The EU AI Act in Portugal: What Online Shops Must Disclose

The EU AI Act — Regulation (EU) 2024/1689 — is the European Union’s landmark law on artificial intelligence. As an EU regulation, it applies directly in Portugal without a separate Portuguese transposing law. Any Portuguese online shop that uses AI tools is covered by the same core rules as shops elsewhere in the Union.

This guide sets out what the AI Act means in practice for Portuguese e-commerce, which duties are most likely to affect a typical shop, and how the Act is being enforced in Portugal.

A directly applicable EU law

The AI Act is being phased in over time. Prohibited practices have been banned since 2 February 2025. Rules for general-purpose AI models applied from 2 August 2025. The bulk of the obligations for high-risk AI systems apply from 2 August 2026. The transparency duties relevant to shops form part of this same phased rollout.

Because the regulation applies directly, Portuguese shops do not need to wait for a national statute. What each Member State does instead is designate the national authorities responsible for supervising and enforcing the rules. Across the EU — including Portugal — that designation is still being finalised during 2025 and 2026.

Are you a provider or a deployer?

The Act separates providers, who develop and place AI systems on the market, from deployers, who use them. Nearly all online shops are deployers. If you use a bought-in chatbot, a third-party recommendation engine, or a commercial AI image tool, you are a deployer, and your obligations are correspondingly lighter than those of a provider.

For the vast majority of Portuguese shops, the practical obligations come from Article 50 on transparency.

Article 50 transparency duties

Article 50 requires that people know when they are dealing with AI. For a Portuguese shop, the main points are:

• Chatbots: customers must be able to tell they are interacting with an AI system, unless it is already obvious.
• AI-generated images, audio and video: this content must be marked as artificially generated or manipulated in a machine-readable form.
• Deep fakes: content resembling real people, places or events must be disclosed as artificially generated.
• Certain public-interest AI-generated text, a narrower case that seldom applies to ordinary product descriptions.

In everyday terms, the two triggers a Portuguese shop is most likely to meet are an AI chatbot and AI-generated marketing visuals.

Disclosures in Portuguese

Disclosures under the AI Act must be clear and understandable to the people who receive them. In Portugal, where consumers are addressed in Portuguese, AI notices should normally be written in Portuguese so that shoppers genuinely understand them. A brief statement that a visitor is speaking with an automated assistant, in plain Portuguese, is the kind of clear disclosure the Act expects.

This complements Portugal’s existing consumer-information practice, where information is routinely given to customers in Portuguese.

Enforcement in Portugal

At Union level, the European Commission’s AI Office coordinates oversight of general-purpose AI and supports consistent application. At national level, each Member State designates its own competent authorities, including a market surveillance authority responsible for supervising AI systems in use.

Portugal is designating and setting up its national AI authorities, a task that — as in much of the EU — is still being completed during 2025 and 2026. Because the substantive obligations come directly from the regulation, Portuguese shops should act on the transparency requirements now rather than waiting for the national framework to be fully in place.

Practical steps for Portuguese shops

• List the places where AI appears on your site, including chatbots and AI-generated media.
• Add a clear Portuguese-language notice wherever customers chat with an AI assistant.
• Label AI-generated or manipulated images and video so shoppers are not misled.
• Keep a short record of your AI tools and how each is disclosed.

This article is for general information and is educational, not legal advice.