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PORTUGAL Law and Practice Contributed by: Jorge Silva Martins, João Carminho and Inês Coré, CS’Associados

is responsible, together with information related to the qualified trust services provided by them. This information is published in so-called trusted lists, and Commission Implementing Decision (EU) 2015/1505 defines the technical specifica - tions of these lists. The trusted list of Portugal comprises informa - tion concerning qualified trust service providers who are under the supervision of the National Security Cabinet of Portugal. This list also includes details regarding the qualified trusted services offered by these providers, in accord - ance with the relevant provisions outlined in the eIDAS Regulation. The trusted list of Portugal includes the following currently active trust service providers: • ACIN iCloud Solutions, Lda; • AMA – Agência para a Modernização Admin- istrativa , I.P.; • CEGER – Centro de Gestão da Rede Informática do Governo ; • DigitalSign – Certificadora Digital ; • Instituto dos Registos e do Notariado I.P. • MULTICERT – Serviços de Certificação Eletrónica S.A. ; and • NOS Comuncações, S.A. The Portugal Digital Identity System Portugal embarked on the development of its digital identity system in 2007, positioning itself as a pioneering nation in aggregating into a single card five different identification numbers and implementing digital certificates with its eID “Citizen Card”. Since then, the Portuguese gov - ernment has consistently invested in enhancing its eID scheme, introducing various secure and easy-to-use mechanisms.

In 2014, Portugal introduced the “Digital Mobile Key”, a mobile solution that expanded its usage into the private sector. Subsequently, the eID schemes were broadened to include profession - al attributes (with the introduction of “SCAP”, 2018). More recently, in 2019, Portugal launched the ID.gov app, a mobile application enabling citizens to securely store, access and share their personal document data at any time, with full legal validity.

9. Gaming Industry 9.1 Regulations Regulations and Codes of Conduct

The gaming industry in Portugal is governed by a combination of general laws and sector-specific regulations, particularly where gaming intersects with gambling. The key legislative instruments include: • The Gambling Law (Decree-Law No 66/2015): regulates online gambling activities, including games of chance, and establishes licensing requirements, taxation rules, and consumer protection measures; • Consumer Protection Law (Law No 24/96): covers consumer rights, including transpar - ency, advertising, and product liability, which may apply to digital gaming; and • The GDPR and its National Implementation Regime: govern the collection, processing, and storage of player data by game develop - ers and platforms. While Portugal does not have a gaming-specific code of conduct, broader EU initiatives, such as the Pan-European Game Information (PEGI) system, apply to age ratings and content clas - sification.

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