AI disclosure requirements in Portugal: what applies since 2 August 2026

The EU AI Act's transparency obligations are a Union-wide regulation, so the substance is the same in Portugal as everywhere in the EU: from 2 August 2026, AI systems that interact with people must disclose they're AI, synthetic media must carry machine-readable marking, and deepfakes and certain AI-generated public-interest text must be labeled. What differs country by country is who enforces it, in what language your users encounter it, and how quickly complaints turn into questions, which is what this page covers for Portugal.

Enforcement in Portugal

Portugal designated ANACOM (the national telecoms and postal regulator) on 19 September 2025 as the single market-surveillance authority and national point of contact for the AI Act, coordinating fourteen sectoral authorities, including the central bank (Banco de Portugal), the securities regulator (CMVM), and the data protection authority (CNPD) for data-protection matters. Portugal missed the Act's 2 August 2025 designation deadline before naming ANACOM, and has signalled no dedicated national AI law is planned: governance runs through ANACOM plus existing sectoral frameworks rather than new domestic legislation. ANACOM is also tasked with standing up a regulatory sandbox, not yet operational at the time of review. Article 50 itself applies from 2 August 2026 regardless, with the EU's penalty ceiling of €15 million or 3% of worldwide annual turnover.

The four duties, as they show up on your site

• Article 50(1): chatbot disclosure. Any AI system interacting with visitors must make that clear no later than the first interaction, in a clear and distinguishable way. A line in your terms doesn't satisfy it.
• Article 50(2): machine-readable marking. AI-generated audio, images, video, and text must be marked in a machine-readable, detectable format. For generative systems already on the market before 2 Aug 2026, this specific duty has a transition until 2 Dec 2026; the rest does not.
• Article 50(3): emotion recognition & biometric categorisation. People exposed must be informed the system is operating.
• Article 50(4): deepfake and AI-text labels. Visible disclosure for deepfakes, and for AI-generated or manipulated text published to inform the public on matters of public interest.

Portugal-specific practicalities

• ANACOM's single-regulator model means chatbot-disclosure and AI-labelling complaints have one clear front door, with sector regulators (Banco de Portugal, CMVM, CNPD) pulled in only where your AI feature touches their domain
• No dedicated Portuguese AI statute is planned, the EU regulation is the whole rulebook here, so ANACOM guidance and the Commission's own materials are the sources to watch, not a forthcoming national law
• The CNPD (data protection authority) is competent today wherever your AI feature processes personal data, ahead of any AI-Act-specific enforcement ramping up
• Keep the Portuguese-language first-interaction screenshot in your evidence file, a notice your Portuguese users can't read is a weak notice

Disclosure language should match your user-facing language. For a site serving Portugal in Portuguese, a first-message line such as "Está a conversar com um assistente de IA" (you're chatting with an AI assistant) is the pattern to aim for, at first interaction, not buried in termos e condições.

Common questions