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European Accessibility Act: Portugal (Decreto-Lei n.º 82/2022)
PT- Applies from
- 2025-06-28
- Maximum penalty
- €44,891.81
- Enforcement authority
- Split by product/service category, with no single central coordinator: ASAE (Autoridade de Segurança Alimentar e Económica) covers general IT products, self-service terminals and e-books; ANACOM covers electronic communications products and services; ERC covers audiovisual services; the Autoridade da Mobilidade e dos Transportes and ANAC cover transport services and terminals; Banco de Portugal covers banking and payment services; CMVM covers investment services; municipalities cover ATMs. — https://www.asae.gov.pt/
- Microenterprise exemption
- Yes — under the EAA's EU-wide microenterprise exemption for services
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- National law
- Decreto-Lei n.º 82/2022, de 6 de dezembro
- Notes
- Article 29(2) of Decreto-Lei 82/2022 sets a tiered fine (coima) structure for administrative offences: 'grave' breaches carry €650–€1,500 for individuals and €12,000–€24,000 for companies; 'muito grave' breaches are capped at the general maximum set by Portugal's framework law for administrative offences, Decreto-Lei 433/82, Article 17 — €44,891.81 for companies acting with intent (dolo), roughly half that for negligent conduct. DL 82/2022 incorporates this general ceiling by reference rather than restating it; the fine actually imposed within that ceiling also scales with recidivism, the number of non-conforming units, and the number of people affected.
Who is obligated in Portugal
Portugal's transposition, Decreto-Lei n.º 82/2022, applies the EAA's full scope: consumer general-purpose computers and operating systems, smartphones, e-readers, self-service terminals (payment terminals, ATMs, ticketing and check-in machines), plus services including e-commerce, banking, e-books, electronic communications, audiovisual media access, and passenger transport information. Manufacturers carry primary responsibility for building in accessibility and drafting the technical file, while importers and distributors must verify compliance before placing products on the market or making them available. As across the EU, the microenterprise exemption (fewer than 10 staff, turnover or balance sheet under €2 million) applies fully to service providers, who are entirely excluded from scope for services; for products, microenterprises get only partial relief, such as exemption from documenting their disproportionate-burden assessment, not from the underlying accessibility duty itself.
What happens if you don't comply
Enforcement is split among sector regulators rather than centralised: ASAE for general IT products, self-service terminals and e-books; ANACOM for electronic communications; ERC for audiovisual services; the Autoridade da Mobilidade e dos Transportes and ANAC for transport; Banco de Portugal for banking and payment services; CMVM for investment services; and municipalities for ATMs. In practice a firm's regulator depends on what it sells. These bodies investigate complaints and can order corrective action; non-compliance is framed as a contraordenação (administrative offence) rather than a crime, with fines scaling by severity and by aggravating factors such as repeat offending, the number of non-conforming units placed on the market, and how many people were affected. The general administrative-offence procedure governs notice, defence rights, and appeal before any fine becomes final.
How this differs from the EU baseline
Portugal's most distinctive feature is how thoroughly it fragments enforcement — nine differently named authorities plus municipalities as a class, each covering a narrow slice of the product or service list, considerably more granular than the 'one coordinator plus a couple of sector regulators' pattern seen elsewhere. There is no single national accessibility ombudsman coordinating across sectors. Portugal also does not fix its own penalty ceiling in the transposition law; it borrows the general administrative-offence ceiling from a 1982 framework law used across unrelated regulatory domains. One genuine Portugal-specific addition is an extended 2027 deadline (rather than 2025) for accessibility of emergency number 112 handling, and a 20-year grandfathering allowance for self-service terminals already lawfully in service before June 2025.
How to complain
Because enforcement is split by sector, the right channel depends on the product or service — but the most broadly applicable route is ASAE's national complaints book (Livro de Reclamações), available electronically and reachable via ASAE's own site. Any consumer can file, not just the directly affected person, and paper and electronic versions carry equal legal weight; the electronic book allows filing at any time, including after leaving an establishment. ASAE forwards complaints to whichever entity actually has jurisdiction — for example ANACOM for a telecoms product, or Banco de Portugal for a banking service — when it isn't the right body itself. A dedicated phone support line (217 998 010) backs the electronic complaint book.
Frequently asked questions about the EAA in Portugal
- What is the maximum EAA fine in Portugal?
- The maximum penalty is €44,891.81. Article 29(2) of Decreto-Lei 82/2022 sets a tiered fine (coima) structure for administrative offences: 'grave' breaches carry €650–€1,500 for individuals and €12,000–€24,000 for companies; 'muito grave' breaches are capped at the general maximum set by Portugal's framework law for administrative offences, Decreto-Lei 433/82, Article 17 — €44,891.81 for companies acting with intent (dolo), roughly half that for negligent conduct.
- Who enforces the European Accessibility Act in Portugal?
- Split by product/service category, with no single central coordinator: ASAE (Autoridade de Segurança Alimentar e Económica) covers general IT products, self-service terminals and e-books; ANACOM covers electronic communications products and services; ERC covers audiovisual services; the Autoridade da Mobilidade e dos Transportes and ANAC cover transport services and terminals; Banco de Portugal covers banking and payment services; CMVM covers investment services; municipalities cover ATMs. Details are published at https://www.asae.gov.pt/.
- Since when does the EAA apply in Portugal?
- The requirements apply from 28 June 2025, the EU-wide date, transposed into Portugal by Decreto-Lei n.º 82/2022, de 6 de dezembro.
- Are small businesses exempt from the EAA in Portugal?
- Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Portugal that places a covered product on the market still has to make that product accessible.
- How do I report an inaccessible website in Portugal?
- Complaints go to the national complaint route at https://www.asae.gov.pt/reclamacoes-e-denuncias/livro-de-reclamacoes.aspx. The enforcement authority above handles market surveillance separately.
Official source: https://diariodarepublica.pt/dr/detalhe/decreto-lei/82-2022-204379872
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.