are subject to licensing. The quickest way to check is to use the IAPMEI simulator on the SIR platform: enter the activity's CAE and the system indicates whether licensing is required, the applicable type and the procedure to follow.
The use permit for industrial purposes is a document issued by the municipal council certifying that the building is authorised for industrial use. It is one of the mandatory documents for licensing in the SIR. Without it, you cannot complete the process. Before signing a lease, always confirm that the warehouse has this permit or an equivalent document.
It constitutes a serious economic offence, with fines of €650 to €24,000 for individuals and €4,400 to €44,000 for legal entities. Ancillary sanctions include closure of the establishment, forfeiture of equipment to the state and loss of subsidies. False declarations in the process may constitute a criminal offence.
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