29 June 26 | Lisboa
TOL LEGAL FLASH N 2
Legal Flash

The TOL Legal Flash is a weekly publication by TOL Legal Team summarising the most relevant legislative, case law and EU doctrinal developments from the preceding week.

 CONSELHO DE MINISTROS 

1. Public Procurement Code Reform — Final Version Approved Following Public Consultation

The Council of Ministers of 25 June 2026 approved the final version of the Public Procurement Code (CCP) reform, incorporating over 100 contributions from public consultation. Key changes: (i) elimination of prior review of the execution project; (ii) project amendments at contractor's initiative (with author consent); (iii) tacit approval of subcontracting if no response within 30 days; (iv) removal of the mandatory base price. New thresholds: direct award for goods/services rises from €20,000 to €75,000; prior consultation from €75,000 to €130,000; for works, direct award to €150,000; prior consultation up to €1,000,000. Also introduces the 'once only' principle, AI in procedures and a 'spontaneous initiative' mechanism. Awaiting Presidential promulgation. Relevant for: Public Procurement, Real Estate, Urban Planning and M&A.

Conselho de Ministros, 25 junho 2026 | Decreto-Lei (aguarda promulgação)

CONSELHO DE MINISTROS 

2. Second Revision Protocol of the Albufeira Convention — Cross-Border River Basin Management

The Council of Ministers approved a Draft Resolution for Parliament's ratification of the Second Revision Protocol of the Albufeira Convention on cross-border water management between Portugal and Spain. For the first time, a specific water flow regime is established for the Guadiana river at Pomarão, ensuring equitable distribution of water resources and preservation of the estuary. Relevant for: Environmental Law, Real Estate and European Law.

Comunicado do Conselho de Ministros, 18 junho 2026 | Proposta de Resolução à AR

CONSELHO DE MINISTROS 

3. National Strategy for Climate Change Adaptation 2030 (ENAAC 2030)

The ENAAC 2030 was approved, launching the third national climate adaptation cycle, integrated within the PTRR. It targets resilience against heatwaves, droughts, wildfires and floods. The previous ENAAC 2020 is extended to 31 December 2026 to maintain Portugal 2030 funding access. Relevant for: Urban Planning, Real Estate and EU Funds.

Comunicado do Conselho de Ministros, 18 junho 2026 | Resolução do Conselho de Ministros

CONSELHO DE MINISTROS 

4. Armed Forces Personnel Cap 2026–2028 — €154 Million Investment

The Decree-Law fixing the Armed Forces at approximately 31,000 personnel for 2026–2028 was approved, representing an investment of €154 million. Sets 16,100–16,500 in Permanent Cadres, 13,700 under volunteer/contract arrangements, and over 2,400 in training. Framed within Portugal's NATO commitments and Armed Forces modernisation.

Comunicado do Conselho de Ministros, 18 junho 2026 | Decreto-Lei

CONSELHO DE MINISTROS 

5. Energy Cost Relief Scheme Adjusted for Agriculture, Forestry, Fisheries and Aquaculture

The extraordinary energy cost relief Decree-Law for agriculture, forestry, fisheries and aquaculture was amended, aligning it with the EU temporary State Aid framework in the Middle East crisis context. The adjustment avoids rapid exhaustion of the de minimis threshold. Relevant for: Tax Law, EU Law and Public Grants.

Comunicado do Conselho de Ministros, 18 junho 2026 | Decreto-Lei

CONSELHO DE MINISTROS 

6. Vehicle Conversion Regulation — New Rules for Post-Registration Modifications

The final Decree-Law establishing the Vehicle Conversion Regulation was approved, setting rules for modifications to already-registered vehicles and their systems. Conversions require prior authorisation from IMT and must not compromise road safety or increase pollutant emissions. Strengthens technical certification requirements.

Comunicado do Conselho de Ministros, 18 junho 2026 | Decreto-Lei

CONSELHO DE MINISTROS 

7. Establishment of the PTRR Agency — Portugal Transformation, Recovery and Resilience

Council of Ministers Resolution No. 134/2026 of 24 June created the 'PTRR Agency' as a mission structure to oversee Portugal's Transformation, Recovery and Resilience Plan, following the extreme weather events of early 2026. Chaired by Prof. Luís Leite Ramos, with a mandate until 31 December 2034. Relevant for: Urban Planning, EU Funds and Public Procurement.

Resolução do Conselho de Ministros n.º 134/2026, DR, 24 junho 2026

ASSEMBLEIA DA REPÚBLICA 

8. Strengthening the Right to Be Forgotten in Credit and Insurance — Law No. 14/2026 of 27 April

Law No. 14/2026, in force since 2 May 2026, strengthens the right to be forgotten in credit and insurance contracts. It extends protection to individuals who have overcome oncological disease, HIV, diabetes and hepatitis C. Establishes a new complaints mechanism and alternative dispute resolution system. Relevant for: Banking & Insurance Law and Consumer Protection.

Lei n.º 14/2026, de 27 de abril, DR | Em vigor: 2 maio 2026

ASSEMBLEIA DA REPÚBLICA 

9. Implementation of the Digital Services Act (DSA) in Portuguese Law — Law No. 12-A/2026

Law No. 12-A/2026, in force from 16 April 2026, implements the EU Digital Services Act in Portuguese law. Designates ANACOM as the Digital Services Coordinator; assigns sectoral competences to ERC and CNPD. Sanctions regime with fines up to 6% of global annual turnover. Decisions appealed before the Competition, Regulation and Supervision Court. Relevant for: Digital Law, Compliance and M&A.

Lei n.º 12-A/2026, de 15 de abril, DR | Em vigor: 16 abril 2026

Note: This Legal Flash is for informational purposes only and does not constitute legal advice. For legal advice, contact TOL Legal Team.

Please note, your browser is out of date.
For a good browsing experience we recommend using the latest version of Chrome, Firefox, Safari, Opera or Internet Explorer.