AI Regulation Tracker / EU AI Act implementation

Portugal names 14 bodies to supervise AI fundamental rights, but its market-surveillance authority is still not in law

Portugal has published and notified its Article 77 list under the EU AI Act, with ANACOM taking a cross-cutting coordinating role. The Article 70 designation that actually carries enforcement powers is still an announcement rather than a legal act, weeks before 2 August 2026.

By Anthony Guerriero · Published July 27, 2026 · Last updated July 27, 2026 · Standard news article

Regulatory Briefing

Bindingness: Regulatory designation under a binding EU regulation. The Article 77 list is a published national designation. The Article 70 designation is not yet adopted in Portuguese law.
Scope: Portugal. Providers and deployers of AI systems, in particular high-risk systems under Annex III of the EU AI Act.
What changed: Portugal drew up, published and notified to the European Commission its list of authorities supervising fundamental-rights obligations, as Article 77(2) requires. ANACOM additionally assumes cross-cutting coordination of the designated national entities.
Current status: Article 77 list published. Article 70 market-surveillance and notifying authority designation announced but not legislated.
Key date: 2 August 2026, when the AI Act applies almost in full.
Primary source: ANACOM, list of entities supervising fundamental-rights protection under Article 77 of the AI Regulation

The list Portugal actually published

ANACOM's page sets out the position plainly. Regulation (EU) 2024/1689 entered into force on 1 August 2024, and its rules apply in stages, with the regulation applicable almost in its entirety only from 2 August 2026. Under Article 77, member states must draw up and make public a list of the authorities they designate to supervise compliance with Union law protecting fundamental rights, and notify that list to the Commission. Portugal has done this.

The point worth holding onto is what kind of designation this is. Article 77 authorities are rights regulators. They get the power to request and access documentation created or maintained under the AI Act when they need it to do their existing job. They are not the AI Act's enforcement arm.

Who supervises what

The 14 bodies cut across most of the Portuguese state. A US firm running an AI hiring tool in Lisbon is not dealing with a single AI regulator. It is potentially dealing with the labour inspectorate and the working-conditions authority. A health AI product touches the health regulator. A credit model touches the finance inspectorate.

The designation that is still missing

Article 70 is the one with teeth. It requires each member state to designate a market surveillance authority and a notifying authority, collectively the national competent authorities, and to name a single point of contact. Those authorities investigate, supervise and impose sanctions.

Portugal has not put that in law. In September 2025 the Secretary of State for Digitalisation announced that the national communications authority would act as market surveillance authority and single point of contact. An announcement is not a legal act. As of the Future of Life Institute's June 2026 tracker, Portugal sits at partial clarity, and the notifying authority has not been identified at all.

That gap has a practical edge. The market surveillance deadline was 2 August 2025. Portugal is a year past it.

What ANACOM's coordinating role means in practice

A ANACOM assume ainda o papel de articulação transversal das demais entidades nacionais designadas.ANACOM, Article 77 designation notice

Translated: ANACOM also takes on the role of cross-cutting coordination of the other designated national entities. That is a coordination function across rights regulators, and it is a reasonable signal about where Portugal intends enforcement to sit. It is not, by itself, the Article 70 designation. Reading it as one is the mistake to avoid.

How Portugal compares with member states that finished the job

Four member states already have a national AI law in force. Portugal is not among them.

Comparison
Member state	National AI law	Market surveillance authority	Status
Portugal	None adopted	Announced (Sept 2025), not legislated	Article 77 list published; Article 70 pending
Italy	Law No. 132/2025, in force 10 Oct 2025	Agenzia per la Cybersicurezza Nazionale (ACN)	First EU state to pass a national AI law
Denmark	Law No. 467, in force 2 Aug 2025	Danish Agency for Digital Government	Designated, coordinating model
Finland	Law 1377/2025, in force 1 Jan 2026	Decentralised; Traficom is single point of contact	Designated, sectoral model
Ireland	S.I. No. 366/2025 + Bill 2026 pending	15 existing bodies; AI Office of Ireland due 2 Aug 2026	Designated, centralising

What this does not establish

It does not create new obligations for providers or deployers. The obligations come from the AI Act itself. It does not name Portugal's market surveillance authority in law, it does not name a notifying authority, and it does not tell you which body will levy a penalty. Anyone citing this designation as proof that ANACOM is Portugal's AI regulator is reading more into it than the document supports.

Frequently asked questions

Is ANACOM Portugal's AI regulator?

Not in law yet. ANACOM is one of 14 bodies on Portugal's Article 77 fundamental-rights list and it takes a cross-cutting coordinating role among them. The government announced in September 2025 that ANACOM would be the Article 70 market surveillance authority and single point of contact, but that designation has not been adopted as a legal act.

What is the difference between Article 70 and Article 77 authorities?

Article 70 covers the national competent authorities, meaning the market surveillance authority and the notifying authority. They supervise, investigate and sanction under the AI Act. Article 77 covers authorities that already enforce EU fundamental-rights law and that gain a right to request AI Act documentation relevant to their existing mandate.

Does this change what my company has to do?

No. Obligations flow from the AI Act itself, not from the designation. What the designation changes is who you deal with, and in Portugal that answer is still partly unsettled on the enforcement side.

Was Portugal late?

Yes, on Article 70. Member states were required to designate market surveillance and notifying authorities by 2 August 2025. Portugal had not done so in law as of mid-2026.

Last verified: July 27, 2026