Social Security Contribution Regime Code and respective Regulations.
Two pieces of legislation were published on 9 December 2025 - Decree-Law No. 127/2025 and Regulatory Decree No. 7/2025 - introducing significant changes to the Social Security Contribution Regime Code and its respective regulations, in the context of the Social Security digital transformation programme.
The changes are essentially aimed at:
(i) Simplify and digitise communications from employers;
(ii) Strengthen the interoperability of systems;
(iii) Reducing administrative costs; and
(iv) Preventing fraud and tax evasion.
Both the aforementioned Decree-Law and the Regulatory Decree will come into force on 1 January 2026, with a transitional period during 2026 for all employers to adhere to the new model, which will become mandatory from 1 January 2027.
What are the main changes to the Social Security Contribution Regime Code?
The changes provided for in Decree-Law No. 127/2025 are part of the digital transformation of the system, promoting the interoperability of information systems and reducing manual intervention by employers, in line with the "once only" principle.
We highlight the following:
The notification of the admission of workers (regardless of the type of employment relationship) must now be made through the Social Security Direct service, and must be done before the start of the employment contract (instead of within 15 days prior to the start of the employment contract), maintaining the exception already provided for in the current regime.
If this obligation is not fulfilled, it is assumed that the employee started work on the first day of the third month prior to the verification of non-compliance, a presumption that can be rebutted by evidence to the contrary.
It is now mandatory to notify social security of changes to the amount of permanent remuneration.
Contributions and dues will now be paid monthly, based on data provided by Social Security between the 1st and 25th of the month following the month to which they relate.
An official supply mechanism has also been created, allowing Social Security to automatically supply or correct missing or insufficient remuneration communications, using the data at its disposal. This supply is notified to the employer and may be made within the legally established period.
In terms of penalties, failure to declare remuneration for employees constitutes a very serious offence. On the other hand, violation of the duty to declare or correct the identified elements, when it results in differences in the amounts due to the employee, may be considered a minor offence, provided that it is regularised within 60 days of the deadline, or a serious offence in other situations.
And what changes in relation to the Regulation of the Social Security Contribution Regime Code?
Regulatory Decree No. 7/2025 aims to adapt the contribution regime to the digital transformation of Social Security, promoting simplification, efficiency and fairness in the relationship between employers, employees and Social Security. In this regard, we highlight the following:
Communications from employers to social security regarding the termination and suspension of employment contracts, as well as changes to the type of employment contract and changes to the amount of permanent remuneration, will now be made through the Social Security Direct service or through the Interoperability Services Platform, gradually eliminating the use of paper forms and other traditional means.
Employers' declarations necessary for determining the contribution rate applicable to employees and for calculating remuneration and contributions due are made through the Interoperability Services Platform.
For companies with fewer than 10 employees, communications and declarations to Social Security will continue to be made via the Direct Social Security service.
Several articles of the Regulation are repealed or amended in order to simplify procedures and eliminate redundancies.
For further information on Decree-Law No. 127/2025 of 9 December and Regulatory Decree No. 7/2025, please click here (insert links).
