Answers to the questions that arise most often, with the article cited alongside wherever the answer follows from a rule.
Questions and answers
When does the sixty-second period start running?
In Portugal, from the moment the caller selects the option for contact with a professional in the menu, not from the moment the call is connected. Where there is no menu, it runs from connection. The rule is in article 6(2) and (3) of Decree-Law 134/2009 of 2 June.
Article 6(2) and (3) of Decree-Law 134/2009
What does it take to demonstrate that we comply?
Evidence organised by obligation. Complying and being able to show that you comply are different things, and before an authority or a contracting party only the second one counts. The practice that solves it is easy to state and laborious to execute: for each applicable obligation, identify the document, record or measurement that demonstrates it, check whether it exists, produce what is missing, and name who keeps it current. That matrix, not good intentions, is what gets produced in an inspection.
Does our virtual assistant have to identify itself as a machine?
Yes. Article 50 of Regulation (EU) 2024/1689 requires that a person interacting with an AI system be informed of that fact, unless it is obvious to a reasonably well-informed person. The duty has applied since 2 August 2026, with a grace period to 2 December 2026 for systems already in operation.
Article 50 of Regulation (EU) 2024/1689
Our customer service is outsourced. Who is responsible?
The undertaking that offers the service to the consumer. Outsourcing distributes execution, not liability to the consumer, without prejudice to any allocation of liability agreed between the parties. Where personal data is processed, the outsourcing provider is generally a processor and a contract under article 28 of the General Data Protection Regulation is required.
Article 28 of Regulation (EU) 2016/679
How many regimes apply to a contact centre?
Six, and they do not cross-refer. The national customer service regime, where one exists; the rules on the cost of consumer contact lines; consumer law as it applies to service and to distance contracting; data protection, as regards recording, logging and unsolicited communications; accessibility of support services; and transparency of automated interaction systems. Each layer has its own instrument, its own timetable and its own authority, and none of them refers to the others.
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