Public Administration digital projects now require prior authorization

On 13 April, the Government published Decree-Law No. 85/2026, creating the State Simplification and Technologies Network and introducing a new prior authorisation regime for certain digital projects and investments within the public administration.  

This measure is part of the government's broader strategy to simplify and digitise the state. The new regime aims to strengthen coordination of technology-related decisions within the public sector, promote closer alignment with the national digital strategy, prevent the duplication of systems and ensure the more efficient use of public resources.  

What is changing?  

The decree-law establishes the State Simplification and Technology Network, which will monitor the technological transformation of the public administration. In practical terms, public bodies will now require approval before proceeding with digital projects covered by the new regime.  

Which entities are covered?  

The regime applies to entities within the direct and indirect Public Administration, including public companies.  

However, it does not apply to public companies whose main activity is producing goods or providing services in competitive markets, including those operating in the financial sector. 

Which projects require prior authorisation?  

According to Article 6 of the decree-law, prior authorisation is now required for the following:  

1. a) Six-monthly or annual investment plans in information technology; 
2. b) IT acquisition projects worth more than €2 million; 
3. c)Artificial intelligence projects developed by or for the benefit of public administration entities;  
4. d)Sovereign cloud projects; 
5. e)Projects included in the National Data Centre Plan; 
6. f) Measures to ensure interoperability between public administration services and, wherever possible, private entities.

How is prior authorisation requested?  

All requests must be submitted online via the e-avalia platform.  

The digital process involves three main stages:  

1) Confirmation that the project falls within the scope of the decree-law.   

2) Description of the project or investment, with the option to attach supporting documents.   

3) Providing information on strategic alignment.   

Authorisation must be requested before the project begins. Once submitted, the request cannot be changed, so entities should carefully check all information before sending it.  

The decree-law also allows prior authorisation to be waived in exceptional cases, but this is always subject to the express approval of the Government member responsible for state reform. 

What are the decision deadlines?  

 Once a request has been submitted, the Coordination Committee for the Digital Strategy has 10 working days to make a decision.  

•  The decision may take one of the following forms:  

•  Authorisation, with or without conditions; 

•  Rejection;  

•  Request for adjustments and resubmission;  

•  Requiring the project to be carried out jointly or in coordination with other bodies.  

  

The Committee's decisions only take effect once approved by the Government member responsible for state reform. This approval, whether express or tacit, must be given within the same 10-working-day deadline applicable to the decision. If no response is issued within this period, the committee's decision is deemed to have been approved.  

The outcome is communicated to the requesting entity via the e-avalia platform and electronic notification. The status of the request can also be tracked on the platform.  

Investment plans may remove the need for individual authorisations.  

Where an annual or six-monthly investment plan in information technology is approved unconditionally and expressly identifies each acquisition, including its scope, purpose, timeline and amount, the acquisitions included in that plan will not require separate authorisation.  

The Government aims to achieve greater coherence, transparency and efficiency in digital investments across the public administration with this new regime, strengthening cooperation between public bodies and promoting a more integrated digital transformation for the benefit of citizens and business.