PORTUGAL Trends and Developments Contributed by: André Miranda, Fieldfisher Portugal
for onshore wind. The solar polygons considered in the mapping typically exceed 100 hectares and are located within 10 km of a grid substation. Areas out- side ZAER are not excluded from development, but do not benefit from acceleration mechanisms. The main benefit of the ZAER framework is procedur- al simplification. Projects located within these zones benefit from coordinated and expedited licensing, supported by a centralised (“one stop shop”) model promoted by EMER 2030, which integrates electrical, environmental and planning components and ensures coordination between authorities such as the DGEG and the Portuguese Environment Agency, alongside municipalities. In environmental terms, the key feature is that the strategic environmental assessment carried out at programme level allows, in principle, for the dispens- ing of project-level environmental impact assessment (AIA) within ZAER, without prejudice to compliance with applicable environmental constraints and permit- ting requirements. For developers, this single-window and pre-assessed zoning approach is expected to reduce both timelines and transaction costs, while providing greater regula- tory visibility and predictability regarding the path to construction. During its preparation, the programme incorporated input from a wide range of public bodies consulted on matters such as the delimitation of the zones, grid integration, mapping scale and the role of municipali- ties. EMER 2030 is incorporating much of this feedback as the text is refined. The process has been conten- tious rather than smoothly collaborative. Both the pro- gramme and the authorities’ opinions remain in pub- lic consultation until mid-July 2026, with the shared aim of securing a delimitation that is environmentally
significant opportunity, and the two policies address it at both scales, though neither is yet fully operative. At utility scale, the ZAER framework provides devel- opers with a key element that has long been lacking: greater spatial and procedural certainty, combined with faster and more predictable permitting. For pro- ject finance, a defined outer limit on licensing and a pre-cleared site materially improve bankability, and the regime applies to a sizeable pipeline of solar and onshore wind capacity still to be built. That pipeline, once the zones are confirmed, trans- lates into construction activity, local employment and investment, much of it in the interior regions where many of the zones lie, bringing land rents, munici- pal revenue and skilled work to areas that have often experienced population decline. One caveat belongs in any serious assessment of the scale of this opportunity: official analysis of the pro- posed zones found that grid connection capacity, not land availability, is the binding constraint. Less than 20% of the territory mapped as suitable for solar sits within realistic reach of available substation capacity. At distributed scale, Law No 29/2026 unlocks zero- capex, third party-owned solar: specialist providers can put idle rooftops, terraces and low-value land to productive use, while households, condominiums, small and medium-sized enterprises (SMEs) and industry obtain cheaper on-site power without upfront cost. It builds on a contracting culture already vis- ible in Portugal’s growing corporate power purchase agreement market. The simple majority condominium rule opens the mul- ti-apartment buildings that hold much of the country’s untapped rooftop potential; the aggregator platform and last resort regime put surplus energy to use and sharpen competition; and adjacent markets follow: behind-the-meter storage, flexibility and demand- response services, energy-management software and the data services that energy sharing requires. Each of these segments is a business in the making, employing local firms and creating demand for skills in installation, maintenance and digital services.
robust and socially acceptable. Opportunities across both tracks
The gap between Portugal’s 2030 targets and its cur- rent installed base represents, in commercial terms, a
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