How many hours of training must employers provide under Portugal's Labor Code?

Every worker is entitled to a minimum of 40 hours of continuous training per year. Article 131(2) of the Labor Code states that the worker is entitled, each year, to "um número mínimo de quarenta horas de formação contínua" or, for a fixed-term contract of three months or more, a minimum number of hours proportional to the contract's duration in that year.

The figure was 35 hours when the Code was enacted in 2009. Law 93/2019 raised it to 40 hours, with effect from October 1, 2019. As at September 2026, the consolidated text published in the Diário da República records Law 93/2019 as the last amendment to Article 131. The 2023 Agenda do Trabalho Digno reform (Law 13/2023, in force from May 1, 2023) amended many other articles of the Code, but it did not change Articles 130 to 134 on continuous training.

The 40 hours is an individual entitlement, so it sits alongside, and is different from, the topic specific mandatory training that other laws require for safety, anti-money laundering, or data protection.

The employer must plan training, involve workers in that planning, and reach a minimum share of the workforce each year. Article 131(1) requires the employer, within continuous training, to:

1. promote the development and adequacy of the worker's qualification, to improve employability and raise the company's productivity and competitiveness
2. guarantee each worker's individual right to training through a minimum annual number of hours, either through training in the company or by granting time for training chosen by the worker
3. organize training in the company through annual or multi-year training plans, and guarantee workers and their representatives the right to information and consultation on those plans
4. recognize and value the qualifications the worker acquires

Article 131(5) adds a coverage target: the employer must provide continuous training each year to at least 10% of the company's workers. Article 127(1)(d) separately lists, among the employer's general duties, contributing to the worker's productivity and employability, "nomeadamente proporcionando-lhe formação profissional adequada". Workers in turn have a duty under Article 128(1)(d) to take part diligently in training the employer provides.

Training counts when it is delivered by a recognized provider and certified. Article 131(3) says it may be delivered by the employer, by a training entity certified for that purpose, or by an educational establishment recognized by the competent ministry, and it gives rise to a certificate and registration in the worker's Caderneta Individual de Competências (individual skills record) under the National Qualifications System.

• Worker-student time and competence recognition (Article 131(4)): time off to attend classes and absences for assessments under the worker-student regime count, as do absences for recognition, validation, and certification of competences processes.
• Temporary and seconded workers (Article 131(8)): training provided by the user company or assignee releases the employer, with compensation between them as agreed.
• Collective agreements (Article 131(9)): a collective agreement may adapt the statutory rules to the sector, the workers' qualifications, and company size.
• Subject area (Article 133): the area is set by agreement or, failing that, by the employer, in which case it must match or relate to the worker's activity. When the worker uses a credit of hours, the worker chooses the area, which must relate to their activity or cover information and communication technologies, occupational safety and health, or a foreign language.

Yes, within limits. Article 131(6) lets the employer bring the annual training forward by up to two years or, if the training plan provides for it, defer it by the same period, with training delivered counted against the oldest obligation first. Under Article 131(7), the advance period extends to five years for competence recognition processes or training that gives dual certification.

Hours that are not provided become a worker's credit. Under Article 132, hours not provided by the end of the two years after they fall due convert into an equal credit of hours for training on the worker's initiative. The credit:

• is counted against normal working time, is paid, and counts as effective service
• can be used by giving the employer at least 10 days' notice
• may be supported by a training subsidy, up to the pay for the credit hours used, if a collective agreement or individual agreement provides for it
• is applied to the oldest credit first when credits accumulate
• lapses if unused three years after it was created

The employer must pay for them. Article 134 provides that when the employment contract ends, the worker is entitled to the pay corresponding to the minimum annual training hours not provided, or to the credit of training hours held on the termination date. Unprovided training therefore becomes a quantifiable liability in final settlements, which is a practical reason to keep accurate hour records per worker.

Failing to meet Article 131(1), (2) or (5), or Article 133(1), is a grave (serious) administrative offense under Articles 131(10) and 133(3). The ACT is the inspectorate that enforces the Code.

Fines are set in Article 554 in procedural units of account (unidades de conta, UC) and scale with the company's turnover in the previous calendar year and with the degree of fault.

If the employer does not state its turnover, Article 554(8) applies the highest band. Where a breach affects several workers, Article 558 counts one offense per worker affected and sanctions them with a single fine of up to twice the applicable maximum.

The simplest control is a per worker ledger that records hours due, hours delivered, deferrals, and credits. The example below is illustrative only and assumes a straightforward proportional reading of Article 131(2) for fixed-term staff; collective agreements and individual circumstances can change the result.

A training matrix that tracks hours by worker, alongside the annual training plan and consultation records, answers most of what an ACT inspector will ask for. Record structure is covered in how to prepare training records for an audit.

Keep records that prove each element of Articles 131 to 134, not just course attendance.

• Annual or multi-year training plan, with evidence that workers or their representatives were informed and consulted (Article 131(1)(c)).
• Hours due and delivered per worker, including proration for fixed-term contracts (Article 131(2)).
• Certificates and Caderneta Individual de Competências registrations, and provider certification status (Article 131(3)).
• Annual calculation showing at least 10% of workers were trained (Article 131(5)).
• Any advance or deferral decisions and the plan provision that allows deferral (Article 131(6)).
• Credits of hours created, used, and expired, with the worker's 10 day notices (Article 132).
• Agreement or employer decision on the training area (Article 133).
• Final settlement calculations for unprovided hours on termination (Article 134).

Knowledge Foundry structures training content around defined competencies and assessment points, so each hour recorded toward the 40 hour entitlement can be tied to a documented learning outcome rather than seat time alone. The same framework can link Portuguese continuous training to the topic specific obligations, such as safety, anti-money laundering, and anti-corruption training, that often fill part of those hours.