If Code 794 appears on your Portuguese driving licence, the validity of some licence categories is now linked to your Portuguese visa or residence permit.
The rule has applied since 9 June 2026 under Decreto-Lei n.º 114/2026. It targets non-EU citizens whose Portuguese licence falls within the validity periods listed in Article 16(9).
Quick Answer: Code 794 means the affected category is valid only while the qualifying visa or residence permit is valid, or while the residence title is in a renewal process. Older Portuguese licences can also be caught even when 794 is not printed on the card.
Last verified: 1 September 2026. I checked the decree, the consolidated Article 16 rules and IMT’s current FAQs, including its 24 August instructions for non-EU drivers using IMT Online.
What Code 794 means
Article 16(9) of Portugal’s Regulamento da Habilitação Legal para Conduzir (RHLC) reduces certain normal driving-licence validity periods to the date shown on the driver’s qualifying visa or residence permit.
Article 16(10) requires licences issued under that rule to carry restriction code 794. In plain English, the official 794 definition means validity is limited to proof of a valid visa or residence permit, including a residence title in renewal.
So a category that would normally last 15 years can end sooner when the immigration document expires first.
IMT now also states in its FAQ that, for a non-EU residence-title holder, the affected licence categories are limited to the residence-document expiry date with harmonised code 794.
What should you do if you have Code 794?
Start with these four checks:
- Check your residence document expiry date. That may be the limiting date for the affected licence category.
- If AIMA renewal is already active, keep the official proof. Article 16(10) expressly protects the licence while the residence title is in renewal.
- Check each licence category separately. Code 794 does not shorten every category in Article 16.
- After AIMA issues the new residence document, check your IMT record. Do not assume the licence record changed automatically.
If you are still exchanging a foreign licence, use the foreign driving licence exchange guide. This page is about a Portuguese licence that has already been issued.
Who is affected by Code 794?
The law uses cidadão extracomunitário, meaning a non-EU citizen, who holds a valid visa or residence permit allowing residence in Portugal.
| Situation | Article 16(9) residence-linked rule? |
|---|---|
| Portuguese citizen | No |
| EU citizen | No |
| Non-EU citizen with a qualifying Portuguese residence permit | Yes, for the validity periods Article 16(9) names |
| Non-EU citizen with a qualifying residence visa | Yes |
| Portuguese licence issued before 9 June 2026 | The transitional rule can still apply |
The provision is not limited to foreign-licence exchanges. If you passed your first driving test in Portugal, the same rule can apply because Article 16(9) is written around nationality, residence status and category validity, not how you obtained the licence.
EEA and Swiss citizens use different free-movement residence arrangements. If IMT has placed 794 on your licence and you fall into one of those groups, confirm the specific record with IMT rather than assuming the third-country rule applies in the same way.
Does Code 794 apply to every driving category?
No. This distinction matters.
Article 16(9) only points to:
- Article 16(2)(a) and (b): the normal validity periods for AM, A1, A2, A, B1, B, BE and T before the separate over-70 rule; and
- Article 16(4)(a): the five-year period up to age 70 for C1, C1E, C and CE, plus B/BE used for specified Group 2 activities such as ambulances, school transport and passenger vehicles for hire.
It does not point to the over-70 period in Article 16(2)(c), Article 16(4)(b), or the separate D1, D1E, D and DE rule in Article 16(5).
If your card carries several categories, check the validity of each one rather than treating the whole card as having one Code 794 date.
My residence card expired and AIMA renewal is pending
For licences issued under Article 16(9), Article 16(10) says they remain valid while the residence title is valid or is in a renewal process.
That is different from simply holding an expired card. The useful evidence is proof that the renewal has actually started.
One thing that keeps tripping people up is treating “expired” and “in renewal” as the same status. They are not. If I were doing this today, I would keep the AIMA renewal confirmation available on my phone and offline as well, especially when the physical card shows an old date.
If the problem is your residence renewal itself, see the AIMA residence permit renewal guide. International travel is a separate issue covered in the expired residence card travel guide.
What about an older licence while AIMA renewal is pending?
There is a drafting wrinkle worth knowing about. Article 4, the transitional provision for licences issued before 9 June 2026, expressly applies the Article 16(9) regime but does not separately mention Article 16(10).
Article 16(10) clearly protects licences issued under the new rule while residence renewal is underway. Even so, IMT’s public FAQ does not spell out this older-card transitional edge case separately.
If your pre-June licence is being treated as residence-limited and your residence card has expired during renewal, keep the renewal evidence and confirm the specific record with IMT if the category validity shown in its system is unclear.
My licence was issued before 9 June 2026
You are not automatically outside the rule just because 794 is missing from the card.
Article 4 of Decreto-Lei n.º 114/2026 applies Article 16(9) to licences issued before the law entered into force, after verification of the visa or residence permit. It specifically says Code 794 does not need to be added to those older licences.
What I’ve noticed in the community discussion is that the missing printed code creates false confidence. For an older Portuguese licence, I would check the category validity recorded by IMT rather than relying only on the date printed on the plastic card.
What happens after AIMA renews your residence permit?
This is still the least clearly documented part of the workflow.
The law clearly protects an affected licence while the residence renewal is underway. It does not give a simple public step saying every Code 794 record will automatically move to the new AIMA expiry date once the new card arrives.
IMT did add a practical instruction on 24 August 2026: non-EU drivers registering an IMT Online request should first upload the current residence document through Documento de Autorização de Residência. If the record needs requalification, IMT says to do that after the upload.
My rule of thumb here is not to assume the database has updated just because the AIMA card has arrived. Check the validity IMT shows. If an online request is needed, upload the new residence document first. If the old date remains, ask IMT which revalidation or record-update action applies to your case.
Do not start another foreign-licence exchange if you already hold a Portuguese licence. If your original exchange is still at Em Análise, Requer Ação or another pre-issuance stage, use the IMT driving licence exchange status guide.
Contact IMT about Code 794
If the validity shown by IMT does not match your current residence document, or your case falls into one of the unclear edge cases above, use IMT’s driver contact channels directly rather than relying on general advice online.
- IMT Call Center: +351 210 488 488
- Telephone hours: 09:00–17:00
- Calls: available for national and international calls
- Online: IMT contact form — use this for questions about Condutores (drivers)
The IMT form includes fields for your NIF and driving-licence number, and it allows an additional document to be attached. For a Code 794 question, make the request easy to understand. Include:
- your Portuguese driving-licence number;
- the affected category, for example B;
- that the licence has Code 794, if it is printed on the card;
- the expiry date currently shown for the category;
- your current residence-permit expiry date; and
- whether an AIMA renewal is already active and, if relevant, the date it was submitted.
If the issue is visible in IMT Online, attach a screenshot or other relevant document through the official form rather than trying to explain the whole record by phone. Do not send passwords or unrelated identity documents.
For a simple question about whether IMT has updated the category after AIMA renewal, I would use the contact form first because it leaves a written record of the question and lets you provide the exact licence details.
Do you need a medical certificate every time?
Not just because Code 794 exists.
This is a recurring community assumption, but IMT’s current revalidation rules are more specific. For ordinary Group 1 categories such as B, an electronic medical certificate is generally required from age 60. For Group 2 categories and the listed professional-use situations, medical requirements apply at each revalidation, with psychological assessment required in the cases set by IMT.
I double-checked this because repeated residence renewals can make Code 794 look like a new medical rule. It isn’t. Code 794 changes the validity limit; the normal IMT medical and psychological requirements still determine what evidence is needed for a revalidation.
Code 794 FAQ
Is Code 794 a fine or penalty?
No. It is a restriction code describing a validity condition on the affected driving-licence category. It is a validity restriction, not a penalty or endorsement for bad driving.
I got my Portuguese licence before June 2026. Am I exempt?
No automatic exemption exists. The transitional provision applies Article 16(9) to licences issued before 9 June 2026 after verification of the immigration document, without requiring 794 to be physically added to the old card.
I passed my driving test in Portugal. Can Code 794 still apply?
Yes, if you meet the Article 16(9) conditions and the category is within one of the validity periods it covers. The provision is not restricted to Portuguese licences obtained by exchanging a foreign licence.
My residence permit expired but renewal is active. Can I still drive?
For a licence issued under Article 16(9), Article 16(10) expressly keeps it valid while the residence title is in renewal. Keep proof that the renewal is active. Older pre-9 June licences have the transitional nuance explained above.
Does Code 794 cover D1, D1E, D and DE?
Article 16(9) does not cross-reference the separate D-category validity rule in Article 16(5). Check each category on a multi-category licence rather than assuming one residence-linked date applies to all of them.
Will AIMA automatically update my driving licence after renewal?
No official source checked on 1 September 2026 confirms an automatic Code 794 extension after AIMA issues a new card. Verify the IMT category validity and use Documento de Autorização de Residência before an IMT Online request if needed.
Has Code 794 been cancelled?
No. A parliamentary petition is challenging the policy, but a petition does not suspend the law. As of 1 September 2026, Article 16(9) and (10) remain in force.