PORTUGAL Trends and Developments Contributed by: Carla Azevedo Gomes, Pedro Malta da Silveira, Miguel Duarte Santos and Camila Cândido, SPS-Barrilero
Emerging risks at the centre of strategic attention Emerging risks have moved to the forefront of stra- tegic and legal analysis in the Portuguese insurance sector, with climate change, cybersecurity and health- related risks receiving particular attention in 2025. Climate risk Climate-related risks are increasingly recognised as structural and systemic. The frequency and severity of extreme weather events have affected claims, particu- larly in property, agricultural and business interruption insurance. Insurers are responding by: • incorporating climate data into underwriting and pricing models; • reassessing exposure concentrations; • adjusting reinsurance strategies; and • aligning risk management practices with ESG and sustainability expectations. From a legal and regulatory perspective, climate risk also raises questions regarding disclosure obligations, solvency assessment and long-term product sustain- ability. Cyber risk Cyber risk represents both an operational threat to insurers and a growing line of insurance business. Increased digitalisation has expanded insurers’ expo- sure to cyber incidents, including data breaches, sys- tem outages and ransomware attacks. At the same time, demand for cyber insurance prod- ucts continues to grow, creating challenges in terms of risk quantification, accumulation management and policy wording. Regulatory initiatives such as DORA reinforce the need for robust governance of cyber risk at board level. Health risk Health insurance remains under pressure due to ris- ing medical costs, demographic ageing and increased utilisation of healthcare services. Insurers are explor- ing cost-containment measures, preventive health programmes and digital health solutions to enhance sustainability.
These developments raise legal and regulatory con- siderations relating to product design, transparency and consumer protection. Intense sectoral debate and market forums The Portuguese insurance sector in 2025 was char- acterised by intense discussion and reflection within industry forums, conferences and professional events. These platforms bring together insurers, reinsurers, regulators, intermediaries, legal professionals and technology experts to discuss: • implementation of new regulatory frameworks; • digital transformation challenges; • emerging risks; and • the future role of insurance in economic and social resilience. Such debates contribute to greater alignment of mar- ket practices, dissemination of best practices and early identification of regulatory and operational chal- lenges. Continued market concentration among leading players In Portugal, market concentration among leading insurance groups has continued to deepen and con- solidate, reflecting a combination of historical market structure, increasing regulatory intensity and strategic economic factors. This concentration did not emerge as a short-term development in 2025, but rather as the result of long-standing trends that have been rein- forced by technological and regulatory transformation. Drivers of concentration Key drivers include: • increasing regulatory and compliance costs; • substantial investment requirements in technology and cybersecurity; and • economies of scale in underwriting, capital man- agement and data analytics. Larger insurance groups are better positioned to absorb these costs and meet regulatory expectations, while smaller players face higher barriers to growth.
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