Guides Air conditioning: legal requirements in Portugal
Air conditioning: legal requirements in Portugal
There is a great deal of inaccurate information about mandatory inspections and maintenance. This guide sets out what Portuguese law actually says, with the source alongside each requirement.
Updated 27 July 2026
Short answer
In a normal domestic split there is no mandatory periodic inspection: checking for leaks is only required at 5 tonnes of CO₂ equivalent load, a threshold that most household units do not reach.
What the law requires always, for every system, is that work on the refrigerant circuit must be carried out by a certified technician, article 9, paragraph 1 of Decree-Law no. 145/2017. And, in a building, fixing the outdoor unit to the façade affects a common part and, as a rule, requires condominium approval.
Leak check: when it is mandatory
The obligation does not depend on the type of unit, but on the fluorinated greenhouse gas charge it contains, measured in tonnes of CO₂ equivalent. The person with the duty is the operator of the equipment, typically the company, in the commercial case.
| Equipment load | Frequency | With leak detection installed |
|---|---|---|
| ≥ 5 and < 50 t CO₂eq | 12 in 12 months | 24 in 24 months |
| ≥ 50 and < 500 t CO₂eq | 6 in 6 months | 12 in 12 months |
| ≥ 500 t CO₂eq | 3 in 3 months | 6 in 6 months |
| less than 5 t CO₂eq | no mandatory periodic check | |
Have a leak detection system installed doubles the range at all levels. In large installations, this is worth the investment just by reducing checks.
Only a certified technician can touch the refrigerant
This is the rule that applies to everyone, from the split room to the warehouse system. Technical interventions on equipment with fluorinated greenhouse gases (installation, maintenance, repair, refrigerant collection) must be carried out by certified technicians and companies by a certification body, in accordance with article 9, no. 1 of Decree-Law no. 145/2017, of 30 November.
Registration of equipment and communication to APA
For the equipment covered, there is a register (RAE) that must be maintained for at least five years and updated whenever there is a technical intervention on components with fluorinated greenhouse gas.
There is also annual communication of data on the use of fluorinated greenhouse gases to the Portuguese Environment Agency, until March 31 of each year.
Condominium: the façade is not yours
In a horizontal property building, the façade, roof and main walls are common parts, article 1421 of the Civil Code. Fixing the outdoor unit to the façade, or drilling holes in it to pass the piping, means messing with a common part.
Jurisprudence and practice treat the placement of an outdoor unit on the façade as a innovation work (article 1425 of the Civil Code), which requires approval at a condominium assembly by a qualified majority.
In classified heritage zones Authorization from the city council may also be required. It is always worth confirming the condominium and municipal regulations before scheduling the installation.
And is maintenance mandatory?
For a domestic unit below the 5 t CO₂eq threshold, the law does not impose a maintenance periodicity. The recommended annual review is good practice in the sector: it serves to maintain performance, avoid breakdowns and slow the growth of consumption. It is not a legal requirement.
In commercial and service buildings there are specific rules for energy efficiency and indoor air quality, which depend on the type and size of the system. See air conditioning maintenance.
Sources
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