THE ESSENTIALS
Before you start
- Article 18 refers to refusal of acceptance by at least three insurance companies.
- The authority may set special conditions and designate the company required to accept on those terms.
- Contracts under this special route must involve no intermediary and confer no commission.
Three responses do not necessarily mean three refusals
Article 18 of Decree-Law 291/2007 starts from acceptance of insurance being refused by at least three insurance companies. It does not mean three prices the customer disliked. Nor does it turn a failed webpage or a proposal still being assessed into a refusal.
As a preparation method, Inês creates an entry for each company, with the date, request and actual response. Clara asks her to identify the insurance company rather than counting intermediaries or sales channels as necessarily separate insurers. Where a response is ambiguous, Inês flags what needs clarification.
What intervention does the law provide?
Where the situation in Article 18 is met, the applicant may approach the authority to define special acceptance conditions. The designated company must accept the insurance on those terms. This does not mean freely choosing any product or insurer, or obtaining the voluntary covers the customer had imagined.
The article still uses the name Instituto de Seguros de Portugal. Article 2 of Decree-Law 1/2015 renamed it Autoridade de Supervisão de Seguros e Fundos de Pensões, ASF, and provides that references to the former ISP are to be read as references to ASF. That is the body to approach for the current official procedure.
Sources: Diário da República — Decreto-Lei n.º 291/2007, artigos 4.º e 18.º completos; consolidação em vigor, última alteração indicada 20/03/2025; lidos em 01/11/2026 ↗ · Diário da República — Decreto-Lei n.º 1/2015, artigo 2.º completo, redenominação do ISP em ASF; consolidação em vigor, última alteração indicada 02/08/2018; lido em 01/11/2026 ↗
Organise the responses without manufacturing evidence
Keep requests and communications as received, identifying the applicant, vehicle and company concerned. Ask ASF for the requirements and form currently applicable. This guide does not provide a complete official attachment list, set refusal validity periods or guarantee that Inês’s documents are sufficient.
Do not turn a quotation error into a refusal letter or alter dates or vehicle use to obtain another response. If requests described different risks, explain this. The folder should show what was actually requested and refused; the applicant’s written count does not replace the documents.
Applying does not permit driving without insurance
Article 4 links the use of vehicles within its scope to liability being covered by insurance. Collecting refusals or applying to the authority is not evidence of a policy in force. Before relying on protection, confirm the terms, date and documents actually applicable to the insurance eventually concluded.
Also separate compulsory liability from own damage, assistance and other voluntary guarantees. Article 18 should not be advertised as automatic access to “all-risks” cover, a guaranteed price or protection for an earlier accident. Inês still needs to read the scope presented to her.
This route expressly limits the intermediary’s role
Article 18(3) provides that contracts concluded under these special conditions must involve no intermediary and confer no commission. RMACHADO therefore does not present this route as a placement service it performs for the customer. The specific application must follow ASF’s procedure directly.
To compare ordinary-market offers, select Automóvel under Request a quote on the RMACHADO website. That task differs from the special application to the authority: it does not submit that application, promise acceptance or activate insurance. Use policy support for an existing contract.
KEEP THESE QUESTIONS
Your checklist for the next conversation
- Distinguish actual refusals, offers and applications still pending.
- Identify each company and keep original requests and responses.
- Check the current procedure and requirements directly with ASF.
- Separate the special application from actual inception and ordinary quotations.
FROM THE ARTICLE TO YOUR SITUATION
Let us discuss your situation
Tell us what you want to protect. We review your request and help compare relevant terms. Requesting a quotation does not activate insurance.
Sources and transparency
Content updated on .
Consultation dates are stated in individual references when available.
Numerical examples are fictional and explain concepts. Editorial interpretations are identified in the text.
- Diário da República — Decreto-Lei n.º 291/2007, artigos 4.º e 18.º completos; consolidação em vigor, última alteração indicada 20/03/2025; lidos em 01/11/2026 ↗
- Diário da República — Decreto-Lei n.º 1/2015, artigo 2.º completo, redenominação do ISP em ASF; consolidação em vigor, última alteração indicada 02/08/2018; lido em 01/11/2026 ↗
Information from RMACHADO GROUP. This is not an insurance offer or individual advice. Covers, acceptance, exclusions, sums insured and costs depend on the policy. The intermediary does not underwrite the risks.