PORTUGAL Trends and Developments Contributed by: Carla Azevedo Gomes, Pedro Malta da Silveira, Miguel Duarte Santos and Camila Cândido, SPS-Barrilero
as an efficiency tool, but as a key driver of competi- tiveness and client retention. Automation, data analytics and artificial intelligence Insurers are making extensive use of automation, data analytics and artificial intelligence in areas such as underwriting, pricing, fraud detection and claims management. These technologies enable more accu- rate risk assessment, faster decision-making and enhanced personalisation of insurance products. However, their deployment raises a range of legal and regulatory considerations, including: • compliance with data protection rules; • transparency and explainability of automated decision-making; • governance of algorithms and models; and • accountability for outcomes generated by artificial intelligence systems. As a result, insurers are increasingly required to inte- grate legal and compliance considerations into tech- nology development and deployment, ensuring that innovation is supported by appropriate governance frameworks. Omnichannel distribution and human interaction Despite the rapid expansion of digital channels, insur- ers continue to recognise the importance of human interaction, particularly in complex or sensitive situa- tions such as claims disputes or high-value underwrit- ing decisions. The prevailing model in 2025 was one of omnichannel integration, combining digital efficiency with personalised support. Increasingly demanding regulation, particularly in technology and compliance One of the most significant developments affecting the Portuguese insurance market in 2025 was the inten- sification of regulatory and supervisory requirements, especially in areas related to technology, operational
• corporate governance arrangements; • internal control and risk management systems; • outsourcing and third-party dependencies; and • operational and technological resilience. Technology-related risks are now explicitly incorpo- rated into supervisory assessments, reflecting the growing reliance of insurers on digital infrastructures and external service providers. Digital Operational Resilience Act (DORA) The application of DORA from January 2025 consti- tutes a major regulatory milestone for insurers oper- ating in Portugal. DORA establishes a harmonised framework at EU level for managing ICT risks across the financial sector. Under DORA, insurers are required to implement com- prehensive ICT risk management frameworks, includ- ing: • identification and classification of ICT assets and risks; • mandatory reporting of significant ICT-related incidents; • regular testing of digital operational resilience; and • oversight of critical third-party ICT service provid- ers. These obligations extend beyond IT departments and require direct involvement of management bod- ies, reinforcing the accountability of boards and senior management for technological resilience. Compliance as a core governance function In this regulatory context, compliance functions have evolved into central governance pillars. Insurers must demonstrate not only formal compliance with regula- tory requirements, but also the effectiveness of inter- nal controls, documentation and decision-making processes. The integration of legal, compliance, risk and IT func- tions has therefore become essential to meet supervi- sory expectations and mitigate regulatory risk.
resilience and compliance. Supervisory focus of the ASF
The Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF) continues to adopt a proactive supervisory stance, placing increased emphasis on:
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