Roughly half of the Portuguese obligations can be verified from outside the operation, by anyone with a telephone. Those are the ones an inspection reaches first, and they are therefore the ones to check first.
In order
- Time to a human operator, counted correctlyMeasured from the menu selection where a menu exists. Sample across different times and days; report the distribution, not the average, because the obligation is not written as an average.
- Menu structureNo more than five initial options, one of which must be contact with a professional, reachable without traversing submenus.
- Opening announcementCost of the call, recording notice with its lawful basis, and — since 2 August 2026 — disclosure where an AI system is interacting with the caller.
- Line costThe consumer contact line may not cost more than the basic rate, and premium-rate numbers are prohibited for this purpose. In force since 1 November 2021, with penalties applicable since 1 June 2022.
- Retention period and its justificationNot externally observable, but the first thing a data protection authority asks about. Written reasoning is the deliverable here, not the number.
The amounts set out in the 2009 text were repealed. Article 10 was amended by Decree-Law 9/2021 and now classifies non-compliance as a serious economic administrative offence, punishable under the Economic Administrative Offences Regime with bands that vary by the size of the undertaking. Any internal documentation still citing the 2009 figures has been out of date for more than five years — and that fact is itself an indicator of how regulatory monitoring is being done.
Apply this to your operation
A general framework is no substitute for a concrete assessment. The diagnostic determines what applies to your operation.