# Vacation Map 2026: Deadline, ACT Fines and Checklist

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![Mandatory vacation map in Portugal](/blog/mapa-ferias-obrigatorio-portugal-lei/cover.jpg)

The vacation map is mandatory in Portugal.

It is not a suggestion. It is not a best practice. It is a legal requirement.

Article 241 of the Portuguese Labour Code requires every company to draw up and post the vacation map **by 15 April** each year. If you do not have this document visible at the workplace, you are non-compliant, and the ACT (Portugal’s Working Conditions Authority) can issue fines.

This guide explains exactly what the law requires, what information the map must contain, and how to make sure your company is compliant.

## What the law says about the vacation map

Article 241(9) of the Labour Code (Law 7/2009 of 12 February) is explicit:

#### Article 241(9) | Portuguese Labour Code

“The employer shall draw up the vacation map, indicating the start and end of each worker’s holiday period, by 15 April of each year, and shall keep it posted at the workplace between that date and 31 October.”

Let us break that down:

**Drafting deadline:** By 15 April each year. Not 30 April. Not “whenever it suits”. 15 April.

**Posting period:** The map must be visible at the workplace from 15 April until 31 October. That is more than six months during which any worker (or ACT inspector) can check whether it is there.

**Who it applies to:** All employers with workers on their books. It makes no difference whether you have 5 or 500 employees. The obligation is the same.

## What information the vacation map must contain

The law specifies that the map must include, for each worker:

-   **Worker’s name**
-   **Start date** of the holiday period
-   **End date** of the holiday period

It sounds simple, but many companies overcomplicate it. Some include too much information, others too little. What matters is that anyone can look at the map and understand: who is on holiday, when it starts, when it ends.

#### Watch out

If a worker splits their holiday into several periods, every period must appear on the map. For example: John Smith, 5 to 16 August and 23 to 27 December.

In practice, most companies also include:

-   Number of working days in each period
-   Department or team
-   Total holiday days for the year

None of this is required by law, but it helps with organisation, especially in larger companies.

## Where to post the vacation map

The law says “at the workplace”. But what does that mean in practice?

**Traditional office:** On a notice board visible to all workers. Usually near the entrance, the kitchen, or a common area.

**Multiple locations:** If the company has several offices, shops or sites, the map must be posted at every location where workers are based.

**Remote work:** Here the law is still not entirely clear. The safest reading is to make the map available in a digital location accessible to everyone: intranet, shared folder, or HR software. But if you have on-site workers, physical posting remains mandatory.

## What happens if you do not comply

Article 241(10) sets out the consequences:

#### Article 241(10) | Portuguese Labour Code

“A breach of the provisions of paragraphs 2, 3 or 4 constitutes a serious administrative offence, and a breach of any of the remaining paragraphs of this article constitutes a minor administrative offence.”

Failing to post the vacation map is a **minor administrative offence**. Fine amounts depend on the company’s turnover and the degree of fault:

**For companies with turnover below €500,000:**

| Type | Negligence | Intent |
| --- | --- | --- |
| Minor administrative offence | 2 to 5 UC (€204 to €510) | 6 to 15 UC (€612 to €1,530) |

*UC (Unit of Account) in 2026 = €102*

That may look modest compared with other offences. But bear in mind: if the ACT finds one problem, it usually finds several. A missing vacation map rarely comes alone, and the fines add up.

## Key dates for 2026

Here is the calendar to follow:

| Date | What to do |
| --- | --- |
| January to March | Collect holiday preferences from employees |
| By 15 April | Draw up and post the vacation map |
| 15 April to 31 October | Keep the map posted and visible |
| 31 October | You may take the map down (but you may leave it up) |

## How holiday scheduling works

Before you draw up the map, the holidays have to be scheduled. The legal process is as follows:

**1\. By agreement.** Scheduling should be agreed between employer and worker. This is the ideal scenario.

**2\. Failing agreement.** The employer may schedule the holidays, but subject to rules:

-   The works council (or union) must be consulted
-   In small, medium and large companies, holidays can only be scheduled between 1 May and 31 October (micro-enterprises are not subject to this restriction)
-   Holidays may be split into several periods by agreement, but the worker is entitled to at least 10 consecutive working days

**3\. Couples in the same company.** Spouses, partners in a de facto union, or people living in a shared household who work for the same company are entitled to overlapping holidays, unless this causes serious harm to the company.

**4\. Priority.** Failing agreement, the rotation of the most sought-after periods (August, Christmas) must be balanced across workers based on the periods taken in the previous two years.

## Can the vacation map be changed?

Yes, but with conditions.

**Change at the employer’s initiative:** Only permitted for “compelling operational requirements of the company”. In that case, the employer must compensate the worker for any loss caused.

**Change at the worker’s initiative:** Subject to the employer’s agreement. It is not an automatic right.

**Illness or incapacity:** If the worker falls ill before or during their holiday, it is suspended. The days not taken are rescheduled by agreement or, failing agreement, scheduled by the employer.

Whenever there are changes, the map must be updated. The posted version must always reflect the actual situation.

## Paper vs digital: which should you use?

The law refers to “posting at the workplace”. Traditionally, that means paper on a notice board.

But in 2026, many companies use digital systems. The question is: does a digital map replace paper?

**The conservative answer:** No. If you have on-site workers, keep the paper version. It is the safest reading of the law.

**The practical answer:** If your whole team works remotely and has access to a digital system where the map is always visible, you are probably covered. But there is no clear case law on this.

**Our recommendation:** Use a digital system for the management side (it is far more efficient), but generate and post a paper version to comply with the letter of the law. That is two minutes of work that protects you from arguments with the ACT. If you are still doing this by hand, see how [leave management software for SMEs](/en/) works.

#### The vacation map, generated automatically.

Forget Excel. A PDF ready for your accountant, with balances calculated and approvals on record.

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## Compliance checklist

Before 15 April, check:

**Map contents:**

-   [ ]  Names of all workers
-   [ ]  Start date of each holiday period
-   [ ]  End date of each holiday period
-   [ ]  All periods included (where holidays are split)

**Process:**

-   [ ]  Holidays scheduled by agreement (or the legal procedure followed)
-   [ ]  Works council consulted (where applicable)
-   [ ]  Workers informed of their dates

**Posting:**

-   [ ]  Map visible in a location accessible to everyone
-   [ ]  Where there are multiple sites, a map at each one
-   [ ]  Posting date: by 15 April
-   [ ]  Kept up: until 31 October

## Common mistakes to avoid

**1\. Posting after the deadline**

I see this constantly. The company only posts the map in May or June because they “were still coordinating”. The law has no exceptions. 15 April is 15 April.

**2\. An incomplete map**

Workers missing, periods missing, dates that do not match. If the ACT asks to check the records against the map and they do not tally, you have a problem.

**3\. Not updating after changes**

John moved his holiday from August to September. Fine. But the map still says August. That is a non-compliance.

**4\. Posting somewhere barely visible**

Inside a cupboard, in a meeting room nobody uses, behind a door. The map has to be where people walk past and can actually see it.

**5\. Confusing the vacation map with other obligations**

The vacation map is not the same as the working time schedule or the time clock records. These are separate obligations with their own rules.

## Frequently asked questions

**Is the vacation map mandatory for all companies?**

Yes. All employers with workers on their books must draw up and post the vacation map, regardless of headcount or sector.

**What is the deadline for posting the vacation map?**

The map must be posted by 15 April each year and remain visible at the workplace until 31 October. This deadline is set out in Article 241(9) of the Portuguese Labour Code.

**What happens if you do not post the vacation map?**

Failing to post it is a minor administrative offence, with fines ranging from €204 to €1,530 depending on the company's turnover and the degree of fault (negligence or intent).

**Can the vacation map be digital only?**

The law refers to "posting at the workplace", which traditionally implies a physical format. For on-site workers, keeping a paper version is recommended. For fully remote teams, a digital system accessible to everyone may be sufficient, although there is no clear case law.

**Can a worker change their holiday after the map has been posted?**

Yes, subject to agreement with the employer. The change is not an automatic right, it depends on negotiation. Whenever there are changes, the posted map must be updated to reflect the actual situation.

## Conclusion

The vacation map is one of those obligations that looks like paperwork until the ACT turns up. And when it does, “I didn’t know” or “we forgot” will not be accepted as an excuse.

The good news: it is simple to comply with. Gather the information, draw up the map, post it by 15 April, keep it visible until October. Done.

With decent [leave management software](/en/), this takes five minutes. You export the map, print it, post it. The system has already calculated and validated everything.

If you are still on Excel, well, that is a problem for another article.

### About the author

![Andre Nabais](/authors/andre-nabais.jpg)

#### Andre Nabais

Co-founder of TeamYo. Passionate about simplifying HR processes for small and medium businesses.

### Want to simplify leave management?

Try TeamYo free for teams up to 5 employees.

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