• Sandra Lima da Silveira
• Cristina Romariz
• Maria Inês Sousa

• Labor and Employment

Decree-Law 127/2025, published on December 9, 2025, amends the Social Security Contribution Regime Code.

This amendment simplifies and standardizes the process for employers to report hirings, terminations, contractual amendments, and remuneration, creating a more digital and interoperable system.

1. What changes does this new reporting regime introduce?

The traditional model of monthly declarations has been replaced with a system that relies on structural information previously provided by employers.

The focus has shifted from a burdensome monthly reporting obligation to a validation system based on employers' initially submitted data. Reporting key aspects of employment contracts, such as hirings, terminations, suspensions, amendments, and updates to permanent remuneration, has become the foundation of the new model. The result is a system that requires enhanced accuracy and timeliness.

2. Who is covered by these amendments?

The amendments apply to all employers subject to the Social Security Contribution Regime Code, including public and private entities, as well as self-employed employees with contributory obligations.

3. Do employers still have to report new hires and terminations?

Although the new decree-law maintains the reporting obligation, it imposes stricter deadlines and strengthens verification mechanisms. Consequently, if employers fail to report on time, the Social Security Office is authorized to carry out official registrations or make any necessary corrections.

4. How should remuneration be declared?

The Social Security Office will automatically pre-fill monthly remuneration figures by referencing the permanent remuneration reported by employers.

Employers no longer need to prepare monthly remuneration statements. Instead, they must confirm, complete or correct the pre-filled amounts by the 20th of the following month (or by the 25th in August). Failure to confirm these amounts will be considered an automatic acceptance of the system-generated figures.

This new model replaces the traditional full monthly declaration and now requires only the monthly validation of pre-filled amounts.

5. What changes are introduced in terms of payment obligations?

The payment deadline for social security contributions has been extended. Employers may make payments between the 1st and the 25th of the following month, based on amounts provided after the remuneration has been validated.

6. When must employers start complying with this regime?

The new model enters into force on January 1, 2026, with a progressive implementation schedule. Compliance will become mandatory for all employers on January 1, 2027.

Conclusion

Decree-Law 127/2025 reforms contributory procedures, enhancing the automation, interoperability and oversight of communications between employers and the Social Security Office.

Practical recommendations for employers

• Review and update internal HR procedures to align with the new reporting model.
• Ensure accuracy and timeliness in reporting hirings, terminations and contractual amendments.
• Instruct administrative teams on the new monthly obligations to validate remuneration.

• Sandra Lima da Silveira
• Cristina Romariz
• Maria Inês Sousa

• Labor and Employment