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Compliance

Instructor compliance

How licensing actually works in Portugal — and where Surf Booking fits (and where it doesn't).

1. Three independent legal pillars

Teaching surf commercially in Portugal is a tourism animation activity regulated by Decreto-Lei 108/2009. For a lesson to be legal, three elements must coexist — all independent of Surf Booking:

  1. The school is registered in RNAAT (Registo Nacional dos Agentes de Animação Turística) with valid liability insurance and authorisation for the beach (APA concession, municipality permit, or ICNF authorisation for protected areas).
  2. The instructor holds a recognised professional certification — TPTD (Título Profissional de Treinador de Desporto, IPDJ), FPS Grade I/II/III, or ISA Level 1/2. This card belongs to the instructor and must be carried.
  3. The lesson is formally linked to the school — via a contract of employment or service provision, declared to AT, with the instructor included in the school's insurance policy.

2. The licence belongs to the school

The freelance instructor does not hold an individual RNAAT. RNAAT belongs to the school. The instructor is legal only when operating under a registered school, and that link must be documented (contract + insurance inclusion + booking on record). You can work with multiple schools — but each lesson must be documentally tied to ONE school.

3. What Surf Booking is — and is NOT

Read carefully

Surf Booking is:

  1. An operational management tool — bookings, payments, calendar, communication student↔school.
  2. A historical record of lessons taught through the platform.
  3. Internal identification linking the instructor to the school that invited them.
Important

Surf Booking is NOT:

  1. Legal proof of coverage for lessons. The booking record is internal operational data — it does not replace RNAAT, insurance, concession, or instructor card.
  2. A substitute for the school's RNAAT, insurance, beach concession or for the instructor's professional card.
  3. A licence issuer. We do not issue licences, we do not certify instructors, we do not authorise beach use.
  4. A legal defence in inspection. If approached by ASAE, Polícia Marítima or Capitania, what counts is the school's documentation (RNAAT, insurance, concession) and your instructor card — not opening the Surf Booking app.

4. Lessons outside the platform

Lessons arranged directly outside Surf Booking (e.g. via WhatsApp between the school and a student, without entering the booking in the system) are not managed by us. Their legality is exclusively a matter between the instructor, the school and the authorities, with no interference or coverage from Surf Booking.

5. Confidentiality between schools

When you collaborate with more than one school, each school is an independent commercial entity. It is strictly forbidden to transfer, copy or export contacts, names, lists or commercial data of one school's students to another. Each school owns its own student base.

6. Consequences of non-compliance

Surf Booking reserves the right to suspend temporarily or expel accounts in case of documental fraud, manifestly illegal teaching, or violation of the confidentiality rule above — subject to internal review by the Surf Booking team. This action is internal to the platform and has no effect on external legal proceedings that may run against the instructor or school before competent authorities. In cases of fraud or illegal teaching, Surf Booking may cooperate with authorities (ASAE, AT, Polícia Marítima) upon formal legal request.

7. Surf Booking respects and values the legal regime

The licence belongs to the school. Responsibility belongs to the school and the instructor. We are a management tool. Operating with us means operating legally — under your school, with your card, with your insurance.

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Version v1 · 2026-05-14. We may update this text — accepted versions are kept on record per Art. 9 DL 24/2014.
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