AI disclosure requirements in Portugal: what applies from 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