The Portuguese low-voltage grid (“LV Grid”) is operated by private entities awarded with a concession provided by the municipalities (up to the maximum length of 20 years). It can also be operated directly by each municipalitybut none of them is currently doing so.

E-Redes - Distribuição de Eletricidade, S.A. (“E-Redes”) is the predominant force in the management of the LV Grid, supplying 99,5% of the Portuguese electricity consumers. There are other 10 small operators, small local communities organized as cooperatives operating exclusively within individual municipalities or autonomous regions (Azores and Madeira).

Most of the existing concession contracts were to expire between 2021 and 2022. The new tenders for awarding LV Grid concessions were initially planned for 2019 but  only in the end of 2023, the former Portuguese Government finally published the tender documents. And shortly before leaving office it announced the timetable for the launching of the LV Grid concession tenders. 

One of the reason for this delay can be found in the Portuguese Energy Supervision Authority ("ERSE") and the National Association of Municipalities ("ANM") different views regarding the number of tenders to be launched, a key element in assessing the competitiveness of the procedures. 

In case the new Government confirms this timetable, the map of the tenders will be decided until October 31st, 2024. The municipalities must decide by then whether to join or not in intermunicipal concessions tenders.  If they do, they will have until March 31st, 2025, to make all resolutions needed to launch the public tenders and, finally, their representative has until June 30th, 2025, to launch the public tender procedure. 

Unfortunately, some of the concession award criteria, such as the years of required experience, may compromise the small grid operators’ ability to participate in the tender and may force them to participate in joint-ventures.

This paper provides an overview of the regulations and of program for the LV Grid tenders and other information that we trust may be relevant for market  players interested in participating.

Access to the full version above. 


Portugal has largely recovered from the impact of the coronavirus pandemic. The inflation pressures felt in 2022 and 2023 are fading mostly due to the end of supply chain disruptions caused by the pandemic and the European Central Bank’s monetary policy. However, the ECB’s interest rate increases and the cooling off of demand in European markets are leading to a decline in economic growth throughout Europe.

After growing 6.7% in 2022, the Portuguese economy is projected to increase by 2.1% in 2023 and 1,2% in 2024. Exports of goods and services reached 56,293 million euros by the end of June 2023, a decline of 3,4% compared to the same period in 2022.

In 2023, investment in tourism, real estate, renewable energy, and other longer-term projects remained strong in Portugal. Despite the present difficulties, local and international investors continue to be confident in the longer-term prospects in tourism, energy, and real estate.

It is expected that the «Recovery and Resilience Plan» (Plano de Resiliência e Recuperação, PRR), supported by the European Union, will improve the performance of Portugal’s economy in the near future. The government plans to invest in 85 infrastructure projects, with €22.200 million in the transportation sector, mainly in upgrading or building new railroads and subway infrastructure, €13,060 million in renewable energy, and €7,418 million in environment-related investments. In 2023, new public funds totaling 400 million euros were established, mostly to invest in start-ups.

Portugal’s commitment to energy transition and technological developments is attracting international and local investors in solar and wind power projects. Investors are waiting for the government to open up public tenders to develop offshore wind power projects on the coast of Portugal.

In a world of many uncertainties, with wars raging in Ukraine and the Middle East, Portugal remains a safe harbour for international investors. According to the Institute for Economics & Peace’s “Global Peace Index 2023”, Portugal is one of the safest countries in the world, ranking 7th in the most peaceful countries in the World and 4th in Europe.

This guide reviews the main aspects to be considered by foreign investors looking at Portugal as a place to invest, such as how to set up a business, government incentives, employment rules, taxation, intellectual property protection, real estate, and the judicial system.

For more information, go to www.macedovitorino.com/en/Why-Portugal


Since we live in a constantly changing world in which only values and principles last over time, we believe in a legal profession in which rigour, initiative, integrity and dedication are the best measure of success. ?

As a law firm, we provide "pro bono" legal services and legal training to non-profit organisations and people they appoint. The firm and each of its employees also endeavour to play a civic role through social volunteering activities, involving ourselves in campaigns and directly supporting certain institutions in need of help.?

MACEDO VITORINO has been aware of its environmental responsibility, developing measures to promote the efficient use of energy, water and consumables, which it has further developed and improved.?

We believe that we have an obligation to the community, to nature and to the planet on which we live. We believe we have an obligation to future generations to leave them a better world. We believe that we can do more and better than we have been doing.?

In 2020, we proposed an Agenda for the Decade and listed 10 concrete principles for changing the world - you can find them on the next slide - in the field of sustainability and ethics, which have served as guidelines for our behaviour.?

This report aims to analyse our progress in this direction and describes what we did during 2023 in favour of sustainability, while also giving some notes on what we want to do in 2024.

Access to full report through the pdf above. 


The water sector in Portugal includes activities such as collecting, treating, and distributing water for public use, as well as managing wastewater. The responsibility for providing these services is shared between the government and local municipalities.

The government is responsible for the Multimunicipal systems, which are a set of components that connect the water distribution network and sewage network. These systems allow for connection to the downstream system.

On the other hand, municipalities are responsible for the Municipal systems, which allow the upstream system to be connected to the end user. They also collect wastewater from producers and redirect it to the upstream system.

Both the government and municipalities can use different management models for these activities, including direct management, delegated management, or concession management.

According to the latest data from the Annual Report of the Portuguese Water and Waste Services | 2022 (RASARP 2022), there are 240 entities that provide public water supply services. Out of these, 18 operate on the upstream system and 232 operate on the downstream system.

The concession management model is more common in the upstream system, with 6 multi-municipal concessions covering 174 municipalities and serving over 5.1 million people. The sector has remained stable in terms of the entities providing water supply services for several years.

On the other hand, the direct management model is more prevalent in the downstream system, with 155 municipal services covering 54% of all municipalities and serving 2.6 million people.

In the state-owned systems, the Águas de Portugal group holds a total or majority share of the share capital in 10 companies out of the 18 that provide water services. In the municipal systems, there is a greater presence of private capital, specifically the Marubeni group (through AGS - Administração e Gestão de Sistemas de Salubridade, SA) and the SAUR group (through the Aquapor group).


Through the AdP Group, the State controls most of the "upstream" systems of supply, abstraction, treatment and distribution of water for public consumption, as well as the wastewater sanitation system.

Águas de Portugal, SGPS, S.A, is a state holding company 81% owned by Parpública - Participações Públicas, SGPS, S.A and 19% by Parcaixa, SGPS, S.A.

The AdP Group owns throughout the Portuguese territory several management entities of multimunicipal systems, which provide water supply and sanitation services to municipalities. The AdP Group also provides water supply and sanitation services directly to the population, through the delegated management resulting from the aggregation of municipal systems.

In 2015, the AdP Group underwent a restructuring process. The 19 multimunicipal systems then in existence were aggregated into 5 entities. The next government, in 2017, partially reversed the the restructuring of the multi-municipal systems, creating Águas do Douro e Paiva and SimDouro by splitting up Águas do Norte and by splitting up Águas de Lisboa e Vale do Tejo, creating Simarsul and Águas no Tejo Atlantico again. A shareholder agreement with the AdP Group was also signed by the Government, in which the "public nature of the management company of the multimunicipal system" was assumed, and therefore, in the near future, a privatization of the company does not seem possible to happen.


Águas de Portugal, SGPS, SA. owns the majority of the share capital in the companies responsible for multi-municipal and municipal systems. The remaining equity is owned by the municipalities covered by the respective water systems, except for EPAL, which is wholly owned by Águas de Portugal.

Multi-municipal systems are operated under exclusive concession agreements with the Portuguese State, which typically last between 20 and 30 years.

Águas do Norte, Águas do Douro and Paiva, SimDouro, Águas do Centro Litoral, EPAL, Águas de Lisboa and Vale do Tejo, Águas Públicas do Alentejo, Águas de Santo André, and Águas do Algarve are responsible for operating multi-municipal systems that cover approximately 285 municipalities and serve over 7.5 million people.

In what concerns municipal systems, Águas do Norte provides water supply and sanitation services to 18 municipalities, Águas da Região de Aveiro serves 10 municipalities, and EPAL covers the entire area of Lisbon, serving around 350 thousand customers. Municipal systems are operated under public partnerships between the State and the municipalities.



AGS – Administração e Gestão de Sistemas de Salubridade, SA (AGS) is a private company operating in the water sector. AGS provides management and operation services for water supply and wastewater sanitation in upstream and downstream systems.

AGS is fully owned by two Japanese companies: Marubeni and Innovation Network Corp. of Japan, which acquired AGS from the Portuguese construction group Somague in 2014 for approximately €72 million euros.

AGS provides its services through concession contracts and public-private partnerships (PPP) between the State and municipalities. AGS serves 855,740 thousand people in water supply and 1,135,859 people in wastewater sanitation.

Currently, AGS’ portfolio includes Águas do Sado, Águas da Figueira, Águas de Gondomar, Águas da Serra, Tratave, Águas de Cascais, Águas de Carrazeda, and Águas de Alenquer.

AGS has interests in the three public-private partnerships in Tavira Verde, Fagar and Águas da Covilhã.


The Aquapor-Luságua Group, owned by Aquapor - Serviços, S.A., is a private entity operating water municipal systems and with investments in other sectors, such as renewable energy projects.

Previously, the Aquapor-Luságua Group was owned by the AdP Group. In 2008, the Aquapor-Luságua Group was sold to the consortium formed by DST (Investhome) and ABB for €63 million euros.

The Aquapor-Luságua Group consists of several companies that manage municipal concessions and participate in public-private partnerships responsible for downstream systems. Aquapor-Luságua Group services 25 municipalities, with a total of 378,000 water supply customers and 305,000 water sanitation customers.

The Aquapor-Luságua Group includes the following concessionaires: Águas da Azambuja, Águas da Figueira, Águas da Teja, Águas de Alenquer, Águas de Cascais, Águas de Gondomar, Águas do Lena, Águas do Planalto, Águas do Sado, Águas do Sado Vouga, Luságua AlcanenaLuságua Lisboa, and Tratave.


INDAQUA – Indústria e Gestão de Água, S.A. (Indaqua) is a privately held company operating in the Portuguese water sector, managing municipal water supply and wastewater treatment systems.

Indaqua is owned by the Miya Group (50.06%) and the Talanx Group (49.94%). The Miya Group acquired Indaqua from Mota-Engil in 2016 for €60 million, while the Talanx Group acquired its stake from Soares da Costa in 2014 for €29.41 million.

Indaqua holds six municipal concessions ("downstream" systems) and exercises direct control over its concessionaire companies through majority ownership. It also holds a 49% stake in Águas de S. João through a public-private partnership (PPP).

In total, Indaqua serves a population of 600,000 inhabitants. Indaqua FafeIndaqua Santo Tirso / Trofa, Indaqua Feira, Indaqua Matosinhos, Indaqua Vila do Conde, and Indaqua Oliveira de Azeméis are the concessionaires of municipal systems owned by Indaqua.


A Be Water, S.A. (Be Water) is a private entity that provides water supply and wastewater treatment services under municipal systems and operates and maintains multi-municipal systems.

Be Water, formerly CGEP - Compagnie Générale des Eaux (Portugal), is wholly owned by the Beijing Enterprises Water Group, a Chinese conglomerate focused on the water sector and environmental preservation. Be Water was acquired in 2013 from Veolia Environment for €95 million, marking the company's entry into operations outside China.

In Portugal, Be Water manages four concession contracts in the municipalities of Mafra, OurémValongo, and Paredes. The company serves a population of 125,337 people in water supply and 90,796 people in wastewater sanitation.

Be Water also provides services to Águas do Algarve, S.A., operating and maintaining certain areas of the system.



ERSAR is the regulatory agency for the following sectors: public water supply, urban wastewater sanitation and urban waste management.

ERSAR is responsible for the following key tasks:

  • Assessing the quality of water for human consumption;

  • Evaluating the performance of management entities based on a number of criteria, including service quality, efficiency, and financial sustainability. The results of these evaluations are made public;

  • Publishing information on the regulated sectors, including the performance of management entities and the latest regulatory developments;

  • Drafting and submitting draft bills and recommendations;

Learn more by download the pdf below. 

With around 3,000 hours of sunshine per year, Portugal stands as the European country with the highest average hours of sun exposure, and it has harnessed this advantage to emerge as one of the most progressive and enthusiastic nations in the promotion of renewable energy.

Portugal’s domestic primary energy production relies predominantly on renewable energy sources, thereby diminishing the country’s dependence on imported fossil, consequently reducing the emission of greenhouse gases. In 2022, 56,9% of the electricity generated was based on renewable sources, and this is expected to rise steeply in the coming decade. 

In its most recent version, released on 30 June 2023, the Portuguese National Plan for Energy and Climate for the period 2023-2030 (“PNEC 2030”), sets ambitious goals for a substantial rise in renewable energy generation, notably by committing to 85% of electricity production based on renewable sources by the end of 2030.

Regarding solar energy, it is expected by the end of 2030 an increase in solar capacity by 20.4 GW with (a) centralized solar production to reach 14.9 GW, and (b) decentralized solar production to reach 5.5. GW.  

These figures come close to quadrupling the current installed capacity with centralized solar production currently standing at 1.5 GW and decentralized production at 1.1 GW. These numbers appear even more impressive when compared at a scale of 1 to 5 to the Spanish PNIEC, which aims for a total solar energy production capacity of 76 GW.

The ground rules and current organization of the Portuguese National Electrical System are established in Decree-Law No. 15/2022, of 14 January (“Energy Law”), setting forth the legal framework applicable to the activities of generation, storage, transmission, distribution and supply of electricity.  

Overall, the road to market of a 1MW+ renewable energy generation must go through the following steps: (i) a grid capacity, (ii) environmental clearance, (iii) a production license, (iv) the approval of the Municipality for construction of the power plant, (v) securing connection to the public grid, (vi) execution of compensation protocol with the Municipality, and (vi) an operation license.

The guide provides a snapshot of the main steps to fully license a solar power plant with 1MW+ of installed capacity.  


The first step of the proceeding starts with the award of a reservation of injection capacity title in the RESP (“Capacity Title”). There are three ways that promoters may apply to obtain the Capacity Title: (i) General Access, (ii) Agreement with the grid operator, or (iii) Competitive Auction  

In the General Access, promoters request directly the Capacity Title to the Portuguese Directorate of Energy (“DGEG”), subject on DGEG’s publication of the available capacity in the grid, by providing the output capacity and the connection substation and voltage level.  

Within 5 days upon reception of the request, DGEG notifies the grid operator to inform on the available capacity within a period of 45 days and DGEG issues the Capacity Title when there is grid capacity on a first-come first-served basis. The request may only be refused on grounds that there is no available capacity in the specific substation or if the request exceeds the available capacity. 

The capacity available in this modality should have been published by DGEG by July 15, 2022, but, up to this date, it has not yet occurred, meaning that this method of obtaining the Capacity Title is currently not feasible.

The second method consists in an agreement between the relevant grid operator and the promoter to extend the grid capacity, on which the promoter finances the expansion of the grid capacity. 

The Secretary of State for Energy shall establish the capacity to be allocated in the RESP in this modality until January 15 of each year and the the promoters must apply until March 15th, of each year.

The grid operators release a ranked list of the projects (based on technical and safety criteria) by August 10th, of the same year and within 10 days after the release of the final list, the grid operators send to the promoters the budget for carrying out the grid reinforcement studies and the relevant payment deadline.

Until April 30 of the following year, the grid operators send to the promoters (i) the grid studies, (ii) the costs of reinforcement of the grid and (iii) availability deadline for completion of the works, and (iv) draft of the agreement to be entered with the promoter.  

The promoter has 30 days to accept the execution of the agreement. If accepted, the agreement must be executed by the end of November, or the request will expire. 


This modality is also currently unavailable due to a procedure launched by the Government in 2020 called “Termos de Referência”, which established a set of criteria for ordering prior submitted requests. DGEG published the final rankings of eligible projects for agreements with the TSO (78 projects) and DSO (53) on 2021, subsequently amending the list in July 2023 to give priority to projects that already conducted an environmental assessment.

The first tranche of projects with a total capacity of 3,6 GW is currently being handled by the TSO (3,2 GW) and the DSO (350 MW), and as far as is publicly known, the draft of the grid reinforcement agreements has been sent to the promoters.

The Government has already confirmed that the second tranche will enclose a capacity of 5 GW for projects on the TSO list (up to the 23rd position) and 1 GW for projects on the DSO list (covering all eligible projects).

A third tranche of projects with the remaining capacity is expected to start being handled by the TSO in 2024.

The grid connection reinforcements necessary for connecting the projects to the RESP are expected to be concluded in 2028, 2029 and 2030.

The allocation of injection capacity in the RESP may also be subject to a tendering procedure.

The modality of the procedure, the conditions and criteria for the allocation of reserve of injection capacity in the RESP, the remuneration scheme, the access, the duration and conditions, the deadlines for the commencement of operation and respective extensions are set in the tender documents. 

The decision to launch a tendering procedure results in the immediate cancelation of the pending applications for allocation of capacity for injection points to be included in the procedure, unless the promoter has already paid for the grid studies.

The application for obtaining a Capacity Title is subject to the delivery of deposit by the promoter, as follows:

  • In the General Access: EUR 10,000.00 per MVA of injection capacity;
  • In the agreement with the grid operator: EUR 15,000.00 per MVA of injection capacity;


Before applying for the production license, a project may have to obtain: (i) a favourable or conditionally favourable Environmental Impact Statement (Declaração de Impacte Ambiental – “DIA”), when the project is covered by the Environmental Impact Assessment (Avaliação de Impacte Ambiental - “AIA”), or (ii) a favourable or conditionally favourable Environmental Repercussions Assessment (Declaração de Incidências Ambientais – “DINCA”), when the project is to be established in areas of National Ecological Reserve, Natura 2000 areas or National Protected Areas Network.

DIA is a decision about the environmental feasibility of a project after an environmental impact study is conducted by the promoter. Any project (i) with a generating capacity ≥50 MW or the area occupied by panels and inverters is ≥100ha, (ii) or, in case it is installed in sensitive areas, has a generating capacity ≥20 MW or the area occupied by panels and inverters is ≥10ha is subject to AIA. Furthermore, the projects that do not reach those thresholds are subject to a case-by-case assessment of their potential impact on the environment, based on their location, size or nature, and may be subject to AIA by decision of the Portuguese Environmental Agency (Agência Portuguesa do Ambiente – “APA”) or of the DGEG

Promoters shall submit the environmental study to APA that will issue the DIA after a period of public consultation of 30 days. A non-favourable DIA decision terminates the relevant AIA procedure.

The project will be subject to DINCA in case it is located in a sensitive area being carried out by the Commission for the Coordination of Regional Development (Comissão de Coordenação e Desenvolvimento Regional – “CCDR”) based on an environmental repercussions study submitted by the promoter. The DINCA is a simplified process, with the same purpose of AIA but with lighter requirements.

When a a project is not subject to AIA or AINCA, the only environmental requirement that shall be stressed out is a favourable opinion of the competent CCDR regarding the location of the project to be requested within the context of the Municipal Licensing, without prejudice to other entities that may be required to issue an opinion within such licensing procedure.

In case the lands where the project is to be installed fall within the National Ecological Reserve or are in areas crossed by water lines, the regulations regarding these two constraints should be taken into consideration.


Renewable power plants with an installed capacity over 1MW must obtain a production license to start the development and operation of the project. The procedure starts with the promoter submitting a request to DGEG for the award of the production license within a 1-year period from the award of the Capacity Title, if the project is subject to AIA, otherwise this deadline is reduced to 6-months.

Upon request of the promoter, the deadlines established in the previous paragraph may be extended – one time - for a maximum of 1-year period upon issuance of a DGEG’s order. This second deadline can be extended for an indefinite period of time by order of the member of the Government responsible for the energy sector, upon request duly grounded by the promoter.

The application to obtain a production license must be accompanied with a set of documents, including: (i) Capacity Title, (ii) land right, (iii) project description and technical documentation in connection with the power plant facility, and (iv) favourable environmental opinions, if applicable.

DGEG shall start the consultation with external entities (particularly grid operator) regarding the installation of the project. Within a period of 30 days after the deadline of 20 days for the external entities to issue their opinion, DGEG shall decide upon the award of the production license.

The award of the production license is subject to the provision of a deposit to DGEG, in the amount of EUR 10,000 per MVA of injection capacity, with a maximum limit of  EUR 10,000,000.00 for a period of 30 months or until the entry into operation of the power plant (whichever occurs later), under penalty of expiry of the procedure.

The production license grants to the promoter, amongst other, the right to (i) install the power plant, (ii) sell the generated energy in organized markets or bilateral agreements, or to the last resort supplier in case the project benefits from a guaranteed remuneration scheme.

The production license may be assigned, but subject to the previous consent of DGEG, and may only be approved if the legal requirements for its award are met by the assignee and (i) if the share of electricity generation capacity held by the assignee in MIBEL on December 31 of the previous year does not exceed 40%, and (b) if the assignee display technical and financial economic capacity and experience to ensure completion of the project). 


The promoter bears the costs of the construction of the necessary infrastructures for connecting the renewable energy project to RESP, including the costs related to the occupation of the land which is necessary for the installation of said infrastructures. As a rule, renewable energy project with an installed capacity of more than 50 MVA are connected to the transmission grid, while plants with less than 50 MVA are connected to the distribution grid.

The grid connection offer is valid for a period of 180 days on which the promoter must accept them or request its modification in case it does not agree with the conditions submitted. Otherwise, such connection conditions expires, and new technical conditions must be requested. Once the promoter has accepted the grid connection offer, the promoter may start the procedure to construct the necessary connection infrastructures.

The costs and charges for the licensing process and construction of the connection facilities that will connect the relevant renewable energy project to the grid are the responsibility of the promoter and, as general rule, subject to technical validation of the project by relevant grid operator since after their construction the connection facilities shall be included into the concession of the grid operator.

Pursuant to the Electrical Installation License Regulation approved by Decree-Law 26852, of July 30, 1936, as a rule electrical facilities that connect renewable energy projects to the grid are subject to obtain an establishment license to be awarded by DGEG. The issuing of the establishment license is not mandatory before starting the construction of the power plant, although it is mandatory for the construction of the connection facilities that will connect the power plant to the public grid.

The request of the establishment license shall be performed by the grid operator after conduction a technical validation of the connection project submitted by the promoter. The promoter is also responsible for securing the necessary land rights and/or easements for the construction and operation of the connection facilities and for compensation due to affected landowners.

The promoter shall assign the connection facilities to the relevant grid operator after its construction as it shall remain under the concession of the latter. Upon the assignment, the promoter shall provide a guarantee to secure any construction or manufacturing defects corresponding to a maximum of 10% of the value of the relevant facilities, valid for a period of 2 years for the electrical works and 5 years for the civil works.


According to legal framework concerning urban planning and building, construction enacted by Decree-law no. 555/99, of December 16, building a power plant is considered an “urbanistic operation”, and thus subject to:

  • A licensing procedure through the obtainment of a construction license and construction permit, being the permit a condition for the construction license to be effective and for the start of the works
  • The approval to a prior communication request which, if properly instructed and approved by the Municipality grants the right to immediately start the construction works.

Before construction, it is possible to ask the municipality, on a preliminary basis, information about the feasibility of certain urban planning operation, including legal and regulatory constraints. A favourable preliminary information binds the competent entities on the decision to make on a potential construction request for a period of 1 (one) year.

To obtain the construction license, the promoter submits online (on the municipalities’ website) a request addressed to the President of the Municipality. The President of the Municipality decides on the completeness of the request and starts a period of consulting external authorities.  Within 45 days from the date of receipt of the last of the opinions, or approvals by such authorities, the Municipality decides upon the issuing of the construction license. 

In any case, the construction works may only commence after the issue of the relevant construction permit, which must be applied by the promotor within one year of the date of the issuing of the construction license. Failing to comply with the said deadline will cause the expiration of the construction license. 

The prior communication request consists of a declaration that, provided it is properly instructed, allows the interested party to proceed immediately with certain urban planning operations after payment of the fees due, dispensing with the practice of any permissive acts.

Based on reasonable grounds, the construction deadline may be extended for a further period not exceeding half of its initial term. 

After completion of the construction works, the license of use for the project shall be obtained attesting that the works are completed and have been executed in accordance with the relevant construction procedure, as well as with applicable law and regulations.

Learn more by download the pdf below. 


During the Paris Conference of the Parties to the United Nations Framework Convention on Climate Change Portugal made a commitment to achieve carbon neutrality by 2050. This commitment resulted in the approval of the Roadmap to Carbon Neutrality 2050 ("RNC 2050") and of the National Energy and Climate Plan 2030 ("PNEC 2030"). "This plan will act as the primary tool for shaping national energy and climate policies in the coming decade, aiming to facilitate the shift towards a carbon-neutral future.

The PNEC 2030, recently subject to a revision and update proposal, addresses key aspects like lowering greenhouse gas emissions, integrating renewable energy sources, enhancing energy efficiency, ensuring energy security, considering the internal market, and fostering research, innovation, and competitiveness, the plan establishes a clear roadmap to achieve its objectives effectively.

To respond to this changing landscape, also the rules governing the National Electricity System ("SEN") have been adjusted, resulting in the approval of Decree-Law 15/2022, of 14 January ("Electricity System Law").

The main focus of new Electricity System Law has been to change the electricity production rules, with an emphasis on decentralized forms that rely on local production and self-consumption. This approach required a significant revision of the permitting procedures. Additionally, regulations were established to promote and regulate the upgrading and expansion of electricity production from oceanic sources or locations to reduce pressure on land-based resources.

The second cornerstone of the Electricity System Law has been to optimize the use of the public service electricity grid ("RESP") by introducing new rules into the development and investment plans of both transmission and distribution networks. This is essential to fully utilize the grid's potential and ensure its efficient operation and growth.

Finally, there has been a push to include competitive procedures for the licensing of several activities within the National Electricity System, to promote fairness and competition in these areas of the electricity sector. Rules such as those in the Electricity System Law establishing the obligation to use competitive procedures to select the Last Resort Supplier (“CUR”) and the Entity Responsible for Issuing Guarantees of Origin (“EEGO”).

Throughout this study, we will address these and other matters governed by Electricity System Law.

1.1. SCOPE

The Electricity System Law applies to the activities of generation, storage, self-consumption, transmission, distribution, aggregation and commercialisation of electricity, as well as to the logistical operation of change of supplier and aggregator, the organisation of the respective markets, the activity of issuing guarantees of origin, the activity of managing guarantees of the National Electricity System, the procedures applicable to access to those activities and consumer protection.

The Electricity System Law excludes certain activities from its scope, namely: (i) the production of electricity through cogeneration, which is regulated by Decree-Law 23/2010, 25 March; (ii) the production of electricity from waves’ energy in the pilot areas, governed by Decree-Law 5/2008, 8 January, and Decree-Law 238/2008, 15 December; (iii) the organization, access, and activities related to electric mobility, regulated by Decree-Law 39/2010, of 26 April; and (iv) the production of electricity from nuclear energy.


The Electricity System Law contemplates the following market participants:

  • Electricity producers, responsible for generating and supplying electricity to the national electricity grids;
  • Electricity stores, responsible for storing the energy produced by energy producers;
  • Global Manager of the National Electricity System, responsible for ensuring the harmonised operation of the SEN, the security and stability of the electricity supply in the short, medium and long term, as well as coordinating a stable and secure electricity supply with other European countries;
  • Integrated Distribution Network Manager ("Integrated ORD"), responsible for the technical management of the electricity distribution networks in high, medium and low voltage and for the technical management of the distribution networks in articulation with the Global Manager of the National Electricity System;
  • Transmission System Operator ("ORT"), responsible for the activity of electricity transmission, and for the construction, operation and maintenance of the transmission system;
  • Distribution System Operator ("ORD") of electricity in high and medium voltage, responsible for (i) the construction, operation, and maintenance of distribution networks, (ii) the management, operation, and maintenance of the electricity system, (iii) the expansion to new locations, (iv) the maintenance of the network and (v) connecting all consumers who request it;
  • Low-Voltage Distribution System Operators ("Low-Voltage ORD"), responsible, in addition to commercial duties, for reading meters, making meter-reading data available to suppliers and invoicing and collecting network access tariffs by suppliers;
  • Closed Distribution System Operators ("Closed ORD"), responsible for ensuring the capacity of the closed distribution system, i.e. for (i) interrupting the supply of electricity within the closed distribution systems, provided that this is duly justified and notified to ERSE, the Portuguese Energy Services Regulatory Authority or to DGEG, the Portuguese Department of Geology and Energy, (ii) knowing the consumption demand and energy produced by the closed distribution systems and (iii) entering into transparent and non-discriminatory agreements with consumers/users of the closed distribution system;
  • Electricity traders, responsible for making commercial offers, buying electricity from electricity producers in the market and selling it to customers;
  • Last Resort Suppliers ("CUR"), responsible for the supply of electricity, namely (i) in areas where there are no free market offers, (ii) to economically vulnerable consumers and (iii) to customers whose free-market supplier has been prevented from exercising its activity;
  • Electricity Market Operators, responsible for managing the market and related activities, namely managing organised markets for contracting electricity, ensuring that the markets are provided with adequate settlement services and establishing the criteria for determining the price indexes for each of the different types of contract;
  • Guarantees Manager, responsible for ensuring the management of the guarantees to be provided by suppliers or market agents;
  • Last Resort Aggregator, responsible for acquiring electricity from producers of electricity from renewable energy sources and which is remunerated at a price freely determined on organised markets and for acquiring electricity from self-consumers who inject surplus energy into the RESP in the event that no electricity aggregators are offered on the market or when aggregators are unable to exercise their activity;
  • Electricity Aggregators, responsible for buying electricity on the free market and selling it to customers who enter into an Electricity Supply Contract, subject to the terms and conditions agreed therein;
  • Self-consumers are those who produce their own electricity from renewable sources and consume it themselves, rather than selling it back to the grid. They may store or sell their electricity, although these activities may not constitute their main business or professional activity;
  • Citizens' Energy Communities (“CCE”), whether public or private, including, in particular, small and medium-sized enterprises or local authorities, whose main objective must not be the achievement of financial profit;
  • Renewable Energy Communities ("CER"), whose main objective is to provide environmental, economic and social benefits to the members or localities where the community operates;
  • Guarantees of Origin Issuing Entity, responsible for issuing Guarantees of Origin ("GO"), whose activity is subject to a license to be awarded under a public tender. Currently, the activity is entrusted to REN - Redes Energéticas Nacionais, S.A. (“REN”) for electricity produced from renewable energy sources;
  • Collective Self-Consumption Management Entity ("EGAC"), responsible for managing and communicating with the self-consumption and renewable energy community platform and connecting self-consumers to the RESP. They are also responsible for the commercial relationship to be adopted for the surplus energy produced by self-consumers;
  • Logistics Operator for Switching Electricity, responsible for operating the change of supplier and aggregator in the electricity markets and providing personalized information to consumers, electricity producers, and self-consumers; and
  • Electricity Consumers, typically residential and commercial customers. They are also responsible for, among other things, (i) making the relevant monthly payments, (ii) contributing to the development of energy efficiency, (iii) keeping their equipment in a safe condition, under the terms of the applicable legal and regulatory provisions.

The electricity generation and storage activities are subject to a permitting procedure (or prior control, as referred to in the Electricity System Law).



The following activities will require aproduction and a operating license:

  • Production of electricity from non-renewable sources;
  • Production of electricity from renewable energy sources for injection into the RESP network or for self-consumption with an installed capacity exceeding 1 MW;
  • Autonomous storage of electricity with an installed capacity exceeding 1 MW;
  • Autonomous production or storage when subject to an environmental impact assessment ("AIA") or environmental incidence assessment ("AINCA"); and
  • Other production or storage activities non-exempted from prior control or not subject to prior registration or prior communication.

The permitting for other activities is less demanding. A prior registration and an operating certificate will be sufficient for:

  • Production of electricity from renewable energy sources for total injection into the RESP, with an installed capacity equal to or less than 1 MW;
  • Production of electricity for self-consumption with an installed capacity greater than 30 kW and less than or equal to 1 MW;
  • Autonomous storage of electricity with an installed capacity equal to or less than 1 MW;
Research and development projects, demonstration and testing, in a real environment, of innovative technologies, products, services, processes and models, within the scope of 
production, storage and self-consumption activities with an installed capacity greater than 30 kW.
  • Small dimension producers must only serve DGEG with a prior noticefor:
Production of electricity for self-consumption with installed power above 700 W and less or equal to 30 kW;
Research and development projects, demonstration and testing in real environment of innovative technologies, products, services, processes and models, within the scope of production, storage and self-consumption activities with installed power higher than 700 W and less than or equal to 30 kW;

The refitting of an electro-production centre, of primary solar or wind source, when it maintains or reduces the installed power initially established in the prior control procedure.

Finally, the following are exempt from prior control: (i) the production of electricity for self-consumption with an installed capacity of 700 W or less, as long as the injection of surplus into the RESP is not foreseen; (ii) research and development projects, demonstration and testing, in a real environment, of innovative technologies, products, services, processes and models, within the scope of production, storage and self-consumption activities with an installed capacity of 700 W or less, as long as the injection of surplus into the RESP is not foreseen.


In most cases, the procedure to obtain a production license starts with the granting of a capacity reservation title ("TRC") issued by E-Redes - Distribuição de Eletricidade, S.A. (as the ORD), or by REN (as the ORT).

However, no TRC is required in the following cases:

  • For Self-Consumption Production Units ("UPAC"), except those where the injection of surplus into the RESP is expected to be greater than 1 MVA;
  • For hybridization;

  • For over-equipment and stand-alone over-equipment; and;
  • For the retrofitting.

When needed, promoters can obtain the TRC in one of three ways:

  • Under the general access regime, when there is capacity available in the RESP;
  • By agreement with the grid operator, when, in the absence of available capacity in the RESP, the developer assumes the costs of strengthening the RESP to allow the connection of its project;
  • By award in a competitive procedure, when the competent authority, subject to tender the capacity available in the RESP.

The award of the TRC is subject to the provision of a deposit to ensure that the promoter obtains the respective production license, with the following amounts:

  • € 10,000/MVA (up to a maximum of €10,000,000), in the general access mode;
  • € 15,000/MVA (up to a maximum of €10,000,000), in the form agreed with the network operator.

In competitive procedures, the amount of the deposit is defined by DGEG in the tender documents.


When the general access regime applies, TRC applicants must file a request at the electronic platform created for the purpose by DGEG, after DGEG publishing the injection capacity available in the National Electricity Distribution Network (“RND”) and at the National Electricity Transmission Grid (“RNT”) at each substation of connection and voltage level.

The applicant submission must identify (i) the intended injection capacity, (ii) the chosen connection substation and voltage level, and (iii) the grid operator to which it wishes to connect.

The submission will automatically be rejected if (i) it does not refer to a substation in the DGEG list or it exceeds the total available capacity of the intended substation; (ii) the intended injection capacity has already been assigned or has been request earlier by another promoter; or (iii) after being notified by DGEG in 5 days from submission the promoter files to provide the deposit mentioned in the above section.

The TRC also requires prior compensation payment for the benefit of the SEN, in the amount of €1500/MVA.

Within 5 days from the deposit, DGEG forwards the request to the relevant network operator to decide within 45 days. The network operator follows the order of the requests received from DGEG, and may be refused the granting of new capacity in the following cases: (i) non-payment of the service fee; (ii) non-payment of the contribution to the SEN, (iii) there are no technical conditions to implement the requested grid connection, or it would affect the security and reliability of the RESP.

In case the grid operator notifies the applicant and DGEG of a favourable decision, DGEG will issue the TRC within 10 days.


If there is no available reception capacity in the RESP, promotor and the grid operator may enter into a grid reinforcement agreement, whereby the promoter assumes the financial costs arising from the construction or reinforcement of the grid necessary for the reception of energy from the production facility, storage or UPAC.

The negotiation of a grid reinforcement agreement (which will constitute itself the TRC) is conditional to an order from the Secretary of State for Energy until 5 January of each year, defining the maximum injection capacity at the RESP made available:

  • By production technology;
  • By RESP operator;
  • By production with total injection into the RESP and production for self-consumption.

Although reality has been different to this date, the Electricity System Law establishes that:

Requests for agreements must be submitted to DGEG by 15 March of each year;
DGEG must send them to the operator of the RESP within five days. The requests are accompanied by the provision of a guarantee;
By 10 August, the network operator, in coordination with the overall SEN manager or the integrated manager of the distribution networks, as appropriate, will proceed to prioritise the requests for agreement, proposing the approval of the provisional list with the requests accepted and excluded in accordance with the following criteria:
  • Technical criteria for the safety and reliability of the SEN, namely those relating to the use of infrastructures and optimising the operation and management of the SEN;
  • Criteria of territorial and environmental sustainability, namely those referring to the efficiency and rationalisation of infrastructure planning through the joint use of various interested parties, the obtaining of favourable prior information issued by the municipality, the existence of a favourable environmental impact statement, or the contractual title legitimising the use of the land necessary for the respective use;
  • Targets that Portugal is obliged to meet according to the applicable technology.
From drawing up the provisional list, the grid operator has 5 days, to provide it to DGEG, which must, within 5 days, notify the excluded promoters for a prior hearing of 10 days. 
  • DGEG, after consultation with the grid operator, shall draft the final list within 10 days of the end of the prior hearing period, and notify the interested parties of it in the following 5 days.
  • The grid operator must, in 10 days from the publication of the final list, provide the selected promoter with a budget for the execution of the network studies and the respective payment deadline.
  • By 30 April of the following year, the grid operator shall send the following information to the selected promoters who paid for the studies: (i) the network studies, (ii) the cost of reinforcements or construction of the new infrastructure, including the criteria for allocation between interested parties, when applicable, (iii) the deadline for making the new infrastructure available, (iv) a proposal for agreement.
  • The promoters have then a period of 30 days to accept or refuse the agreement proposed by the grid operator. In case of acceptance, the agreement must be executed until 30 November.

The agreement with the network operator must include:

  • The rights, obligations and conditions to be observed, to add power injection capacity in the RESP;
  • The injection capacity at the RESP assigned to the promoter;
  • The charges, payment plan and plan for submission and release of guarantees.

With the signing of the agreement, the promoter must pay an amount corresponding to 5% of the budget presented by the grid operator. The remaining budget amount will be secured by a guarantee, which shall be subsequently released once the agreed payment plan is fulfilled.


The Secretary of State for Energy may launch competitive procedures for the allocation of a TRC for electricity production from renewable energy sources.

The procedure documents should define:

  • The scope of the procedure and the launching method adopted;
  • The conditions and criteria for the allocation of the TRC;
  • The requirements for the qualification of interested parties;
  • The electricity production remuneration models admitted and the respective access, duration and maintenance conditions;
  • The deadlines for entry into operation; and
  • The amount of the required deposit.

When a decision is taken to start a competitive procedure, all pending TRC requests for the same grid connection points that will be included in the procedure are immediately voided. And the respective deposit will be returned within 10 days from the procedure's opening date. However, the competitive procedure cannot include grid connection where there is an agreement between the interested party and the grid operator or where the applicant has already paid for the grid reinforcement studies.


Holders of a TRC can, subject to the consent of DGEG, transfer it before the respective production license is issued. A TRC transfer is deemed to occur whenever there is:

  • A transfer of the project itself,
  • When a change of control over the TRC holder occurs, being in any case subject to the consent of the DGEG.

The change of ownership of a TRC also depends on the promote providing a reinforcement of the guarantee in half of its initial value, except when:

  • The TRC is transferred to a SPV - a vehicle company whose corporate purpose includes the exercise of the activities of construction and operation of an electricity generation plant, storage facility or UPAC, as the case may be, and which has as its sole shareholders the holders of the TRC;
  • The shares are encumbered in favour of financing entities, changes in the direct ownership of the holder resulting from the execution of pledges of shares under agreements entered with the same financing entities, or changes in direct ownership under group restructuring operations that do not imply a change in the beneficial owner.


The installation of 1MW or plus electrical generation plants can only begin after a production license has been obtained.

The procedure starts with the presentation of an application to DGEG for the granting of a production license with a set of documents specified in Annex I of Electricity System Law, including (a) a copy of the TRC; (b) proof of the right to use the land where the installation will be installed, (c) a description of the project and technical documentation relating to it, and (d) favourable environmental opinions, if applicable.

DGEG has 15 working days to decide on the reception of the application and may request additional information only once. The production license holder must provide the requested information within 30 working days.

The application for a production license must be filed within a maximum period of 1 year from the award of the TRC if the project is subject to AIA. Otherwise, this deadline is reduced to 6 months.

These deadlines may be extended at the request of the applicant:

  • To DGEG, only on time and for a maximum period of 1 year, if de delay arises of reasons not attributable to the applicant; or
  • To the Government, for an indefinite period, where in exceptional and duly justified circumstances the time limit proved to be insufficient.

The holder of the production license is entitled to:

  • Install the electricity generation plant, the UPAC or the storage facility according to the terms of the production license;
  • Sell electricity in organised markets or through bilateral contracts and buying electricity up to the limit of the injection capacity defined in the production license;
  • Establish and operate direct lines to supply electricity to end customers when this cannot be done through the RESP or when it is technically and economically more advantageous for the SEN, in accordance with DGEG’ assessment;
  • Deliver the electricity produced to CUR, against payment of the guaranteed remuneration if the plant benefits of a FiT;
  • To deliver the electricity produced, to an aggregator or supplier, against payment of remuneration at a price freely determined between the parties; and
  • Selling storage capacity to third parties.

On the other hand, the duties of the holder of the production license are, namely:

  • Comply with the provisions of the production license;
  • Obtain licenses, authorisations or opinions required for the installation and operation of the plant, UPAC or storage facility;
  • Notify DGEG and the respective grid operator of the conclusion of the electrical installation;
  • Send DGEG and ERSE data regarding the operation and exploitation of the electricity installation: (i) by the 15th of each month, the data referring to the previous month, (ii) by the end of March of each year, the annual data referring to the previous calendar year;
  • Establishing and keeping insurance up to date that guarantees the civil liability of the holder of the production license arising from the exercise of the activity;
  • Informe DGEG in advance, who will inform the grid operator, of any changes to the electrical installation that are not subject to obtaining a new production license.


Before starting operation of the power plant, UPAC or storage facility, it is possible to carry out previous tests and trials. These are subject to request by the holder of the production license and authorisation from DGEG and they may relate to units capable of operating autonomously (in the case of phased construction), or to the entire facility.

The application for authorisation to carry out tests and trials must be addressed to DGEG and accompanied by (i) the test programme to be carried out and its duration, signed by the technician or experts responsible for its execution, (b) the opinion of the grid operator to which the generating plant is connected, (c) a sworn statement by the holder of the production license that the installation complies with the terms of the respective license, the applicable regulations and the technical and safety conditions, and (d) a favourable opinion from the overall manager of the SEN.

DGEG will issue a decision on the authorisation request within 20 days from receipt of the application. It is considered tacitly granted if it is not expressly decided upon within that period and provided that the grid operator has given a favourable opinion on the existence of grid connection conditions.

The period for carrying out tests and trials and trial operation may not exceed:

  • 3 months, except in exceptional circumstances recognised by DGEG; or
  • 12 months, in the case of contractors of a competitive procedure for the award and TRC.

After the experimental operation period has elapsed, the continued operation of the electrical installation depends on the issuance of an operation license.

The energy injected into the RESP in the test and trial or experimental operation phase is remunerated at market price, through the signing of a contract with a market agent.


The production license can be transferred by its holder, subject to the same regime applicable to the transfer of the TRC before the issue of the operating license, which includes an authorisation from DGEG.

The transfer request to DGEG must be accompanied by all the elements relating to the identification, technical and financial standing of the transferor, as well as by a declaration of acceptance of the transfer and of all the license conditions.

DGEG decides within 15 days and may request additional elements. The elements must be provided within a maximum period of 30 days, during which time the decision period will be suspended.


The effects of the production license cease by expiry or revocation, implying the automatic extinction of the operating license and expiry of the TRC.

The production license expires in the following situations:

  • With the expiry of the reserve capacity title for injection into the RESP;
  • When the guarantee is not provided;
  • With the issuing of a new production license replacing it;
  • By renunciation by the holder, exercised by means of a written statement addressed to DGEG;
  • In the event of dissolution, cessation of activity or approval of the liquidation in insolvency and company recovery proceeding of the company that holds the license; and
  • With the extinction of the title of use of water resources or of the title of use of the maritime space on which it depends, if applicable.

The production license may be revoked when its holder:

  • Fails to comply with the duties relating to the exercise of the activity;
  • Fails to comply with the determinations imposed by the technical supervision;
  • Does not obtain or maintain updated the civil liability insurance;
  • Fails to send to DGEG and ERSE, on two consecutive occasions, informative data on the operation and exploitation of the electricity installation;
  • Abandons the installations allocated to electricity production or interrupts the licensed activity, for a continuous or interspersed period of six months or more, within a period of one year, for reasons not based on technical reasons or on capacity mechanism or system services;
  • Undertakes substantial changes to the electrical installation without having obtained a permit.


Except for the possibility of operation on an experimental basis, the electrical projects subject to production license can only start operating after obtaining the operation license.

The application for the issuance of the operation license is addressed to DGEG and must be accompanied by the following documents: (i) a declaration of conformity of execution, signed by the person responsible for the execution and by the installing entity, certifying that the installation is concluded and ready to operate in accordance with the conditions of the production license, (ii) an opinion from the grid operator that the conditions for connection and injection of energy into the grid have been met, (iii) a favourable opinion from the overall manager of the SEN, (iv) proof of conclusion of the civil liability insurance, and (v) a document proving the availability of the land.

Once the application for an operation license is submitted, DGEG must inspect the electrical installations within 30 days of receipt of the license application. If the application is duly completed, DGEG will make its decision within 10 days of receipt of the inspection report. The request for the issue of the operating license can only be rejected on the grounds of non-compliance of the installations with the legal and regulatory conditions or with the conditions stipulated in the production license.

Once granted, the operation license establishes the conditions under which the electrical installation is to operate and certifies that the project was built in accordance with the requirements and specifications set out in the production license and applicable regulations, as well as that it is fit to supply power to the grid, granting the project the right to start operating.

The operation license must be issued within a maximum period of one year from the date of issue of the production license, except in the following cases:

  • TRC allocation in agreement with the operator of the RESP, in which case the operating license may be issued within a maximum period of 90 days after the start-up date of the RESP infrastructures to be built or reinforced;
  • Operationalisation of the connection conditions by the operator of the RESP within a period longer than that defined for the issue of the operating license, in which case it may be issued within a maximum period of 90 days after the availability of that infrastructure.

In any case, the periods for issuance of the operation license may be extended under the same terms applicable to the issuance of the production license referred to in paragraph 2.3 above.

Decree-Law 30-A/2022 of 18 April, which established exceptional measures to simplify the procedures for producing energy from renewable energy sources, exempted the issuance of an operation license for electricity generating centres from renewable energy sources, for storage facilities and for production units for self-consumption whenever the grid operator confirms the existence of conditions for connection to the RESP. The operating license is now requested within 3 years after notification by the grid operator, and the DGEG may also waive the need for a previous inspection.

The rules set out in Decree-Law 30-A/2022 are temporary in nature and will remain in force until 19 April 2024.


The previous registration for project 1 MW or below capacity is made through an electronic platform as follows.

After the applicant has registered on the platform, the ORD has 20 days to issue an opinion on the existence of technical conditions for connection to the grid and compliance with applicable regulations, respecting the sequential order of requests.

DGEG may refuse prior registration within 30 days of the issuing of a statement by the ORD or after the end of the respective period in which it was issued, in the event of non-compliance with the legal and regulatory requirements for exercising the activity.

After the deadline for refusal, the prior registration is issued (with or without conditions) and the applicant can proceed with the installation.

After installation, the holder of the previous register requests the inspection entity for private service electrical installations to carry out an inspection to check the compliance of the installation with legal and regulatory standards. If the inspection report is not refused within 10 days after submission, the operation certificate is considered awarded and the connection of the installation to the RESP is authorised.

The request for the issuing of the operation certificate must be made within a maximum period of 9 months after the issue of the previous register, except in cases where there is a delay in the network operator's provision of the connection conditions to the RESP. In this case, DGEG will suspend the deadline for the corresponding period. In any case, the time limit can be extended by half.

The previous register can be freely transferred by its titleholder. However, changing ownership before issuing the operating certificate follows the same regime as that established for the transfer of the production license (see 2.3.2 above) and the TRC (see 2.2 above). The prior registration can also cease its effects due to expiration or revocation.

The prior registration expires when:

  • Fees due are not paid;
  • No request for an operating certificate is presented within nine months after the issue of the prior registration (except in cases where there is a delay in the RESP operator making the connection conditions available to the RESP); and
  • The holder renounces the registration.

In turn, prior registration is revoked by DGEG when the activity is carried out in breach of legal and regulatory norms and the holder has not - within the time limit set - adopted the DGEG's recommendations for restoring legality.


The prior notice of small (up to 700W) self-consumption projects is carried out through an electronic platform. After registration of the applicant by filling in a form, the respective proof of submission is automatically issued.

After obtaining the proof, the interested party may proceed immediately with the installation of the equipment.

If the injection of electricity into the RESP is planned, the DGEG requests the ORD to indicate the conditions for connection to the RESP within 30 days of obtaining proof.

The effects of the prior notice cease under the same terms applicable to prior registration.


Over-equipment and re-equipment are allowed with the aim of: (i) maximizing the generation capacity allocated to a reception point at the RESP and (ii) reducing the pressure on the territory resulting from the installation of new power generation plants. These are defined in Electricity System Law as:

  • Over-equipment: the alteration of the generating plant through the installation of more generating equipment or inverters with an increase in installed capacity up to a limit of 20% of the connection power assigned to the generating plant in the respective prior control title;
  • Retrofitting: the total or partial substitution of equipment, without changing the implantation polygon of the power plant, with a maximum limit of 20% of the connection power at the RESP.

Both overfitting and retrofitting constitute a non-substantial amendment to the pre-existing prior control title. Both may be requested after the issue of the production license or prior registration and before or after the issue of the operating license or operating certificate. Non-substantial alterations depend on prior authorization from DGEG and are annotated to the production license or prior registration.

The request for alteration of the prior control title is submitted to DGEG with the same information that accompanied the application for the granting of the production license or prior registration. Within 5 days of submitting these elements, DGEG may request additional information to be provided within a maximum period of 30 days. Within the same period, DGEG may also consult the entities that have made statements in the prior control process on the issues that are the object of the alteration.

DGEG issues its decision within 15 days from the deadline for responses from the entities consulted.

Except for hydroelectric plants with a connection power of more than 10 MVA, all renewable energy power plants can be over-equipped or retrofitted.

The energy injected into the RESP relative to over-equipment and/or re-equipment is remunerated at market price or through bilateral contracts. However, in relation to retrofitting, if the power plant benefits from a guaranteed remuneration scheme, this scheme is also applicable to the electricity injected into the RESP resulting from the retrofitting.

The over-equipment may be legally separated from the pre-existing generating plant, being registered, in the pre-existing prior control title, in the name of a legal entity distinct from the holder of the generating plant to be over-equipped, but compulsorily controlled by the holder of the generating plant.

To this end, the holder of the plant must submit to DGEG a contract signed with the holder of the new plant resulting from over-equipment defining, namely, (i) production of electricity, (ii) injection of electricity into the RESP, (iii) metering and billing, (iv) ownership of facilities and equipment, and (v) sharing of information.

The holder of the generating plant and the holder of the autonomous over-equipment are jointly liable to the licensing and supervisory entities, grid operators or the overall SEN manager for the fulfilment of legal and regulatory duties and obligations arising from the prior control and inherent to the installation and operation of the over-equipment and its connection to the grid..

The over-equipment installation is not susceptible to autonomous transmission in relation to the pre-existing power plant, even in cases of legally separated over-equipment, except when the transmission is part of group restructuring operations that do not result in a change of the beneficial owner registered in the RCBE.


Hybrid power plants and hybridization regimes aim at mitigating the scarcity of grid capacity and maximizing the reception of energy at the RESP, and are defined in Electricity System Law as follows:

  • Hybrid plants: generating plants or UPAC that, in the prior control procedure, present simultaneously more than one production unit using several primary sources of renewable energy;
  • Hybridization: the addition to an existing plant of new generation units using different primary renewable energy sources, without changing the injection capacity of the pre-existing generating plant. Hybridization can be carried out at any power plant.

The Electricity System Law allows hybrid production systems to be set up ab initio or, subsequently, through a greatly simplified prior control procedure to amend the production license.

The installation of a hybrid power plant and the hybridization of an existing power plant are subject to the prior control regime applicable to the exercise of the activity of electricity generation referred to in chapter 2.1. However, hybridization, regardless of the installed capacity, is exempt from obtaining TRC, since there is no increase in the injection capacity of the existing electricity generating plant.

For hybridization, a new prior control title will be issued - the subsequent prior control title - which expressly identifies the injection capacity in the RESP allocated to the new production unit. This implies the modification in conformity of the pre-existing TRC, to be promoted by DGEG or, in cases of modality of agreement with the grid operator, by the respective operator. In the prior control procedure, DGEG informs the applicant of the instructional elements already delivered and which remain valid.

As in the case of over-equipment, the new plant resulting from hybridization may be legally separated from the generating plant to be hybridized. However, in hybridization, it is not necessary to have a domain relationship with the owner of the pre-existing generating plant.

Learn more by download the pdf below. 


A whistleblower program, if well-designed, is an adequate tool to build a culture of good communication and corporate social responsibility, where reporting persons are considered to contribute to self-correction and excellence within the organisation significantly.

The most significant risks typically occur in a work-related environment, such as theft or fraud, bribery/corruption, environmental misconducts, health and safety concerns, privacy issues, employer’s policy breaches.

Employees are the ones to which it is easier to detect a breach. Still, they do not often report violations, mainly because they either believe that the breach cannot be effectively addressed or that there is a risk of retaliation.

As part of compliance programmes, reporting channels can be used as a risk management tool, giving organisations the chance to become aware of concerns/misconducts at earlier stages and prevent or mitigate financial and reputational risks.

Reporting channels allow building a confident and secure environment. Employees are encouraged to openly speak about their concerns with the management as their first preferred course of action. Confidentiality, response times, and follow-up must be ensured. Otherwise, a reporting channel will quickly fail its credibility and trust before its primary recipients – the employees.
This paper explains the main steps organisations need to take to comply with the Directive (EU) 2019/1937 (the ‘EU Whistleblowing Directive’ or the ‘Directive’) and Law 93/2021 of 20 December 2021, which implemented the Directive in Portugal.

The time to act is now for those who have not yet taken steps to ensure that a whistleblowing programme with effective report channels is in place. The Portuguese Whistleblowing Law requires ongoing internal reporting channels by 18 June 2022.

The EU Whistleblowing Directive

Currently, whistle-blower protection provided in the EU is fragmented across its Member States. This situation is due to different reasons, including cultural ones.

The purpose of the EU Whistleblowing Directive is to create a harmonised legal framework, which will introduce substantial changes in approach to whistleblowing in the many Member States, including Portugal, and with effects for employers with EU cross border operations.

The Directive affects all legal entities in the private and public sector with 50 or more employees and, regardless of the number of employees, entities within the scope of some EU acts, including Anti-Money Laundering (AML) rules. These organisations must provide means for employees to report misconducts that occurred in a work-related environment, including, but not limited to, the following: public procurement; prevention of money laundering; environment; personal privacy data.

The definition of “employees” has a broad range, comprising those with the employee’s status and freelance employees, contractors, subcontractors, suppliers, shareholders, management roles, former and prospective employees.

The deadlines to incorporate the minimum standards of the Directive into local laws are as follows:

  • Businesses and government organisations with or more than 250 employees, entities falling into the scope of EU some acts (such as AML rules), and municipalities serving 10,000 inhabitants must implement an internal reporting system by 17 December 2021; and
  • Businesses and government organisations with 50 to 249 employees must have their internal reporting system by 17 December 2023.

Organisations must have systems in place to monitor and follow up on reports. They must be prepared to understand the steps to protect whistle-blowers following their reports, safeguard their identity, and ensure that employees will not suffer any retaliation.

The Directive contains the minimum standards for accepting, processing, and reporting information received from whistle-blowers. The EU Member States may impose additional requirements on top of these, so it is recommended to keep track and review the local whistleblowing legislation.

 Reporting channels

In Portugal, the Whistleblowing Directive was implemented by Law 93/2021, of 20 December 2021.

The Portuguese Whistleblowing Law imposes that local businesses and government organisations with or more than 50 employees, “obliged entities” falling into the scope of the Portuguese Anti-Money Laundering Law (Law 83/2017, of 18 August 2017), and municipalities serving 10,000 inhabitants implement an internal reporting system by 18 June 2022.

Employees must first use internal reporting channels before using external channels. The procedures for internal reporting channels shall include:

  • Setting-up of channels for receiving the reports which need to be designed, established, and to operate in a secure manner that guarantees that the confidentiality of the identity of the reporting person and any third party mentioned in the report is protested, and prevent access thereto by non-authorized staff members;
  • Acknowledgment of receipt of the report within seven days of that receipt;
  • An impartial person or department competent for following-up on the reports and which will maintain communication with the reporting person and, where necessary, ask for further information from and provide feedback to the reporting person;
  • Provision of feedback within a reasonable timeframe, not exceeding three months from the acknowledgement of receipt or, if no acknowledgement was sent to the reporting person, three months from the end of the seven days after the report was made; and
  • Provision of clear and easily accessible information regarding the procedures for reporting externally to competent authorities.

Employees must use external channels in case internal channels cannot reasonably be expected to function correctly. This may occur if employees have valid reasons to believe that:

  • They will suffer retaliation in connection with the reporting, including as a result of a breach of confidentiality, or
  • Competent authorities will be better placed to address the breach effectively.

Internal reporting channels

Main features

Employees can address complaints in writing and/or verbally. Complaints can be submitted anonymously.

Internal reporting channels can be operated in-house to receive and follow-up on complaints by persons or services selected for that purpose, or externally, to receive complaints only.

Independence, impartiality, confidentiality, data protection, secrecy, and absence of conflict of interest of the person(s) or entity chosen for this purpose must be safeguarded.

That person or entity will have to act diligently to follow up on the report.

Appropriate actions must be taken to verify the assertions made in the report and, where necessary, to cease the reported violation by opening an internal investigation or informing the competent authority to investigate the breach.

 Deadlines for the follow-up of reports

  • Seven days: acknowledge receipt of the report to the reporting person should occur within seven days of that receipt. Within the same deadline, the reporting person must be informed, in a clear and easily accessible way, on relevant procedures and external reporting procedures to relevant competent authorities.
  • Three months: follow-up and feedback should take place within a reasonable timeframe, given the need to promptly address the issue that is the subject of the report and the need to avoid unnecessary public disclosures. This timeframe should not exceed three months but could be extended to six months, if necessary, due to the specific circumstances of the case, in particular the nature and complexity of the subject of the report, which may require a lengthy investigation.

The reporting person can, at any time, request the organisation to disclose the outcome of the review carried out following the report and within 15 days as of its conclusion by the organisation.

External reporting channels

Main features

Competent authorities will establish external reporting channels, independent and distinct from other communication channels, to receive and pursue reports. They will also publish information on the reporting procedures in a separate, easily identifiable, and accessible section on their websites.

When there is no competent authority to address the report or in cases where the target of the report is the competent authority itself, the report must be addressed to the Portuguese Anti-Corruption Authority and, if this authority is the target, to the Public Prosecutor's Office.

Reports will be dismissed when the competent authority, by a reasoned decision (to be notified to the reporting person), considers that:

  • The reported offense is of minor seriousness, insignificant or manifestly irrelevant;
  • The complaint is repeated and contains no new elements of fact or law that justify a different follow-up to the first complaint; or
  • The complaint is anonymous and there is no evidence of an infringement.

Deadlines for the follow-up of reports

  • Seven days: acknowledge receipt of the report to the reporting person should take place within seven days of that receipt unless the reporting person explicitly requested otherwise, or the competent authority reasonably believes that acknowledging receipt would jeopardise the protection of the reporting person's identity;
  • Three months: for the organization to notify the whistleblower of the measures envisaged or adopted to follow up the complaint with the relevant grounds.

The reporting person can, at any time, request the competent authority to disclose the outcome of the review carried out following the report and within 15 days as of its conclusion by the competent authority.

Competent authorities will review the procedures for receiving and handling reports every three years, considering their experience and that of other competent authorities.


In addition to implementing effective, confidential and secure reporting channels, it is crucial ensuring that reporting persons are protected effectively against retaliation.

Retaliation means any direct or indirect act or omission which occurs in a work-related context, is prompted by internal or external reporting or by public disclosure, and which causes or may cause unjustified detriment to the reporting person.

For instance, employees need specific legal protection to acquire the information they report through their work-related activities. Therefore, employees risk work-related retaliation for breaching the duty of confidentiality or loyalty. Employees may also find themselves in a position of economic vulnerability in the context of their work-related activities.

Protection should be provided against retaliatory measures taken not only directly vis-à-vis employees themselves but also those that can be taken indirectly, including vis-à-vis facilitators, colleagues or relatives of the reporting person who are also in a work-related connection with the reporting person's employer or customer or recipient of services.

Once employees make their report, they should be protected by:

  • Steps are being taken to prevent retaliation, harassment and threats against them by issuing fines to anyone looking to hinder the process in such a manner;
  • Suspension, lay-off, dismissal or equivalent measures;
  • The burden of proof being reversed so that the business or municipality has to provide evidence that it was not trying to retaliate against a whistleblower;
  • Being offered free advice and information on procedures;
  • Understanding that, by exposing wrongdoing, they did not contravene contracts, non-disclosure agreements or similar;
  • Being offered financial assistance;
  • Being offered psychological support.

 The role of the management

Many organisations make their internal reporting system accessible to their employees but do not actively encourage its use. Only a few seek to instil a sense of obligation by sending the message that persons who perceive misconduct but do not raise the alarm are complicit in their apathy or indifference.

Whistleblowing programmes may fail if the high-level management cannot provide proper assurance that those who report issues will not be ignored, silenced, or punished for the bad news.

In turn, middle-level management must balance supporting the programme and preventing access due to much control. Too much management control over the process can hinder its use.

Doubts about management commitment can still arise if the reporting channel is exclusively handled in-house and without the involvement of an independent and impartial third party.

Ensuring the protection and safety of whistleblowers is necessary for the effectiveness of a whistleblowing programme.

A whistleblowing programme must guarantee confidentiality and allow discreet or anonymous reports. If an individual feels seriously threatened or in a situation where a company has only a few employees, guarantees of confidentiality may not be sufficient to encourage whistleblowing, in which case it would be necessary to offer anonymity.

Any reports must be stored confidentially and securely. Each organisation needs to take steps to protect whistleblowers' identities and comply with the General Data Protection Regulation (GDPR). Having a central tracking system to enter, monitor, and update case details will help ensure this while at the same time simplifying the investigation procedure.

Providing feedback to the reporting person as part of the investigation process will also show that the issue is assessed and taken seriously by the organisation.

The programme still needs to be informed to all employee levels. The announcement must have a clear and strong message and be repeated from time to time. This communication that the programme enjoys support at the highest-level management and that the use is an act of loyalty, not infidelity, is crucial and stresses the message that reporting is the right thing to do.

If you wish to know more, please download the pdf below. 


In 2022, the Portuguese road infrastructure manager, Infraestruturas de Portugal (IP) announced plans to build a new high-speed rail line between Lisbon and Porto. 

The North Line (Linha do Norte) currently connects Portugal’s two main cities (Lisbon and Oporto) and is Portugal's primary railway, spanning 336 km. However, it has been struggling with capacity and competitiveness issues. 

Despite significant investment in its modernisation over the past 30 years, the travel time between Porto and Lisbon remains at 2 hours and 49 minutes. 

Consequently, constructing an entirely new line with a different path is deemed the most viable solution. This is because the North Line is crucial to the country's railway infrastructure, with almost 730 trains per day or 44% of all trains operating on it - including over 90% of freight trains and half of all passenger trains.


As part of the broader stimulus programme, the 2030 Investment National Plan, Portugal plans to build a high-speed rail line connecting Portugal's two largest metropolitan areas. 

This will free up space on the North Line for regional and suburban passenger and freight traffic, while boosting transportation and connectivity between the two cities. 

The establishment of a high-speed line linking the Metropolitan Areas of Porto and Lisbon will greatly enhance the capacity and quality of the national railway network, promoting territorial cohesion and environmental sustainability in the transportation sector. 

Additionally, the project aims to link the high-speed rail line to neighbouring Spain and the European high-speed network. 

The project is set to be implemented alongside the construction of the high-speed rail line between Porto and Vigo, with the first phase of the project (Braga-Valença) expected to be completed by 2030.


The project for the high-speed rail line between Lisbon and Porto will be implemented in phases with double-tracking, utilizing the Iberian gauge (1668 mm). 

The anticipated benefits of this new rail line include improved transportation infrastructure and reduced travel time between both cities from over 3 hours to only 1 hour and 15 minutes (without stops). 

The new high-speed railway will be connected to the traditional railway network, with existing stations being adapted to accommodate high-speed trains (such as Aveiro, Coimbra, and Leiria) and a new railway station being built in Vila Nova de Gaia. 

The new line will have a minimum speed of 160 Km/H, nearly five times faster, and a maximum of 300 Km/H speed. 

This project is part of the government's efforts to comply with the goals and objectives of the European Green Deal and the Sustainable & Smart Mobility Strategy climate/sustainability actions.


To minimize costs and make the most of available resources while also managing risk, IP proposes implementing the high-speed rail line project through three concession agreements. 

The concession agreements will cover the design, construction, maintenance, and financing of the project using the DBFM model. IP will oversee the operation of the line.

The project team, in collaboration with the Technical Unit for Project Support, will assess whether the concession model is the best option compared to public sector alternatives and prepare all necessary contracting procedures. The proposed contracting model will adhere to international best practices.

IP plans to contract specific works separately, such as signalling and telecommunications, resulting in increased risk-sharing with the private sector compared to other railway projects.


The new high-speed rail line between Porto and Lisbon will have a length of approximately 290 km.

The project is scheduled to be executed in three phases starting in Porto, adjusted according to the country’s financial capabilities and the availability of EU funding, as follows:

  • Phase 1between Porto (Campanhã Station) and Soure, with an investment of almost 3,000 million euros and expected completion in 2028; 

  • Phase 2between Soure and Carregado, with an estimated investment of 1,900 million euros and expected completion in 2030; and 

  • Phase 3between Carregado and Lisbon (Oriente Station), which will likely be constructed later. 

The first tender regarding the construction of the first section of the Porto-Lisbon high-speed rail line is expected to be launched at the end of 2023, so that works can begin in 2024 and be completed by the end of 2028.


The estimated cost of this project is approximately €4,900 million until 2030. 

Phase 1 will be divided into two sub-sections: 

  • The Porto-Aveiro (Oiã) sub-section, with an investment of €1,650 million (which will include a new bridge over the Douro River connecting the cities of Porto and Gaia); and 

  • The Aveiro-Soure sub-section, with an investment of €1,300 million. 

It is expected that €1,000 million from the European Union's Connecting Europe Facility will be allocated to Phase 1 - €500 million for each sub-section - with the potential to secure additional funding through competitive means.

EU funds will only finance one-third of the construction works on the new high-speed rail line between Porto and Lisbon. The remaining amount will come from the State Budget.

However, EU funds may be at risk if the European Commission does not accept financing new railways built with Iberian gauge. 

Learn more by download the pdf below. 


Portugal is a country located in the southwestern Europe, enjoying a prime location, good climate and an immense natural beauty from sandy beaches and cliffs along the Atlantic Coast to mountains in the country’s inland.

With a lower cost of living than most of Western Europe and a good quality of life, Portugal proves to be well suited for families, modern investors, businesspeople and retirees.

Portugal’s ranked 4th in the 2022 Insider survey, as a country where expats can enjoy quality of life in a sunny and mild weather country, packed with history and culture.

Security levels in Portugal are high when compared with most countries in the World, including Western European countries.

Portugal ranked 5th most peaceful country in the Global Peace Index. 

The Global Peace Index, created by the Institute for Economics and Peace (IEP), measures “global peace” using three broad themes: the level of safety and security in society, the extent of domestic and international conflict and the degree of militarization.



In the nineteen seventies, Portugal underwent a series of major political, social and economic changes. On 25 April 1974, a military coup overthrew the fascist dictatorship and colonial regime. Today, is a republic based on a parliamentary democracy with a semi-presidential regime.


The Prime Minister is the head of the government and holds the executive power. The current Prime Minister is António Costa.

António Costa, the Socialist Party (PS) leader, has been the prime minister since November 2015. 

Far-right populism, surging across Europe, is largely absent in Portugal. The government has the support of the two far-left parties in the Parliament.

The current President of the Republic is Marcelo Rebelo de Sousa, elected in January 2021.


Portuguese legislative power is concentrated in a parliament called the Assembly of the Republic (Assembleia da República). 

The Parliament has 230 seats. Its members are elected by universal vote for a 4-year term.

The executive branch of government is dependent on the support of parliament often expressed by a vote of confidence. 

The Portuguese parliament is comprised of the following parties:

  • The left-wing parties include the Socialist Party (PS), now in government, the Left Bloc (BE); the Portuguese Communist Party (PCP) in coalition with the Green Party, People Animals and Nature Party (PAN) and Livre.

  • The main centre right party is the Social Democratic Party (PSD). Other right-wing parties include the Liberal Initiative and Chega, literally “Enough”, which seats further in the far right.


Portugal is a member of the OECD (Organisation for Economic Co-operation and Development), EFTA (European Free Trade Association), and the United Nations.

Portugal is committed to European integration and transatlantic relations and member of the European Union, since 1986, and a founding member of the transatlantic defence alliance NATO (North Atlantic Treaty Organization) since 1949.

Portugal has been part of the European Monetary System and the European single currency, the “Euro”, since its creation in 2000. 

Portugal joined the Schengen Agreement, which is a European internal security and border control system that allows travelling across its members without any additional visas and no routine immigration checks when travelling to and from another Schengen country, allowing for faster and easier trips. 

Other members of the Schengen Agreement include Austria, Belgium, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Iceland, Hungary, Latvia, Lithuania, Italy, Luxembourg, Liechtenstein, Malta, The Netherlands, Norway, Poland, Slovakia, Slovenia, Spain, Sweden and Switzerland.

Portugal keeps close relationships with the remaining Portuguese-speaking countries and is a founding member of the Community of Portuguese-Speaking Countries (CPLP, Comunidade dos Países de Língua Portuguesa), created in 1996. 

CPLP is an intergovernmental organization for cooperation among nations where Portuguese is the official language. CPLP’s current members include Portugal, Angola, Brazil, Cape Verde, Guinea-Bissau, Mozambique, São Tomé and Príncipe, Timor-Leste and Equatorial Guinea.

Portugal has diplomatic relationships with many countries around the world and historic relations with the United Kingdom, which goes back to 1373 with the establishment of the Anglo-Portuguese alliance, a treaty still in force, China, where the Portuguese arrived in 1513 and were allowed to establish a settlement where is now the city of Macau in 1554 (China regained control of Macau in 1999), and Japan, where Portuguese where the first westerners to arrive in 1543.


The currency in Portugal is the Euro, which is the currency of 20 European countries. The Euro is the second most actively traded currency in the World after the United States dollar.

The currency symbol is “€”. It circulates with seven banknotes and eight different coins: banknotes of 500, 200, 100, 50, 20, 10 and five euros, and coins of two and one euros and 50, 20, 10, five, two, and one cent. Banks are the most accessible places to exchange currencies. Generally, bank exchange commissions are between €3 to €5. 

Debit and major credit cards (especially Visa and MasterCard) are widely accepted.

Portugal pioneered establishing a countrywide ATM network, which allows cash withdrawal, money transfers and other services across the country. Even in more remote areas, there will likely be a bank branch with an ATM machine.

The leading banks in Portugal are Caixa Geral de DepósitosMillenium BCP, BPI, Santander and Novo Banco.


With its roots in the Latin language, Portuguese belongs to a group of languages called "Roman" or "Neo-Latin" that evolved from Latin. Since the fifteenth century Portuguese spread to America, Africa, India and Oceania. 

Portuguese is now spoken by about 261 million in Portugal, Brazil, Angola, Mozambique, Guinea, São Tomé e Principe and Timor, making it the sixth most spoken language in the World.

English is spoken widely in Lisbon, Oporto, most of Algarve, and other main tourist destinations. 

If you are visiting Portugal, learning just a few simple Portuguese words would surely facilitate your communication in more remote areas and with native Portuguese that are not fluent in English.

Although most Portuguese nationals do not speak Spanish, most people can understand Spanish. French is less spoken in Portugal than it used to be before it was replaced by English as the second language in schools. Still, French is spoken by some people.



Citizens of the European Union (EU) countries, Iceland, Liechtenstein, Norway, Switzerland or Andorra do not require a visa to enter Portugal for short periods of stay, it’s sufficient to hold a valid identification document. British citizens can travel to Portugal for holidays or short trips up to three months without needing a visa, holding only a valid passport which should be valid for the whole time one is in Portugal.

Citizens of EU countries, Iceland, Liechtenstein, Norway or Switzerland who plan to stay in Portugal for a period exceeding 3 months, should request a registration certificate (certificado de registo) from the municipal council (Câmara Municipal) of the area of residence.

Five consecutive years after holding the registration certificate, their holders may request a permanent residence certificate (certificado de residência permanente) from the Foreigners and Borders Service (Serviço de Estrangeiros e Fronteiras).


Citizens of non-EU countries who wish to live in Portugal should request a residence visa (visto de residência) at the Portuguese embassy in their country of residence. A residence visa is a long-term visa allowing holders to enter Portugal for four months to apply for a permanent residence permit (autorização de residência) from the Foreigners and Borders Services. Residence visas are issued if specific purposes of stay are met, such as:

  • Working as a self-employed person, as an employee, or investing in Portugal as a private entrepreneur;

  • Conducting research, teaching at a higher education institution or carrying out the highly-skilled activity;

  • Studying, volunteering or doing an internship; and 

  • For purposes of family reunification.

Following the golden visa impulse, the Institute of Support to Small and Medium Enterprises and Innovation (IAPMEI – Agência para a Competitividade Inovação) developed the “Start-Up Visa” program to promote the creation of business and innovative projects.

The program is intended for entrepreneurs who wish to develop their entrepreneurial or innovative projects in Portugal, even if they haven’t already set up a company or if they have business projects in their countries of origin and that wish to carry on their activity in Portugal. Candidates must fulfil the following requirements:

  • Not to have a permanent residence in a country of the Schengen Area 

  • To have fulfilled their obligations before the Portuguese Tax Administration and Social Security (if applicable);

  • Not to have a criminal record;

  • To be of age;

  • To possess the financial resources equivalent to 12 times the Social Support Indexation (IAS).

For the presentation of the application, the candidate must complete an online form with his identification and the other entrepreneurs involved and also the description of the project, accompanied by the following documents:

  • Letter of motivation;

  • Copy of the passport;

  • Criminal record from their origin country;

  • Statement from the bank that proves the existence of own financial means of subsistence and the possibility of transferring these funds to a bank operating in Portugal; and

  • Curriculum vitae;

Applicants should submit their application to one or more incubators on the certified incubators list. In the second phase, the entrepreneur must complete the application information and submit it to IAPMEI through an online platform. Eligible entrepreneurs under the program will conclude an incubation contract with the certified incubator.
Learn more by download the pdf below. 


The European Green Deal has set the roadmap for reduction of greenhouse gas emissions by at least 55% by 2030. Renewable energies are inevitably susceptible to variations in availability, as the sun and wind are not programmable. Energy storage is therefore essential to meet European targets. 

Energy storage installed capacity in Portugal is still predominantly based on hydropower pumping, which is today over 3 GW, and will increase to 4,164 GW when the Alto-Tâmega dam is completed this year. However, this paradigm is about to shift with the democratization of energy storage solutions with wind and solar production.

Storage solutions outside hydro generation have been in the electricity legislation since 2019, and they have been considered in the auctions for the allocation of reception capacity in the public service electricity grid ("RESP") or for the purpose of project assessment in agreements with the grid operator.

The new National Electricity System Law enacted by Decree-Law no. 15/2022, of 14 January, which establishes the rules applicable to the licensing of these facilities, also sets some, few, specific rules for storage. 

Energy storage activity can be carried out in one of the following ways:

  • Autonomous Storagewhen the facility has a direct connection to the RESP and is not associated with a power plant or an self-consumption production unit (“UPAC”); or

  • Associated Storagewhen the facility does not have a direct connection to the RESP and is associated with an electricity generation. 

With 21 318 GWh of electricity generated in Portugal between January and June 2022 - 57% of which of renewable origin - storage will be decisive for the much-desired energy transition for two major reasons. On one hand, storage will offset the intermittent generation of renewable energy. On the other, storage ensures that the price of electricity injected into the grid never exceeds a particular value in case of price fluctuations.


Electricity generation and autonomous or stand-alone storage facilities are subject to prior control by the Portuguese energy authority (Direção-Geral de Energia e Geologia - "DGEG") according to the following procedures:

  • Production and Operation License: applicable to facilities with an installed capacity greater than 1 MW, or if subject to environmental impact assessment (“AIA”) or environmental incidences assessment.

  • Prior Registration and Operation Certificate: applicable to facilities with installed capacity greater than 30 kW and less than or equal to 1 MW and autonomous storage with installed capacity less than 1 MW.

  • Prior Notice: applicable to facilities with an installed capacity greater than 700 kW and equal to or less than 30 kW.

  • Generation facilities' projects with an installed capacity of 700 W or less are exempt from prior control.

The award of a Production License is subject to the prior obtaining a grid capacity reservation title in the RESP (título de reserva de capacidade - "TRC"). 

TRC can be acquired in one of three ways:

  • General Access: applicable if there is reception capacity at the RESP. It is subject to a deposit or bond of EUR10,000.00/MVA to DGEG for a minimum period of 30 months, or until the power plant or storage facility reaches commissioning.

  • Agreement with RESP operator: applicable if there is no reception capacity at RESP and subject to a maximum annual injection capacity set by the Government until 15 January of each year. Requires a deposit to the RESP operator in the amount of EUR15,000.00/MVA for a minimum period of 24 months. After the agreement is executed, this deposit is returned, and a General Access deposit to DGEG must be provided.

  • Tender Procedure: Applicable when the Government sets up a competitive procedure for the award of TRC. The terms and conditions for the award of TRC and the provision of the deposit are established in each tender documents.


The licensing of a storage facility associated with a generation plant may occur:

  • Ab Initio: where the permitting process for the generation and storage facilities start at the same time; or

  • A Posteriori: where a storage facility is installed in an already existing power plant.

In the case of associated storage Ab Initio, the prior control procedure is integrated in the generation plant permitting procedure, which will cover simultaneously the two activities (generation and storage).

The associated storage A posteriori will be construed as a non-substantial amendments to the Production License or Prior Registration, as the case may be. Non-substantial amendments are subject to the prior approval of DGEG and then recorded in the Production License or Prior Registration and, if applicable, in the Operating License or Operating Certificate. DGEG may require a new inspection of the facilities before authorising the amendment.?

The filings to amend the Production License are submitted to DGEG with the documents set out in Annex I to Decree Law n.º 15/2022. In turn, amendments to the Prior Registration are processed through DGEG's electronic platform. ?

Within five days of receipt of the application, DGEG will promote a new consultation to the external entities - such  as the Portuguese environment agency (Agência Portuguesa do Ambiente - "APA") - that have given their opinion in the context of the award of the Production License or Prior Registration. When the amendment relates to a project that has been submitted to an AIA procedure, a new consultation with this entity is waived, if the amendment does not entail any change:

  • To the AIA decision and underlying reasons; and 

  • To the increase of the the footprint of the power plant.

DGEG decides within 15 days after the deadline for reply from the consulted external entities. If the decision is of refusal, DGEG must submit it to prior hearing of the interested party.


In addition to the prior control procedure described in the two slides above, for the installing of an electricity plant with associated storage or of an autonomous storage facility, other licensing steps will be required:

  • Environmental assessment: Projects with an installed capacity exceeding 50 MW, or with more than 20 MW but located in sensitive areas are subject to AIA, or to an environmental incidences assessment procedure if, regardless of installed capacity, they are in sensitive areas.

  • Local Government Control: Construction of power plants or storage facilities are subject to comply with a licensing construction procedure before the Municipality through the obtainment of (i) a building permit, or (ii) an approval to a prior communication request.

  • Connection to the RESP: Connection between infrastructures connecting to RESP are built at the promoter's expense. Promoters may request expropriation for public utility, as well as request easement rights regarding the properties required for the installation of the electricity infrastructures that will be part of the RESP.

  • Operation License: Must be applied within one year after the award of the Production Licence, Deadline can be extended for another year on grounds beyond the promoter’s control.

  • Operation Certificate: Must be applied within nine months after the award of the Prior Registration. Deadline can be extended for a further half of the initial period on grounds beyond the promoter’s control.

Autonomous storage and associated storage AB Initio vs Associated Storage a Posteriori

Holders of renewable power plants or of storage facilities, with an allocated connection power greater than 50 MVA are obliged to transfer, on a one-off basis and free of charge, to the municipality or the municipalities where the power plant or storage facility is located:

  • An UPAC with an installed power equal to 0.3% of the connected power of the power station or storage facility; or

  • A storage facility for installation in municipal buildings or collective use equipment; or

  • Electric vehicle charging stations for public use with an equivalent capacity

Learn more by download the pdf below.