Corporate M and A 2026

PORTUGAL Trends and Developments Contributed by: Martim Morgado and Joana Geada dos Santos, CS’Associados

AI Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 (the AI Regulation) will be fully in force by August 2026, although some of the provisions already entered into force during 2025. Although the AI Regulation primarily regulates devel - opers and deployers of high-risk systems, it is expect - ed to have an impact on infrastructure providers. Data centre operators and cloud service providers may face heightened contractual demands relating to availabil - ity, auditability, traceability and security.

The interaction between AI compliance, cybersecu - rity governance and data protection requirements is likely to increasingly influence contractual structures and operational standards, even where infrastructure operators are not directly regulated as AI system pro - viders.

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