Following the entry into force of the new legal framework for electric mobility, enacted by Decree-Law no. 93/2025, of 14 August (“DL 93/2025”)—which we have previously addressed here —ERSE has approved, after a public consultation period, new regulations for the Electric Mobility sector, in line with the aforementioned legislation.

The primary purpose of this update is to simplify procedures and reduce overly burdensome obligations that could hinder the adaptation of stakeholders, as well as the evolution of electric mobility throughout the transitional period, which runs until the end of 2026.

I. New Electric Mobility Regulation

ERSE Regulation no. 7/2026 has been published, approving the new Electric Mobility Regulation (“EMR”), thereby repealing the previous Regulation no. 854/2019, of 4 November.

Transitional Regime

The revised EMR temporarily maintains, under a transitional arrangement, the operation of the previous model for charging points that remain integrated within the electric mobility network management platform, coexisting with points already operating outside of said integration.

Until 31 December 2026, the essential obligations set out in the previous regulation shall continue to apply to Charging Point Operators (“CPOs”) and Electricity Suppliers for Electric Mobility (“ESMEs”) that choose to operate under the transitional regime provided for in DL 93/2025.

New Electric Mobility Regulation

The EMR also features a new chapter applicable to the activities of CPOs and Electric Mobility Service Providers (“EMSPs”) under the new electric mobility regime, detailing transparency, reporting, and service quality obligations aligned with the new liberalized model.

Among the key obligations introduced, the following are particularly noteworthy:

  • Real-time price transparency: CPOs and EMSPs who do not operate exclusively with a kWh-based pricing model must provide, via an easily accessible digital platform, information allowing End Users (“UVE”) to monitor the cost of each charging session in real time, subject to a latency period of up to three minutes (six minutes in 2026 and five minutes in 2027), not including post-charging fees.
  • Public information by EMSPs: EMSPs must maintain on their website an up-to-date list of all charging points of CPOs with whom they have valid agreements.
  • Support services for End Users by CPOs: CPOs must ensure the availability of support services throughout the operation of charging points, guaranteeing telephone or equivalent service where no in-person service is available, without any prior registration requirement.
  • Evaluation and reporting of telephone support: CPOs must assess the performance of their telephone support, using the indicator of calls answered within ≤60 seconds as a proportion of the total, excluding dropped calls with ≤60 seconds wait time, and must submit quarterly reports of relevant data to ERSE.
  • Complaints and response times: Both CPOs and EMSPs must respond to all complaints within 15 business days and report quarterly to ERSE both the total number of complaints received and those for which the response time exceeded this limit.
  • Application of Network Access Tariffs (“NAT”): For facilities with internal delivery points, NAT shall apply in accordance with the Tariff Regulation, including specific rules for determining power and energy based on voltage level and consumption profile.
  • Compatibility of contracted power: For Low Voltage (“LV”) installations, the contracted power level may not be lower than that of the highest internal point or greater than that of the overall installation. For High Voltage (“HV”)/Medium Voltage (“MV”) installations, invoiced power shall be determined pursuant to the Tariff Regulation.
  • Regulated metering prices for internal points: ERSE shall approve annually the regulated prices for metering equipment for internal points. Distribution System Operators (“DSOs”) shall submit proposals by 15 September. Alternatively, current self-consumption prices may apply.
  • Disintegration from the EGME platform: CPOs may request full or partial disintegration of their points during the transitional period. Installation of internal metering points shall require the complete disintegration of those points. The Electric Mobility Network Management Entity (“EGME”) shall notify the DSO of the disintegration date within two business days.
  • Pilot projects: Pilot projects of up to three years’ duration, with regulatory exemptions, may be authorized upon a reasoned proposal and stakeholder consultation, with ERSE monitoring their results and ensuring public disclosure.
  • Adaptation for supply interruption: Existing installations must adapt within a maximum of 12 months to allow for supply interruption, preferably remote, by the DSO at internal points. Failure to adapt will result in loss of the internal point and possible disconnection, after due notice.

These requirements are without prejudice to the legal obligations applicable to CPOs and EMSPs pursuant to DL 93/2025.

The EMR enters into force on the day following its publication, with immediate effect, except for matters relating to non-exclusive electric mobility consumption facilities with internal delivery points, which come into effect six months after publication in the Official Gazette (Diário da República).

II. Amendments to the Self-Consumption, Service Quality, and Commercial Relations Regulations and to the Metering, Reading, and Data Availability Guide

ERSE has also approved Regulation no. 4/2025, which amends four instruments to align them with the new electric mobility regime established by DL 93/2025:

  • Self-Consumption Regulation for the Electricity Sector, approved by Regulation no. 815/2023, of 27 July: Now allows, on equal terms, the participation of delivery points corresponding to internal metering points of non-exclusive electric mobility installations in self-consumption schemes, with data collection determined by the Metering, Reading, and Data Availability Guide.
  • Metering, Reading, and Data Availability Guide for the Electricity Sector, approved by Regulation no. 987/2025, of 13 August: Recognizes free choice of supplier for charging points connected to non-exclusive installations and establishes the regime for internal metering points, including coexistence rules for self-consumption, data model for quarter-hour balances, creation of a virtual metering point by the network operator, allocation of balances to contracts, and treatment of injections. Internal points are now counted for access charge billing. No reactive energy is calculated for internal points. A transitional regime for previous integrations is provided, in accordance with DL 93/2025.
  • Service Quality Regulation for the Electricity and Gas Sectors, approved by Regulation no. 826/2023, of 28 July: Clarifies the definition of “delivery point,” excluding internal metering points at non-exclusive electric mobility installations, and clarifies the calculation of the continuity compensation limit based on the annual consumption of the public network connection point, without deducting internal consumption.
  • Commercial Relations Regulation for the Electricity and Gas Sectors, approved by Regulation no. 827/2023, of 28 July: Prohibits the establishment of internal delivery points in provisional or temporary installations, admitting them only in permanent, non-exclusive electric mobility installations.

This Regulation comes into force six months after its publication in the Official Gazette, which is currently pending.