In the past few weeks, something unprecedented has happened in people management in Portugal. On 14 May 2026, the Council of Ministers approved a proposal to revise the Labour Code — the most comprehensive HR labour reform Portugal 2026 in over a decade. Simultaneously, fewer than 20 days remain before the transposition deadline for the European Pay Transparency Directive. And before the end of the year, the AI Act obligations for HR systems and the transposition deadline for the Platform Workers Directive will both come into force.
Four regulatory transformations in a single semester. No organisation can ignore them. The question is no longer whether they will be affected — it is whether they are prepared to manage this convergence without paralysing operations.
1. Labour Code Reform: What Changes from 2026
The proposal approved by the Council of Ministers on 14 May now moves to the Assembly of the Republic. Even without a confirmed vote date, organisations should start preparing for the most significant changes.
Fixed-term contracts increase from 2 to 3 years maximum duration. Indefinite-term contracts extend from 4 to 5 years. For HR departments, this means reviewing all hiring policies, automatic renewal alerts, and contract expiry tracking in personnel management systems.
The individual time bank returns, through direct agreement between employer and worker — without the need for collective bargaining. A change that requires new mechanisms for recording, monitoring, and compensating hours in attendance systems.
Outsourcing limitations are fully revoked, regardless of previous collective dismissals. Organisations with externalised operations must review contracts and ensure compliance with the new rules.
Parental leave is strengthened, with 28 mandatory days. Absence management systems need to be updated to reflect this new minimum.
The 4-day week enters an expanded experimental regime, with corporate tax incentives for organisations that adopt it without salary reduction. A concrete fiscal incentive that many organisations will want to evaluate — and one that requires shift modelling and operational impact assessment before any decision.
AI regulation in the workplace is included for the first time in Portuguese labour legislation. Although the details depend on the final version approved by Parliament, the signal is clear: the use of artificial intelligence in decisions about people will have a specific legal framework.
2. Pay Transparency: 19 Days to the European Deadline
The transposition deadline for Directive (EU) 2023/970 is 7 June 2026. Portugal published a preliminary draft law on 30 March, but the definitive legislation has not yet been approved. Regardless of the national legislative timetable, the directive’s obligations are clear and organisations with European operations must prepare now.
Organisations with 100 or more employees will be required to report gender pay gaps. Job advertisements must indicate the salary range — or communicate it before the first interview. Asking candidates about their current salary is prohibited. If the gender pay gap is 5% or more without objective justification, the organisation is obliged to conduct a joint assessment with employee representatives and implement corrections.
2025 data shows that fewer than 30% of job advertisements in Portugal included salary references, and only 26% of organisations disclosed salary tables internally. The gap to bridge is enormous — and the deadline is extremely tight.
An HR platform like UnikPeople, with centralised management of professional categories, salary tables, gap analysis, and an employee portal with access to remuneration information, becomes an essential tool for meeting these obligations without multiplying spreadsheets or exposing the organisation to non-compliance risks.
3. Platform Workers Directive: December 2026
Directive (EU) 2024/2831 must be transposed by 2 December 2026. Although it appears to target companies like Uber or Glovo, its scope is considerably broader and affects any organisation that uses digital platforms to manage work.
The directive creates a presumption of employment relationship between the worker and the platform, shifting the burden of proof to the organisation. It prohibits the automated processing of biometric data or emotional states of workers. And it requires disclosure of all automated monitoring systems in use.
In the European Union, an estimated 28 million workers — potentially 43 million — are covered. Portugal already has some legal basis through the presumption of employment introduced by the Decent Work Agenda, but the new obligations on algorithmic transparency and data protection will require adaptations in people management processes and systems.
4. AI Act: HR Systems Classified as High Risk
The European Artificial Intelligence Regulation classifies AI systems used in HR as high risk (Annex III, Category 4). This covers automated recruitment, CV screening by AI, algorithm-based performance evaluation, employee monitoring, and decisions about promotions or contract termination.
General obligations for high-risk systems come into force on 2 August 2026. The specific deadline for HR systems was extended to December 2027 by the Digital Omnibus package, but this does not mean preparation can be postponed.
Organisations that use — or plan to use — AI in people processes must conduct documented risk assessments, ensure meaningful human oversight, implement bias testing, and mandatorily consult employee representative bodies before activating high-risk AI systems.
In a 2025 Gartner study of 360 organisations, those that implemented AI governance platforms were 3.4 times more likely to achieve high effectiveness in their compliance programmes. Governance is not bureaucracy — it is competitive advantage.
5. SIADAP and the Public Sector: New Evaluation Cycle
For public sector organisations, 2026 brings the SIADAP reform, promulgated by the President of the Republic on 6 January. The deadline for reviewing adapted evaluation systems was extended to 30 June 2026, and participatory proposals for the new model are scheduled for the second half of the year.
The reform promises a simpler and less bureaucratic system, with greater autonomy for evaluators, merit awards focused on results, and greater weight given to performance as a progression criterion. For universities, municipalities, and public institutes, updating performance evaluation systems is an immediate priority — and an opportunity to digitalise processes that in many cases still depend on paper and spreadsheets.
The SIADAP module of UnikPeople allows configuration of evaluation cycles, objectives, competencies, and quotas in accordance with the current legal framework, ensuring automatic compliance and eliminating the administrative complexity that consumes HR teams’ time in Public Administration.
Bonus: HR Compliance Checklist — H2 2026
By 7 June 2026
- Audit salary structure by gender and role
- Include salary range in all active job advertisements
- Remove questions about current salary from recruitment processes
- Prepare first gender pay gap report (organisations with 100+ employees)
By 2 August 2026
- Inventory all AI systems used in HR processes
- Classify each system according to AI Act risk level
- Document risk assessments and human oversight mechanisms
By 30 June 2026 (Public Sector)
- Review performance evaluation system adapted to the new SIADAP
- Prepare transition to the new model in H2
By 2 December 2026
- Review use of digital platforms for work management
- Assess exposure to the presumption of employment relationship
- Document automated monitoring systems and ensure transparency
Before end of 2026
- Update hiring policies to reflect the new Labour Code
- Review time banking, outsourcing, and parental leave
- Evaluate feasibility of the 4-day week with fiscal incentive
Sources: Council of Ministers (14 May 2026), Directive (EU) 2023/970, Directive (EU) 2024/2831, Regulation (EU) 2024/1689 (AI Act), OECD Economic Surveys Portugal 2026, Gartner (2025), EY Portugal, L&E Global, CMS Portugal.
About the author: Eva Winter is HR Director and Co-Founder of Uniksystem, a European enterprise platform company specialising in people management, process automation, and digital transformation for regulated industries. Uniksystem holds ISO/IEC 27001 certification across the entire JOYN Group.
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