Summary
Details
- Portugal
Legally binding for:
Operators of charging points and mobility service actors subject to RJME and ERSE operational rules.
Data and interoperability obligations where required by the regime and AFIR alignment mechanisms.
Transitional provisions can allow limited continuation of prior operational rules, but only within the conditions of the RJME transition.
Applicability varies by role (operator, service provider, data-related entity) and by public vs private network scope.
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What’s Required
Portugal updated its electric mobility framework in 2025 to regulate the organisation, access, and operation of charging activities and to align with the EU alternative fuels infrastructure context.
Key requirements include:
Decree-Law 93/2025 establishes the new Legal Framework for Electric Mobility (RJME), governing access and exercise of electric mobility activities and replacing the previous framework.
The decree-law includes transitional provisions and references AFIR-related data and system roles (including data aggregation and reporting interfaces for charging networks).
ERSE adopted a new Electric Mobility Regulation via ERSE Code No. 3/2025 (22 December 2025), updating operational rules under the new legal framework and repealing the prior regulation.
Important Deadlines
14 August 2025: Decree-Law 93/2025 published (new RJME).
22 December 2025: ERSE Code 3/2025 approved (new regulatory framework).
Transition timing exists under the regime; operators should track transitional obligations and optional continuation of previous operational rules during the transition, where permitted.
Current Status
In force and actively implemented through ERSE regulation and sector transition arrangements.
Penalties for Non-Compliance
Regulatory enforcement through administrative sanctions and corrective orders under the RJME and ERSE rulebooks.
Restrictions on market participation, operational limitations, and compliance orders where rules on access, interoperability, transparency, or data duties are breached.
Examples of Known Violations
Operating charging points without meeting the required operator status or compliance obligations under the RJME.
Failure to meet required operational, transparency, pricing, or data obligations under ERSE rules, particularly during transition periods.
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