The year 2025 was marked by significant legislative and regulatory activity in the Portuguese Technology, Media and Telecommunications.
Developments in 2025 focused on the reinforcement of cybersecurity and critical infrastructure resilience through the transposition of the NIS2 and CER Directives, as well as on the development of new infrastructure supporting data transmission and electronic communications, notably through strategic investment in submarine cable systems aimed at strengthening connectivity and international data flows.
Regulatory action addressed key aspects of the electronic communications framework, notably through the approval of the number portability regulation, strengthening consumer protection by allowing end users to change providers more swiftly and at no additional cost, while lowering barriers to effective competition.
Set out below is an overview of the main legislative and regulatory developments adopted in Portugal during 2025 that are of particular relevance to TMT.
National Legislation
Decree-Law No. 2/2025 (23.01.2025)
Implements Regulation (EU) 2022/868 (Data Governance Act) in Portugal, designating the competent national authorities and establishing the applicable sanctioning regime. The decree assigns supervisory powers to ANACOM for data intermediation services, with direct implications for digital platforms and operators involved in controlled data sharing activities.
Ordinance No. 166/2025/2 (28.02.2025)
Establishes procedures for determining revenues relevant to calculating the financial contribution payable by providers of electronic communications networks and services under the general authorisation regime. The ordinance standardises calculation and reporting through a mandatory declaration model, electronically submitted to ANACOM, and enhanced audit mechanisms.
Decree-Law No. 22/2025 (19.03.2025)
Transposes Directive (EU) 2022/2557 (CER) into Portuguese law, establishing a national framework for the identification of critical entities and the enhancement of their resilience. The decree defines the competent authorities, sets out the applicable obligations and procedures, and establishes the supervisory and sanctioning regime applicable to entities providing essential services.
Order No. 5477/2025 (14.05.2025)
Assigns to the Institute for Mobility and Transport (IMT, I.P.) responsibility for overseeing the management of the Atlantic CAM concession agreement between the Portuguese State and Infraestruturas de Portugal, S.A.
Authorises the Government to establish a new legal framework for cybersecurity through the transposition of Directive (EU) 2022/2555 (NIS2).
The decree sets out the scope and governance structure of the future regime, including risk management and incident notification obligations, supervisory and enforcement powers, and the applicable sanctioning framework, while also allowing for amendments to related legislation and establishing a 180-day period for the exercise of the legislative authorisation.
For more information on this subject, please refer to our newsletter of 24 November 2025.
Council of Ministers Resolutions No. 183/2025,184/2025 and185/2025 (26.11.2025)
Establishes Portugal's strategic framework for submarine cable infrastructure development.
Resolution 183/2025 updates the multi-year expenditure authorisation for the Atlantic CAM system. Resolution 184/2025 mandates preparatory studies for the complementary “Anel Açores” submarine cable system, requiring open wholesale access and enhanced cybersecurity compliance. Resolution 185/2025 authorises Infraestruturas de Portugal to incur multi-year expenditure and to allocate financial commitments relating to the subcontract for the operation, management and maintenance of the Atlantic CAM submarine cable system.
For more information on this subject, please refer to our newsletter of 28 November 2025.
Decree-Law No. 125/2025 (4.12.2025)
Establishes a new national cybersecurity framework through the transposition of Directive (EU) 2022/2555 (NIS2). The decree defines the categories of covered entities and the governance model, identifies the competent authorities, and sets out risk management and incident notification obligations. It also establishes the applicable supervisory powers and sanctioning regime, thereby strengthening Portugal’s overall cybersecurity.
For more information on this subject, please refer to our newsletter of 15 December 2025.
ANACOM rulings and public consultations
Regulation No. 38/2025 (9.01.2025)
Establishes the rules applicable to the number portability regime, ensuring that end users can retain their telephone numbers when switching providers of electronic communications services.
The regulation defines the procedural and operational requirements applicable to providers, including cooperation obligations, processing timelines and technical arrangements necessary to ensure a smooth, timely and uninterrupted switching process. The regime supports consumer protection and promotes effective competition by reducing barriers to changing service providers.
For more information on this subject, please refer to our newsletter of 13 January 2025.
Notice No. 22408/2025/2 (10.09.2025)
Approved the draft regulation setting out the technical instructions applicable to the deployment of reduced-area wireless access points, implementing Decree-Law No. 97/2024, and defining installation requirements to ensure minimal visual impact and compliance with applicable technical standards.
The draft regulation was submitted to a 30-day public consultation, which closed on 22 October 2025.
Notice No. 22543/2025/2 (11.09.2025)
Approves a draft amendment to Regulation No. 86/2007, updating electromagnetic field monitoring and measurement procedures to reflect technological developments, notably the deployment of 4G and 5G networks. The draft introduces specific rules for small-area wireless access points, adjusts decision levels to avoid double counting of measurement uncertainties, and modernises monitoring obligations to align with current technical standards.
The draft regulation was submitted to a 30-day public consultation, which closed on 23 October 2025.
Notice No. 22650/2025/2 (12.09.2025)
Approves a draft amendment to Regulation No. 256/2009, updating the rules on the identification and signage of radiocommunications stations to reflect current regulatory and operational requirements.
The draft regulation was submitted to a 30-day public consultation, which closed on 24 October 2025, and was approved on 23 December 2025.
Approves the draft decision setting out the regulatory framework applicable to the international wholesale traffic carrier services, clarifying its qualification under the Portuguese Electronic Communications Law and the criteria for determining when such services fall within the scope of the regulatory framework.
The draft decision was submitted to a 30-day public consultation, which closed on 19 January 2026.
For more information on this subject, please refer to our newsletter of 17 December 2025.