9 october 2026
Background
As part of the digital transformation of the Social Security system, changes were introduced to the contributory regime applicable to employers by Decree-Law No. 127/2025, of 9 December, Regulatory Decree No. 7/2025, of 9 December, and Ministerial Order No. 445/2025/1, of 15 December.
The Simplification of the Social Security Contribution Cycle (SCC) introduces a new framework for the reporting and calculation of social security contribution obligations. Under this framework, Social Security calculates remuneration and working time based, among other elements, on information previously reported by the employer.
Employers must confirm the amounts calculated or, where applicable, report the correct amounts and any other remuneration due. While the SCC simplifies monthly reporting, it requires employee, employment relationship and remuneration data to be complete and up to date.
Who does it apply to and when?
The SCC applies to employers covered by the general social security regime for employees.
During 2026, employers may request to join the SCC, subject to confirmation by Social Security that the applicable conditions have been met. The transition takes effect in the month following confirmation and is irreversible. From that date onwards, remuneration statements submitted under the previous system will be considered as not having been submitted.
From 1 January 2027, all employers will be mandatorily covered by the SCC.
Under the SCC, employers with 10 or more employees must use the Interoperability Services Platform (PSI). Employers with fewer than 10 employees may submit the relevant communications and statements through Social Security Direct.
Main changes
1. Reporting the commencement of employment
The commencement of employment must be reported to Social Security before the employment contract starts. The notification must include, among other information, the type of employment contract, permanent remuneration and the information required for the employee’s registration with Social Security.
Failure to report the commencement of employment may result in a presumption that the employee started work on the first day of the third month preceding the date on which the non-compliance is identified. This presumption may be rebutted by evidence of the actual commencement date.
2. Changes to employment relationships and permanent remuneration
Employers must report the termination or suspension of an employment contract, changes to the type of contract and changes to permanent remuneration by the 10th day of the month following the relevant change.
3. Monthly calculation and confirmation of remuneration
Social Security calculates the monthly amounts based on the information available, including previously reported permanent remuneration.
By the 20th day of the month following the month to which the statement relates, the employer must:
- confirm the amounts calculated, where they are correct; or
- report and confirm the correct amounts where there are changes to remuneration or working time, or where other remuneration is due.
If the employer does not respond within the applicable deadline, the amounts calculated by the system are deemed to have been accepted. Accordingly, the absence of a response should not be understood as removing the need to review the amounts: values may be recorded even where they do not correspond to the amounts actually due.
In August, the deadline for accepting or confirming these elements is extended until 25 August.
4. Recording of working time
Where the law requires remuneration to be reported on an hourly basis for social security purposes, one working day is reported for every five hours worked.
Where the number of hours exceeds a multiple of five, an additional working day is reported, up to a maximum of 30 days per month. This rule should not be applied to situations where hourly reporting is not legally required.
5. Payment of social security contributions
Payment is made based on the information made available by Social Security, between the 1st and 25th day of the month following the month to which the contributions relate.
6. Correction or completion of information by Social Security
Social Security may complete or correct missing or insufficient information based on the data available. The employer is notified and given 10 days to provide the missing information or justify the situation.
Where no information on base remuneration is available and effective remuneration is involved, the remuneration taken into account may correspond to the statutory minimum monthly wage applicable to 30 working days.
Failure to submit a remuneration statement relating to an employee constitutes a very serious administrative offence. Conversely, failure to correct information resulting in differences from the amounts due may constitute a minor administrative offence if corrected within 60 days following the applicable deadline, or a serious administrative offence in other cases.
What should employers prepare?
Employers should:
- review employee, employment relationship and permanent remuneration data, as well as the applicable contribution rates;
- ensure the timely reporting of employment commencements and changes;
- establish a monthly procedure to compare the amounts calculated by Social Security with payroll records;
- identify and report variable remuneration and other amounts due;
- confirm that payroll systems are compatible with the applicable reporting channel – PSI or Social Security Direct;
- carefully assess whether to join the SCC during 2026, given that the transition is irreversible and affects statements submitted under the previous system.
How can we help?
Nexia can support employers in preparing for and implementing the SCC, including through:
- assessing the impact of the new rules on payroll processing and Social Security reporting procedures;
- reviewing employee, employment relationship and permanent remuneration data;
- assessing the social security classification of remuneration components;
- reviewing monthly reconciliation and validation procedures;
- assessing system readiness and integration with the PSI;
- supporting the identification and addressing of gaps before the transition or mandatory implementation in 2027.
For further information on the impact of the Simplification of the Social Security Contribution Cycle on your organisation or on the applicable obligations, please do not hesitate to contact us.
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As informações acima não pretendem ser uma análise exaustiva à totalidade das alterações ao regime legal vigente, mas uma seleção daquelas que entendemos serem as mais relevantes, e não dispensam a consulta da nossa Empresa e/ou diplomas às quais as mesmas se referem.
Para mais informações contacte: Catarina Breia (+351 91 7575 832 ou cbreia@pt-nexia.com) do nosso Departamento Fiscal.
