Areas of Focus
With the aim of capitalizing on the international context favorable to investment in these data infrastructures, the Plan structures its actions around four main areas:
- Regulation and Governance
The Plan envisions strengthening AICEP (Portuguese Agency for Investment and Foreign Trade)’s role as the sole point of contact for investors, alongside the review and simplification of licensing processes, the monitoring of projects in the pipeline, and the standardization of evaluation criteria applied by the various competent authorities.
- Energy and Infrastructure
This involves identifying and qualifying pre-prepared zones that have already obtained prior licensing and have a scheduled connection to the power grid, alongside incorporating energy efficiency requirements and mapping existing value chains at the national level.
- Demand and Market
Covers the centralization of public needs regarding computing capacity, the definition of guidelines for government involvement in strategic initiatives, and the provision of a single information portal for investors.
- Territory and Ecosystem
Includes the design of benefit-sharing models with local communities, the promotion of academic and technological hubs, and the definition of territorial safeguard mechanisms applicable at the end of the infrastructure lifecycle.
Timeline and Coordination with Other Public Policies
Although the Plan’s timeframe spans the 2026–2027 biennium, most measures are expected to begin as early as 2026, with the majority launching in the first half of this year.
Several measures are aligned with the National Artificial Intelligence Agenda (ANIA), as well as with the sovereign cloud objectives set out in the Action Plan of the National Digital Strategy (EDN) for 2026–2027, particularly regarding the alignment between the supply of computing capacity and the needs of the public sector.
The central role of AICEP
The PNCD assigns AICEP a significant leading role in coordinating the actions of the various public entities involved. In this context, AICEP is tasked with reviewing licensing procedures and technical guidelines, promoting the establishment of maximum decision deadlines in licensing processes, and contributing to the reduction of disparities in evaluations by harmonizing criteria, methodologies, and requirements among the different licensing entities.
Private Sector Involvement
The involvement of private operators and sector-specific business associations is primarily reflected in measure “II.3 — Maximizing the economic impact on the value chain,” which aims to establish a network of qualified suppliers accessible to investors and developers. This measure seeks to mitigate implementation risks and ensure the necessary conditions for the effective launch of data centre deployment projects within the country.
Final considerations
The approval of the PNCD constitutes a significant milestone in positioning Portugal as a competitive destination for investment in critical digital infrastructure. The effective implementation of the planned measures—particularly regarding the development of the value chain, the identification of constraints, and the promotion of solutions that streamline project implementation—will be crucial for ensuring that the outlined objectives translate into tangible results.
Close monitoring of the Plan’s implementation by all sector stakeholders will, in this regard, be essential to ensuring efficient coordination among investors, operators, and public entities.
In this regard, VdA provides specialized legal support to all companies operating within the data centre value chain, covering interconnectivity, storage infrastructure, and data hosting services, as well as crucial areas such as energy, the environment, and sustainability. VdA accompanies the entire process, from investment planning to operational compliance, ensuring efficiency and adaptation to the specific needs of each project.
To learn more about our multidisciplinary team dedicated to the data centre sector, visit
