Climate Change Regulation 2026

PORTUGAL Law and Practice Contributed by: Assunção Cristas, Catarina Pinto Correia and Carolina Vaza, VdA

• carry out their activities in compliance with the minimum safeguards, which include a due dili - gence through the value chain. Compliance with Minimum Safeguards implies the execution of due diligence procedures to ensure the alignment with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Busi - ness and Human Rights. Although the alignment with the European Taxonomy is optional, the mandatory reporting represents a significant pressure. The tech - nical screening criteria of the Taxonomy Delegated Acts is also under simplification in the context of the Omnibus I package. In Portugal, there are no statutory duties to perform due diligence throughout the value chain. Nonetheless, with the transposition into the Portuguese legal order of the CSDDD, the statutory duties to perform due diligence on environmental and social matters are expected to be established through a progressive in scope timeline from 2029. The CSD - DD will require in-scope companies to conduct envi - ronmental (which includes climate related) and human rights due diligence. This includes EU and non-EU companies and parent companies with over 5,000 employees and with a turnover of more than EUR1.5 billion in the EU, as well as franchises with a turnover of more than EUR275 million if at least EUR75 million was generated by royalties in the EU. In-scope com - panies must integrate due diligence in their policies, identify actual or potential adverse impacts, prevent and mitigate potential adverse impacts, monitor the effectiveness of their due diligence policy and meas - ures, and publicly communicating on due diligence. Since the CSDDD is built on a value chain approach, it will have an indirect impact on SMEs, as these SMEs are part of the chain of activities. 6. Climate-Friendly Investment Support 6.1 Renewable Energy Portugal has implemented the National Action Plan for Renewable Energies, establishing concrete objec - tives regarding the share of Portugal’s energy sup - ply from renewable sources, as well as the National Action Plan for Energy Efficiency. Concerning energy efficiency, Portugal has established an energy cer - tification system for buildings, with the purpose of

improving the energy performance of buildings and making the obtaining of energy certificates mandato - ry. More recently, the National Long-Term Strategy to Eliminate Energy Poverty 2023–2050 was approved. Its main goal is to eradicate energy poverty in Por - tugal by 2050, protecting vulnerable consumers and actively integrating them into the energy and climate transition, which is intended to be fair, democratic and cohesive. The major objectives established by the Climate Framework Law regarding the energy sec - tor were to ban the use of coal to produce electricity from 2021, and the use of natural gas of fossil origin to produce electricity from 2040. With regard to energy supply, it is worth noting that the ocean will play a key role as an important source of electricity production. Recently, the following decrees and decisions regard - ing renewable energies were approved and published. • Decree-Law 85/2025, which sets targets for the integration of energy from renewable sources in the industry and transport sectors. • Decree-Law 22/2024, that extends the exceptional measures to simplify procedures for the produc - tion of energy from renewable sources. It aims to maintain the exceptional and temporary meas - ures established in 2022 for the implementation of projects and initiatives for the production and storage of energy from renewable sources, includ - ing the procedures for the prior control of urban operations, in order to adapt them to the material simplicity of the operations for the installation of power plants for renewable energy sources and the production of hydrogen by water electrolysis. • Decree-Law 18/2024, that creates a mechanism to compensate municipalities for strategic elec - tricity 18 projects of great impact that generate significant negative externalities in their territories. The objective is to establish a compensations framework (financial or other) for municipali - ties strongly impacted by high-impact strategic national projects that involve the construction and rapid operation of new renewable power plants, energy storage facilities and the development of new electricity grid capacities developed as part of the acceleration of the energy transition to reduce dependence on fossil fuels. • Resolution of the Council of Ministers 19/2025, that approves the Allocation Plan for Offshore

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