Portugal
Legislative basis for CCAM testing
Portugal regulates the testing of Automated Driving Systems (SAC) and connectivity systems under Decree-Law No. 113/2026, published on June 8, 2026. This legislation established a comprehensive legal framework to accelerate research, innovation, and the safe integration of technologies on Portuguese roads.
Licensing and Application Requirements
The licensing process ensures that any automated testing on public infrastructure undergoes rigorous inter-agency scrutiny. The procedure is fully digital, requiring high-security authentication and electronic signatures from applicants.
Competent Authority and Inter-Agency Approval: The procedure is managed digitally by the Institute for Mobility and Transport (IMT, I.P.). Final approval is granted via a deliberative conference involving the IMT, I.P., the National Road Safety Authority (ANSR), the National Republican Guard (GNR), the Public Security Police (PSP), and the national road administration (Infraestruturas de Portugal, I.P.).
Local Municipal Jurisdiction: If any part of the testing occurs on municipal roads, the issuance of the license is strictly subject to a prior binding opinion from the respective local municipality.
Geographical Scope of Application: Testing is permitted on all public roads (state, autonomous regions, or local authorities) and on private roads when open to public traffic.
Regulatory Documentation and Compliance: Applications must include detailed vehicle identification, operational scheduling, driver/operator certificates, an insurance declaration, and a mandatory declaration of self-certification regarding legal compliance.
Cross-Border License Recognition: The IMT, I.P. can formally recognize testing licenses issued by foreign states within 45 days, provided local road managers confirm that the intended segments and schedules are available.
Connectivity System Notification: Testing standalone connectivity systems, such as Vehicle-to-Vehicle (V2V), Vehicle-to-Infrastructure (V2I), or Vehicle-to-Everything (V2X), does not require a full license. It requires only a prior technical communication to the IMT, I.P. and local police forces at least 15 days before operations begin.
Driver and Operator Requirements
The regulation distinguishes between different roles depending on the level of system automation and establishes strict guidelines to manage human fatigue and cognitive alertness.
Role Classification (Drivers vs. Operators): A Driver exercises real-time dynamic control over conditional automation systems, while an Operator exercises strategic control over high or full automation systems.
Background and Record Verification: Personnel must have held a valid license for the relevant vehicle category for at least six years and have a completely clean driving history for the previous 5 years, with absolutely no record of traffic crimes or administrative contraventions.
Statutory Blood Alcohol Restrictions: The blood alcohol concentration (BAC) thresholds are reduced to 0.2 g/l for drivers/operators on duty, and 0.5 g/l for supervisors.
Operational Shifts and Rest Periods: Personnel are legally banned from operating or supervising a test vehicle for more than 3 consecutive hours, and must be given a rest interval of at least 1 continuous hour between working periods.
Vehicle, Technical and Testing Conditions
Vehicles utilized in these trials must meet rigid telemetry standards and adhere to baseline operating principles where road safety acts as an absolute priority.
Telemetry Requirements: Data logging systems must record at a minimum frequency of 10 Hz, capturing system versions, georeferencing, multi-axis acceleration, steering/braking inputs, signalling status, network latency, and all V2X communications.
Safety Plan and Cybersecurity Protocols: The safety plan must explicitly address risks to vulnerable users, clear human-machine handovers, and specific cybersecurity measures taken to protect the vehicle’s automated driving system (ADS) against unauthorized third-party access.
Velocity Limitations: Speed limits are automatically slashed by 20 km/h for test vehicles, unless explicitly exempted within the license.
Prohibited Operations: The transport of any classified dangerous goods is strictly prohibited during tests, in accordance with Decree-Law No. 150/2015, of August 5.
Visual Identification Requirements: If deemed necessary by the risk analysis, test vehicles must carry distinct visual labelling identifying them as autonomous test vehicles.
Insurance and Liability
Due to the unproven nature of experimental driving systems, financial liability limits are heavily expanded to protect the public.
Mandatory Civil Liability Coverage: The operating entity must maintain a valid automotive civil liability insurance policy whose minimum insured capital is four times (4x) the standard minimum legal requirement enforced for regular vehicles in Portugal.
Contractual Continuity: The license holder is legally obligated to ensure the contract remains active and uninterrupted for the entire duration of the trial period.
Reporting and Incident Management
The decree establishes transparent reporting hierarchies for both normal testing evaluations and unexpected safety failures.
Emergency Accident Protocol: If an accident or a serious incident occurs, the vehicle must stop immediately, and the crew must summon law enforcement to the scene.
Technical Incident Reporting Deadlines: Following an accident or serious incident, the operating entity has a strict 24-hour deadline to submit a comprehensive technical telemetry report to the IMT, I.P. and the road manager.
Routine Operational Reporting: Compilation reports outlining any disengagements, unscheduled human interventions, or public complaints must be filed within 10 days of trial completion or monthly. Recorded data serves as primary evidence in infraction proceedings.
Penalties and Enforcement
Enforcement powers granted under this decree combine immediate operational halts with significant financial and asset forfeitures for non-compliance.
Provisional Administrative Suspension: Traffic enforcement authorities can provisionally suspend a testing license on the spot if an accident/serious incident occurs, if safety conditions are compromised, or if the crew fails to present a copy of the testing license.
Statutory Financial Fines: Regular infractions carry fines ranging from €150 to €3,000 for individuals, and from €2,000 up to €40,000 for corporate entities depending on the exact infraction.
Asset Seizure and Permanent Forfeiture: Operating an automated test deployment without an authorized license or driving a test vehicle while a license is suspended, results in the immediate physical seizure of the vehicle and its permanent loss to the State.