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Portugal ePrivacy + CNPD Sender Rules (Lei 41/2004)

Portugal (PT) is an enabled Orbit destination for voice and SMS, dialing prefix 351. Portuguese marketing traffic sits under Lei 41/2004 of 18 August, the national transposition of the ePrivacy Directive, which carries the opt-in rule for electronic direct marketing (with the existing-customer exception that Portuguese law conditions on the same product or service category), and on top of it the GDPR as applied by the CNPD (Comissão Nacional de Proteção de Dados, the national data protection authority). Telecom-side context sits with ANACOM. Portugal operates a national do-not-contact posture for covered telephone marketing that you scrub before voice campaigns alongside your own suppression ledger. This page expands the PT row of the country-requirements matrix so you can assemble the posture before your first Portuguese send. Portugal is a tenant-owned burden. Orbit keeps the country-rules reference and the send-time surfaces; the legal posture for your Portuguese recipients is yours.
This page is documentation, not legal advice. Lei 41/2004’s direct-marketing provisions and the CNPD’s GDPR enforcement are applied against the sender, and the CNPD publishes guidance that moves over time. Have counsel review your consent and scrub practice for Portuguese recipients; Orbit supplies the surfaces.

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Accepted sender types and registration level

Portugal operates no statutory alphanumeric sender-ID registry. Portuguese operators accept alphanumeric senders at the operator level, and the operative layer is carrier deliverability rather than law: an unregistered alphanumeric sender can be relabeled in transit, so register the sender identity where stable branding matters and treat that as posture, not statute. Expect the live PT country-rules row to read registration: none:
Registration levels change at the regulator and the operators; always read the live registration field rather than this snapshot. Where a row ever reads recommended or required, file the sender through Sender-ID Registration.

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Opt-in and opt-out posture

Electronic direct marketing to Portuguese individuals requires prior consent under Lei 41/2004; the narrow existing-customer exception applies only to the same category of products or services you sold to the recipient, and only while a clear opt-out rode the sale and rides every message after it. Record consent before dispatch and honor revocations on every channel. For voice campaigns, scrub the national do-not-contact list before the campaign alongside your own suppression ledger.

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Quiet hours

Portugal sets no statutory marketing quiet-hours window for SMS; the recipient’s consent and your own sending policy carry the clock. Orbit’s tenant quiet-hours channel toggles default OFF, per Quiet Hours FAQ; for Portuguese campaigns, opt in a recipient-local window over Europe/Lisbon and apply an evening cutoff consistent with your consent basis. The toggle is tenant-owned and fails open until you set it, matching the platform posture that every compliance control except the US federal voice window is yours to configure.

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Number purchase

Portugal is not a member of the platform’s regulated phone_number_purchase set (DE, GB, FR, BR, MX, IN, JP, FI, NL, SE), so a Portuguese number order does not wait on an approved compliance profile. The marketing posture above still applies to the traffic you originate from the number: the purchase gate and the sending posture are separate obligations, and the lighter purchase path does not soften the opt-in rule. The same holds under the voice country-coverage reference, where PT reads enabled ahead of the call.

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Worked configuration before your first Portuguese send

1

Record consent with an sms scope

Capture prior consent for each Portuguese recipient in Consent Management before the first send; store the source and timestamp so the record is producible. If you rely on the existing-customer exception, scope it to the same product category as the original sale.
2

Add the Portuguese stop vocabulary

Confirm STOP is active and add PARAR as a Portuguese alias in the opt-out rules editor so Portuguese-language replies suppress immediately.
3

Scrub the national list for voice

Before any Portuguese voice campaign, run the DNC Scrub against the do-not-contact list and keep the suppression ledger current for every channel.
4

Set the quiet-hours window

Opt in the tenant quiet-hours toggle for the SMS and voice channels and set a Europe/Lisbon evening window per Quiet Hours FAQ.
5

Read the live row and send

Re-read GET /api/v1/compliance/country-rules?country=PT for the current registration and sender_types values, then send. A revocation received on any channel lands in the suppression ledger and blocks the next send to that recipient.