PORTUGAL Law and Practice Contributed by: Assunção Cristas, Catarina Pinto Correia and Carolina Vaza, VdA
On 18 March 2026, the amendment to the Europe - an Climate Law was published in the Official Jour - nal of the European Union, introducing an obligation to achieve a 90% reduction in net greenhouse gas emissions by 2040, compared with 1990 levels. This amendment therefore fulfils that legal obligation by introducing a new target, in addition to the existing intermediate target, of at least a 55% net reduction in emissions by 2030, which has been part of the law from the outset. The European Climate Law originally established the European Union’s commitment to achieve climate neutrality across the entire economy by 2050, by reducing net greenhouse gas emissions by that date and aiming thereafter to achieve net neg - ative emissions. The introduction of the 2040 legal target is consist - ent with the Climate Law and represents a significant development in the EU’s long-term climate policy. However, notwithstanding a more demanding time - line, the Regulation also provides flexibility in how cli - mate neutrality is to be achieved, notably by allowing greater scope for compensation mechanisms. It also sets out important policy guidelines regarding carbon removals, the use of international carbon credits, the competitiveness of European industry, and the evolu - tion of the EU Emissions Trading System (EU ETS). 2. National Policy and Legal Regime (Overview) 2.1 National Climate Change Policy At the end of 2025, the EC submitted to the UNFCCC an updated version of the EU NDC on behalf of the EU and its member states, replacing the previous one submitted in 2023. In the new document, the EC reit - erates the EU’s target of achieving a 55% net reduc - tion in greenhouse gas emissions by 2030, whilst introducing an indicative contribution of 66.25% to 72.5% for 2035, on the path towards carbon neutral - ity by 2050. The updated NDC builds on previous commitments, aiming to accelerate the transition to a decarbonised economy and industry, and outlines the EU’s ongoing efforts to achieve climate neutrality, in line with the objectives of the Paris Agreement. It should be noted that after the first Global Stocktake at COP28 in Dubai, the European Commission assumed
an intermediate target of reducing 90% of emissions by 2040. As a member of the EU, Portugal is fully committed to the goals of the UNFCCC. It was part of the Kyoto Protocol and was particularly active in the preparation of the Paris Agreement. These interna - tional commitments have been implemented into the national climate change and energy efficiency legal framework through various instruments. • The Roadmap to Carbon Neutrality (2050), which determines renewable energy targets for Portugal, set at 80% by 2030 and 100% by 2050. • The National Climate and Energy Plan 2030 (PNEC 2030), which was updated in 2025 according to the provisions of the national Climate Framework Law, anticipates, within four years, reaching the goal of incorporating renewable energies in electricity production. Thus, as of 2026, 80% of the energy produced in the national territory should be of renewable origin. • The Decree-Law No 84/2022, amended by Decree- Law No 23/2023, ensures the reinforcement of measures to accelerate the energy transition and the decarbonisation of the economy, establishing targets concerning energy consumption for renew - able energy. For instance, in 2024, fuel suppliers, in addition to other mandatory measures, are also required to make a minimum annual contribution of advanced biofuels and biogas of 0.7% on the quantities of fuels they release for consumption. • The National Air Strategy focused on the improve - ment of air quality. Portugal has also approved the Green Growth Com - mitment (CCV), that imposed the following goals to be achieved in 2020 and 2030: • reduce greenhouse gas emissions by between 30–40% in relation to 2005; • increase the share of renewable energy in the final consumption of energy to 40%, which has been updated to 49% by Decree-Law No 84/2022, amended by Decree-Law No 23/2023; and • increase energy efficiency through a reduction of 30% over the energy baseline in 2030. The Portuguese Parliament also approved the Climate Framework Law in 2021, establishing the principles of
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