PORTUGAL Law and Practice Contributed by: Leonor Futscher de Deus, Broseta Abogados, SLP
11.2 New Products or Alternative Solutions See 11.1 Emerging Risks Affecting the Insurance Market . 12. Developments in Insurance Law 12.1 Significant Legislative or Regulatory Developments In terms of other regulatory developments from the ASF in 2025, the following details are worth highlight- ing. • Recommendation to insurers to make a clear dis- tinction between health insurance and health plans – Recommendations No 1/2025 of 8 April 2025. • Reporting of information regarding PEPPs – Regu- latory Standard No 2/2025-R of 8 April 2025.
• Reporting of serious ICT-related incidents and significant cyber threats – Circular No 3/2025 of 8 April 2025. • Amendments to Regulatory Standard No 13/2020- R regarding insurance intermediaries, aimed at simplifying the regulatory requirements applicable to ancillary insurance intermediaries – Regulatory Standard No 4/2025-R of 27 May 2025. • Approval of “standard terms” regarding health insurance – Circular No 6/2025 of 3 June 2025. • New disclosure duties applicable to pension funds – Regulatory Standard No 7/2025-R of 26 August 2025. • Recommendation on gender diversity in insurance companies and pension fund management enti- ties – Recommendations No 4/2025 of 9 December 2025.
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