A member received the info from a service provider that he doesn’t need an energy certificate as he is only renting out for four months per year.
We received this answer from an expert in the field:
The Legislation (Law 128/2014) or the new portaria does not have that information yet, because the Tourism of Portugal is still waiting for an answer from the Department of Energy. A provider cannot say if it or not necessary, because even the Legislator is not yet ready to answer this question.
This is exactly what the secretary of tourism has answered in the last seminar in Albufeira.
Because the legislation is not clear and it says that any property rented or available to the public needs a energy certificate it’s better to follow the rules.