The Complete Guide to Using AI in the Retail Industry in Portugal in 2025

Portugal's retail landscape in 2025 sits at the intersection of fast-moving AI opportunity and a strict European rulebook: the EU's Artificial Intelligence Act (AIA) now applies alongside GDPR and active supervision by CNPD, while national initiatives like AI Portugal 2030 push public‑private innovation - so retailers can deploy customer‑facing bots, dynamic pricing and hyper‑personalisation but must tame data quality, IP and bias risks first; practical advice from market reports urges starting with focused micro‑experiments to turn pilots into ROI and to prepare for third‑party conformity checks for high‑risk systems.

For a compact legal primer, see the Portugal practice guide on AI, and for concrete retail use cases and implementation notes, read Publicis Sapient's review of the top generative AI retail opportunities in 2025 - think chat assistants that can take a shopper from discovery to checkout and rigorous data foundations that make that possible.

“If retailers aren't doing micro-experiments with generative AI, they will be left behind.” - Rakesh Ravuri, CTO at Publicis Sapient

AI Portugal 2030 sits at the heart of Portugal's push to turn digital skills and research into real retail advantage: promoted under the INCoDe.2030 umbrella, the strategy is designed to mobilise citizens, industry and public bodies to build a “living laboratory” for AI - focusing on skills, specialised research, modernising public administration and niche service export opportunities - so Portuguese retailers can pilot advanced NLP, real‑time edge apps and data‑driven customer journeys in a regulated, innovation‑friendly environment.

Coordinated by INCoDe.2030 with FCT, ANI, Ciência Viva and AMA, the plan's seven pillars (inclusion and education, qualification, research & innovation, public admin, specialisation, knowledge advancement and public service improvements) provide a clear roadmap for workforce reskilling and industry collaboration; the national programme even signals large-scale research funding to follow.

For a concise policy overview, see the OECD summary of the AI Portugal 2030 strategy and the INCoDe.2030 forum report that highlights retail use‑cases and funding signals for research and innovation.

“The next funding program will have 95.5 billion euros for research and innovation.” - Sofia Azevedo, National Innovation Agency

The AI industry outlook for 2025 in Portugal is cautiously upbeat: robust digital infrastructure - “almost full” 5G and gigabit coverage - and a national roadmap made up of 157 measures backed by EUR 2.15 billion set the stage for faster adoption, but the take‑up of advanced technologies by enterprises (AI included) remains modest, so progress will hinge on closing that gap; Portugal had an estimated 27 edge nodes and one unicorn in 2024, a vivid reminder that pockets of advanced capability exist even as many firms lag.

Large-scale public funding (notably EUR 4.5 billion from Recovery & Resilience and EUR 2.4 billion from Cohesion funds) combined with expanding EU research programmes - see the Horizon Europe 2028–2034 proposal - should create pathways for retailers to move pilots into production, provided they pursue the recommended public‑private‑academic collaboration and focused reskilling to translate connectivity into commercial AI value.

For a concise policy snapshot, consult the Portugal 2025 Country Report and the Horizon Europe programme overview to map funding and partnership opportunities for retail AI deployments.

“You spoke, we listened. As one of Europe's strongest brands, Horizon Europe will place research and innovation at the heart of the EU economy and investment strategy. We will attract and retain talents through ‘Choose Europe', de-risk and mobilise private research and innovation financing, empowering innovative startups and work together with Member States to reach the 3% investment target.” - Ekaterina Zaharieva, Commissioner for Startups, Research and Innovation

Portugal's regulatory picture for retail AI is dominated by the EU's risk‑based Artificial Intelligence Act alongside existing GDPR duties, so retailers must treat compliance as an operational program not a checklist: the Act entered into force on 1 August 2024, with prohibitions (for example bans on subliminal manipulation, social scoring, untargeted biometric scraping and emotion‑recognition in workplaces) and an “AI literacy” duty kicking in on 2 February 2025, while governance rules for general‑purpose AI and notifier/authority obligations came into effect from 2 August 2025 and full application for many high‑risk systems follows through 2026–2027.

That phased timetable means practical steps now - risk‑classify systems, embed AI‑literacy training for staff who operate recommender engines or chat assistants, document datasets and post‑market monitoring - will reduce legal and commercial risk; retailers should also watch national guidance (Portugal's AMA published an ethical risk evaluation tool in mid‑2025) and the EU templates and GPAI code that clarify transparency and training‑data summaries.

In short: translate the Act's dates into a product‑level roadmap (design, pre‑market checks, transparency notices and ongoing monitoring) so that promising uses like personalised pricing or in‑store assistants scale without tripping the bans or GDPR obligations - because a single misapplied emotion‑detection or biometric scraping feature can turn a competitive edge into a regulatory headline overnight.

EU AI Act timeline and legislative milestones and Portugal AMA implementation notes and guidance for practical next steps.

Portugal's governance picture for AI is now a multi‑headed but coordinated system: ANACOM was appointed to act as the national coordinator (the Digital Services Coordinator) and has publicly notified a slate of sectoral supervisors under the EU AI Act, so retailers should expect cross‑agency scrutiny rather than a single point of contact - see ANACOM's competent‑authority listing for details.

National bodies such as the CNPD (data protection), health and safety regulators, labour inspectors and market authorities all play designated roles, and ANACOM even pulled together a 32‑body working group to map enforcement and capacity needs - a vivid reminder that AI supervision in Portugal blends telecoms-style coordination with sectoral watchdog muscle.

Enforcement will follow the EU rulebook (including the AIA's administrative penalties) and national practice relies heavily on EU standards and guidance, so companies in retail must plan for third‑party checks, multi‑agency inquiries and detailed documentation; for a legal roadmap consult the Chambers Portugal AI practice guide and the IAPP's regulatory directory for a practical view of who does what and when.

Portuguese retailers are already turning AI into practical store‑floor and back‑office advantages: MC (Sonae) is experimenting with a record‑breaking autonomous store in Leiria - a real‑world lab with 1,676 cameras, 10,000 SKUs and seamless, real‑time basket checkout that blends assisted counters with democratic entry (Sensei and MC Sonae Leiria autonomous supermarket case study); Continente uses machine learning to deliver personalised weekly brochures to over one million users of the Continente Card, surfacing the right promotions for each household (Continente personalized weekly promotions case study).

Behind the scenes, a scalable API and cloud strategy powers loyalty, omnichannel fulfilment and partner integrations - MC has built hundreds of API proxies and handles billions of calls a year to stitch together stores, apps and delivery partners (MC (Sonae) API and cloud strategy case study).

These examples show practical use cases - autonomous checkout, hyper‑personalised promotions, realtime inventory and partner orchestration - where measurable tech (cameras, APIs, loyalty signals) meets customer experience, turning experimental pilots into production tools that cut friction and keep shelves stocked in real time.

“Artificial Intelligence is solving the problems of our operation and our management. The Continente card adopted a process of innovation and enabled the leverage of a communication strategy, organization of products, ranges and stores, based on Customer Behavior…” - Liliana Bernardino, Head of Customer Intelligence, SONA E MC

Data, IP and model governance are now practical risk‑controls for Portuguese retailers: GDPR and the EU AI Act impose clear duties (including data‑governance, quality checks and bias mitigation for high‑risk systems by August 2026), so teams should treat training datasets and model behaviour as core product features rather than hidden R&D. Start by preferring lawfully acquired or licensed corpora, de‑identifying personal data early, keeping deletion/“blacklist” processes and DPIAs in place, and testing models for unintended memorisation or verbatim output; technical safeguards like synthetic data or machine‑unlearning and contractual data‑supplier clauses reduce exposure.

The U.S. litigation trend shows training can sometimes be deemed “transformative,” but piracy or models that can verbatim reproduce inputs remain a major hazard (the Anthropic disputes alleged millions of pirated copies in a central library).

For practical legal and technical guidance on scraping, personal‑data limits and the AI Act's data‑governance duties see the Taylor Wessing briefing on scraping and processing AI training data and the IP Alert summarising the recent U.S. fair‑use rulings for AI developers.

Both the order in Anthropic and the order in Meta generally suggest that the training of machine learning models using legally-acquired copyrighted works is, standing alone, transformative and thus highly likely to be found fair use.

Portugal's labour rules are reshaping how retailers deploy AI at work: telework now requires written agreements, expense compensation and limits on intrusive remote monitoring (including a 24‑hour notice rule for remote meetings), while digital‑platform indicators such as algorithmic direction or real‑time supervision can trigger a presumption of employment - so any store using algorithmic shift allocation or performance scoring should expect employment‑law scrutiny and stronger worker protections (see the Eversheds‑Sutherland briefing on the 2023 Labour Code changes).

Employers must also be transparent about monitoring tools and algorithmic decisions in worker information packets, consult employee representatives for major monitoring rollouts, and respect strict privacy limits (CCTV may be used for security but not repurposed as covert performance surveillance and often requires consent) - details and practical guidance on monitoring risks are usefully summarised in Eurofound's review.

Add to that Portugal's whistleblower channels and GDPR duties: retailers should treat model‑driven rostering, productivity metrics and camera feeds as HR and legal products, not just IT projects, build clear consultation and notification steps into deployments, and budget modest monthly telework reimbursements and formal notices into pilot plans; a vivid operational rule to remember is this: a camera installed to protect goods cannot quietly become a performance‑tracking badge without breaching employee rights.

Eversheds Sutherland briefing: Updates to the Portuguese Labour Code (Agenda for Dignified Work)
Eurofound report on employee monitoring and privacy risks in Europe
CXC Global guide: Employee protections and employment law in Portugal

Portugal retailers buying or building AI should treat procurement as risk management: start by inventorying and risk‑classifying systems, require vendors to warrant AI Act and GDPR conformity, and bake in indemnities, ongoing‑compliance covenants and termination rights for unresolved non‑compliance - practical contract language and clause examples are usefully highlighted in procurement guidance such as WNS's checklist for the EU AI Act.

Insist on logging, documentation, DPIAs and post‑market monitoring from providers (these are core AIA obligations), require access or audit rights to training‑data provenance and model change logs, and plan for Product Liability Directive transposition and tougher consumer claims that make traceability essential.

Consider targeted insurance (product/professional indemnity and cyber cover) now: Portugal firms are advised to hedge against regulatory penalties and third‑party claims while EU rules and national transpositions evolve.

Finally, run a vendor gap analysis and a measurable remediation plan (register systems, assign roles, train staff, update T&Cs) so a single misclassification or undisclosed biometric feature doesn't turn a competitive pilot into a multimillion‑euro headline - see the Portugal AI practice guide for legal and fine‑level detail and Skadden's AIA preparation notes for practical next steps.

By 2030 Portugal's retail sector is likely to look very different: a Copenhagen Economics‑backed study forecasts data centres could add about €26 billion to GDP and support up to 50,000 jobs as roughly 70% of computing capacity shifts to AI workloads, a demand surge that underpins everything from faster recommendation engines to real‑time inventory orchestration; at the same time the Portugal e‑commerce market is projected to nearly double from USD 6.45B in 2025 to USD 11.03B by 2030 (an ~11.3% CAGR), signalling clear commercial upside for retailers that pair modern, low‑latency infrastructure with disciplined data and compliance practices.

The practical takeaway for Portuguese retailers: secure resilient, sustainable compute and connectivity, treat data governance and model monitoring as product features, and invest in people - reskilling in prompt design, AI literacy and operational AI will be the difference between pilots and scalable value.

For a concise look at the infrastructure case see the Copenhagen Economics write‑up on Portugal's data‑centre opportunity and the Portugal e‑commerce market forecast, and retailers ready to build workplace AI skills can start with targeted programmes like the AI Essentials for Work bootcamp to turn strategy into measurable outcomes.