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Entidade Reguladora da Saúde
Área Privada Pesquisa ERS
Entidade Reguladora de Saúde
EN PT
Institutional
Organisational structure
About ERS
Institutional policies
Contacts
ERS Whistleblowing Channel
Organisational chart
ERS Governing Board
Data Protection and Privacy Policy
Management policy
Board of Directors
Advisory Board
Satutory Auditor
Activities
Registration and licensing
Inspections
Supervision
Sanctioning intervention
Users' rights and protection
Economic regulation
Public consultations
Advisory activity
International
Dispute resolution
Users
Users' rights and protection
Frequently Asked Questions
Forms
Complaints
Information Request
Complaints
Dispute Resolution
Access to Administrative Information
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Frequently Asked Questions

This section provides a set of simplified questions and answers on topics governed by a complex regulatory framework, which have led to numerous information requests and/or complaints submitted to the Portuguese Health Regulatory Authority (ERS).ERS.

These Frequently Asked Questions (FAQs) are intended as a guidance tool and do not replace a careful review of the applicable legislation.

If you cannot find the information you are looking for, you may contact ERS by submitting an information request.

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   02.02.2026

Access to Primary Health Care (Health Centres)

Learn more

   06.01.2026

Complaints, compliments and suggestions

Learn more

   20.08.2025

Access of Foreign Citizens to Healthcare Services in the National Health Service (SNS)

Learn more

Voltar
02.02.2026

Access to Primary Health Care (Health Centres)

These Frequently Asked Questions (FAQs) are intended as an information, guidance and support tool and do not replace the need to read the applicable legislation.

For further information, please consult the section Rights and Duties of Patients » Right to the Protection of Health» The National Health Service (SNS) » Generality.

 


1
1. What is the National Health Service User Number (NNU) and how is it assigned?

The National Health Service User Number (NNU) is a unique and permanent national identifier assigned following a citizen’s registration in the National User Registry (RNU).

The RNU is the national database for the identification and registration of patients within the National Health Service (SNS), supporting the classification of enrolment in primary healthcare services.

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

2
2. How is registration in the National User Registry (RNU) carried out?

Healthcare service user registration in the RNU may be carried out in two ways:

a) Through the RNU portal, by National Health Service (SNS) units in both hospital and primary healthcare settings;

b) By applying for the Citizen’s Card, through data interoperability mechanisms.

Registration in the RNU may also occur via data interoperability with other entities, in accordance with specific and duly regulated procedures.

Registered healthcare service users may access their identification data and their Primary Health Care (CSP) enrolment details through the SNS24 Portal and the SNS24 mobile app.

They may also update their contact details (telephone number and email address) via the same channels.

 

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

3
3. What types of registration exist in the National User Registry (RNU)?

Registration in the RNU may take four forms:

1. Updated registration

2. Registration in progress

3. Incomplete registration

4. Historic registration

 

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

4
4. To whom does the updated registration apply?

The updated registration applies to individuals whose healthcare service user register contains the following information:

  • Portuguese citizens residing in Portugal:

    • Name
    • Sex
    • Date of birth
    • Country of nationality
    • Country of birth
    • District, municipality and parish, when the place of birth is in Portugal
    • Type of identification document (mandatory for individuals over 2 months of age)
    • Identification document number (mandatory for individuals over 2 months of age)
    • Tax Identification Number (NIF)
    • Residence (full address, in Portugal or abroad)
  • Foreign citizens with permanent residence in Portugal:

    • Name
    • Sex
    • Date of birth
    • Country of nationality
    • Country of birth
    • District, municipality and parish, when the place of birth is in Portugal
    • Type of identification document (mandatory for individuals over 2 months of age)
    • Identification document number (mandatory for individuals over 2 months of age)
    • Tax Identification Number (NIF)
    • Residence (full address, in Portugal or abroad)
    • Residence permit document

 

If the individual’s habitual residence address is abroad, the conditions for an updated registration are not met, and enrolment in primary healthcare services is not possible.

 

 

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

5
5. To whom does the registration in progress apply?

A registration in progress applies whenever the conditions for an updated registration are not met (see Frequently Asked Question No. 4).

This type of registration is valid for a maximum of 180 days from the date on which the SNS contacts the citizen for the purpose of updating their data, using the contact details provided.

After this period, it is automatically converted into an updated registration if the required conditions are met, or into an incomplete registration if they are not.

 

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

6
6. To whom does the incomplete registration apply?

The incomplete registration applies to situations in which the citizen does not provide the missing information after the 180‑day period established for the registration in progress (see Frequently Asked Question No. 5).

This 180‑day period is counted from the date on which the SNS contacts the citizen for the purpose of updating their data, using the contact details provided.

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

7
7. To whom does the historical registration apply?

The historical registration applies to deceased citizens who had previously been registered.

 

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

 

8
8. How does the SNS contact healthcare service users for the purpose of updating their registration?

The SNS contacts healthcare service users in order to complete and keep their information in the RNU up to date. This contact is made using the details available in the RNU, preferably by telephone.

When a healthcare service user is registered in the RNU and the required fields for an updated registration are not completed, the SNS will make an initial contact using the communication channels provided by the user.

If, 90 days after this first contact, the required information for an updated registration has still not been provided, a second contact will be made.

 

[See Ministerial Order no. 14830/2024 of 16 December and the Regulation of the National User Registry]

 

9
9. Is access to the SNS dependent on the type of registration in the National User Registry (RNU)?

No.

Regardless of the type of registration in the RNU, the following are beneficiaries of the National Health Service (SNS): all Portuguese citizens, as well as all citizens with permanent residence in Portugal or in a situation of temporary stay or temporary residence in the country, including nationals of European Union Member States or equivalent, nationals of third countries or stateless persons, applicants for international protection, and migrants, whether or not their legal status is regularised, in accordance with the applicable legal framework.

 

[See Ministerial Order no. 14830/2024 of 16 December, the Regulation of the National User Registry;  Law no. 95/2019 of 4 September and Decree-Law no. 52/2022 of 4 August]

 

10
10. Where should enrolment in primary healthcare services take place?

Enrolment in primary healthcare services requires an updated registration in the RNU (see Frequently Asked Question No. 4) and is carried out at a health centre within a local health unit (ULS).

A healthcare service user enrolled in primary healthcare services becomes eligible for allocation to a family health team.

A user who is without a family health team by choice may request to be assigned to one at any time.

 

[See Ministerial Order no. 40/2025 of 2 January and the Regulation of the National User Registry – Enrolment in Primary Health Care]

 

11
11. How is a healthcare service user assigned to a family doctor (General Practitioner)?

The integration of waiting lists must take into account the number of places available for each family doctor (doctor/waiting list ratios), in order to ensure that all existing places are filled.

A healthcare service user’s enrolment on a family doctor’s list must comply with the regulated list size limits and is carried out according to the availability of places in the functional units of the respective local health unit where the user is registered.

[See Ministerial Order no. 40/2025 of 2 January and the Regulation of the National User Registry – Enrolment in Primary Health Care]

 

12
12. Can a healthcare service user be eligible for a reassignment of their family doctor (General Practicioner)?

Yes. Foreign residents and non-residents (national or foreign), registered with a family doctor (General Practicioner) but without a primary care consultation in the last five years, become eligible for reassignment.

The updating of primary healthcare lists takes into account the application of the registration typology defined in Frequently Asked Question No. 3.

 

[See Ministerial Order no. 40/2025 of 2 January and the Regulation of the National User Registry – Enrolment in Primary Health Care]

13
13. Can a healthcare service user registered with a primary healthcare unit seek care at another unit?

Yes. Although the healthcare service user should prioritise contact with the primary healthcare unit where they are registered, they may, on an occasional basis and in situations of acute illness or other urgent needs, seek care at another functional unit. In such cases, the user makes a one‑off contact without a new registration being created at that unit and may, subject to the resources available, receive the necessary care there.

 

[See Ministerial Order no. 40/2025 of 2 January and the Regulation of the National User Registry – Enrolment in Primary Health Care]

14
14. Can an unregistered healthcare service user attend a healthcare unit to obtain medical and/or nursing care?

Yes. An unregistered healthcare service user who requires medical and/or nursing care may make occasional contacts without any registration being created in a functional unit.

 

[See Ministerial Order no. 40/2025 of 2 January and the Regulation of the National User Registry – Enrolment in Primary Health Care]

15
15. Can a healthcare service user request a transfer to another primary healthcare unit?

Yes. The healthcare service user may request a transfer between functional units within primary healthcare.

 

[See Ministerial Order no. 14830/2024 of 16 December]

16
16. Can a healthcare service user choose not to have a family doctor (General Practitioner)?

Yes. Healthcare service users may choose not to be assigned a family doctor (General Practitioner) and may also request to be removed from the list on which they are currently registered.

 

[See Ministerial Order no. 14830/2024 of 16 December]

 

17
17. If a healthcare service user does not have an assigned family doctor (General Practitioner), are they entitled to access care in a primary healthcare unit?

Yes. Regardless of whether or not they have an assigned family doctor (General Practitioner), the healthcare service user is entitled to receive healthcare of appropriate quality and within a timeframe considered clinically acceptable for their health condition - see Questions 8 and 9 of the Frequently Asked Questions on Guaranteed Maximum Response Times (TMRG).

 

[See Law no. 95/2019 of 4 September, Decree-Law no. 52/2022 of 4 August and Ministerial Order no. 153/2017 of 4 May]

 

18
18. What should a healthcare service user do if their right of access to healthcare provision within the National Health Service (SNS) is not being respected?

If, for any reason, the healthcare service user encounters difficulties in exercising their rights and their access to healthcare provision is being limited, they should:

  • First, seek clarification from the healthcare provider concerned.
  • If any doubts persist, they may request information from the Portuguese Health Regulatory Authority (ERS), namely through the online form;
  • If the issue remains unresolved, they may submit a complaint directly to ERS.
Voltar
06.01.2026

Complaints, compliments and suggestions


1
What is a complaint?

A complaint is the expression of disagreement concerning a situation that may give rise to censure, conflict, dissatisfaction or divergence, resulting from an interaction with a service provider (for example, a healthcare provider).

Submitting a complaint is a voluntary act and constitutes one of the most important rights of service users, as enshrined in the Constitution of the Portuguese Republic.

2
Who can make a complaint?

All individuals, regardless of whether they act in a personal or collective capacity, and irrespective of nationality or residence, are recognised and guaranteed the right to make a complaint regarding any aspect of healthcare provision, and the right to receive an appropriate, clear, and understandable response.

Accordingly, a complaint may be submitted not only by patients receiving healthcare and their legal representatives, but also by anyone attending, using, or accessing a healthcare facility, as well as by those accompanying or visiting patients.

3
Against whom can a complaint be made?

A complaint may be made against any establishment that provides services to the public.

With regard to complaints falling within the remit of the Health Regulatory Authority, and by way of illustration only, complaints may be submitted concerning:

  • Hospitals (public or private);
  • Clinics;
  • Dental clinics;
  • Health centres;
  • Medical practices;
  • Nursing centres;
  • Physical medicine and rehabilitation clinics or physiotherapy practices;
  • Clinical laboratories for medical analyses, pathology, and medical genetics, including sample collection points;
  • Long-term care units;
  • Any home healthcare unit or services provided through mobile or motorised facilities;
  • Telemedicine units.

See here for the complete list of establishments against which a complaint may be made.

4
What complaints are handled by the Health Regulatory Authority (ERS)?

The ERS regulates and supervises the activities of healthcare service providers.

Complaints falling within the remit of the ERS are those where the respondent is a healthcare provider (regardless of whether it operates in the public, private, cooperative, or social sector), with a facility located in mainland Portugal, and where the content of the complaint relates to the activities carried out there. Examples include:

  • Access to healthcare services;
  • Discrimination;
  • Quality of healthcare provision;
  • Quality of administrative support;
  • Patients’ rights;
  • Waiting times for appointments (administrative, scheduled clinical, and unscheduled clinical);
  • Waiting times for access to healthcare services;
  • Financial matters;
  • Quality of facilities.

 

Aviso

In the analysis of complaints, the following are excluded from the ERS competence:
- Healthcare professionals, about their activity subject to regulation and discipline by their respective public professional associations (Orders) - example: clinical malpractice, misconduct by healthcare professionals, disrespect for ethical standards;
- Establishments subject to specific regulation by INFARMED - National Authority for Medicines and Health Products, I.P., such as pharmacies, in aspects relating to this regulation - example: dispensing of medicines and health products;
- Behaviors that may constitute criminal liability.

However, if the ERS becomes aware of facts relating to matters outside its scope of action, it forwards them to the competent authority.

5
What can be done before submitting a complaint?
  1. Consult the information published by the ERS regarding the rights and duties of healthcare service users, available at https://www.ers.pt/pt/utentes/direitos-e-deveres-dos-utentes/
  2. Contact the healthcare provider, who may provide support and information to help achieve a resolution.

 

6
What channels are available for submitting a complaint?

Healthcare service users may submit a complaint through the following channels:

  1. Directly with the healthcare provider:
  2. a) Via the physical Complaints Book, which must be made available in all establishments providing services to the public.
  • In private healthcare facilities, the Complaints Book (referred to as the “Red Book”) may be requested by the patient, who retains the duplicate copy (blue sheet).
  • In public healthcare facilities, the Complaints Book (referred to as the “Yellow Book”) may also be requested by the patient.

 

  1. b) Via the Electronic Complaints Book (LRE) platform.

The Electronic Complaints Book is a digital platform that enables patients to submit complaints, suggestions, or compliments electronically.

 

Currently, only healthcare providers in the private, cooperative, and social sectors are required to have an Electronic Complaints Book.

 

 

If you filed a complaint with the service provider, you do not need to file it again with ERS.

 

  1. Directly with the ERS:
  2. a) Via the online complaint form provided by the ERS in the Complaints

The ERS website provides a form that patients may use to submit a complaint directly to the ERS.

  1. b) By post to ERS postal address (see FAQ question No. 21), or by email to reclamacoes@ers.pt.

 

A complaint can only be fully addressed, either by healthcare providers or by the ERS (Health Regulatory Entity), if it is submitted exclusively through the legally established channels identified above.
The use of different digital platforms (such as, for example, the Complaint Portal) does not guarantee that complaints, compliments, and suggestions will be processed in accordance with the applicable legal regime, either by the provider or by the ERS, since the full content of those may not reach them.

 

Voltar
20.08.2025

Access of Foreign Citizens to Healthcare Services in the National Health Service (SNS)

These frequently asked questions do not replace a careful review of the applicable legislation and are primarily intended to serve as a source of information, guidance, and support.

For more information on this topic, please consult the section Rights and Duties of Healthcare Users » Right to the protection of health » The National Health Service » Universality.


1
1. Do foreign citizens have access to healthcare within the Portuguese National Health Service (SNS)?

Yes. Pursuant to paragraphs 1 and 2 of Basis 21 of the Health Basis Law (Law No. 95/2019 of 4 September) and to Article 4 of Decree-Law No. 52/2022 of 4 August, all Portuguese citizens, as well as foreign citizens with permanent residence or in a situation of temporary stay or residence in Portugal, are beneficiaries of the SNS. This includes nationals of European Union Member States and equivalent, third-country nationals or stateless persons, applicants for international protection, and migrants, irrespective of their legal status, in accordance with the applicable legal framework.

[See  Law No. 95/2019 of 4 September (Health Basis Law)  and  Decree-Law No. 52/2022 of 4 August] 

2
2. What is the National User Registry (RNU) and what is its purpose?

The RNU is the national database for the identification and registration of users within the National Health Service (SNS). It is through the RNU that the SNS user number (NNU) is issued, which is required in order to access healthcare within the SNS.

[See Order No. 14830/2024 of 16 December and the Regulation of the National User Registry]

3
3. How can a foreign citizen obtain the SNS user number (NNU)?

The NNU (or SNS user number) is obtained through the registration of the individual in the National User Registry (RNU).

This registration is carried out when the citizen first comes into contact with a National Health Service (SNS) healthcare unit.

For this purpose, the citizen must provide a minimum set of mandatory information, namely:

  • Full name;
  • Sex;
  • Date of birth;
  • Country of nationality;
  • Country of birth;
  • District, municipality and parish, when the place of birth is in Portugal.

[See Order No. 14830/2024 of 16 December and the Regulation of the National User Registry]

4
4. What types of registration exist in the National User Registry (RNU)?

Registration in the RNU may take four forms:

1. Updated registration – requires the completion of a mandatory set of information in the user’s record within the RNU.

2. Registration in progress – applies where not all the necessary information fields for an “updated registration” have been completed within 180 days of the creation of the record in the RNU.

3. Incomplete registration – applies where, after 180 days from the creation of the record in the RNU, the citizen has not provided the mandatory data required for an updated registration.

4. Historic registration – applies to records classified as deceased.

 

For further information on the different types of registration in the RNU, please consult the Frequently Asked Questions on Access to Primary Health Care (Primary Health Care Units). 

[See Order No. 14830/2024 of 16 December  and the  Regulation of the National User Registry]

5
5. Does the legal status of a foreign citizen in Portugal affect the type of registration assigned in the National User Registry (RNU)?

Yes.

Foreign citizens with permanent residence in Portugal and holding a valid residence permit are assigned the status of “updated registration”. The condition of “updated registration” requires a national address.

Foreign nationals without a valid residence permit are assigned the status of either “registration in progress” or “incomplete registration”.

For further information on the different types of registration in the RNU, please consult the Frequently Asked Questions on Access to Primary Health Care (Primary Health Care Units).

 

In the context of the application of exceptional and temporary measures, Decree-Law No. 85-B/2025 of 30 June established the extension of the validity of residence permits, as follows:

 

  • “Residence permits expiring between 22 February 2020 and 30 June 2025 shall remain valid, under the same terms, until 15 October 2025.”
  • “After 15 October 2025, residence permits shall be accepted upon presentation by the holder of proof of payment of the renewal application, issued by the Agency for Integration, Migration and Asylum, I.P. (AIMA, I.P.), valid for 180 days from the date of issue.”

(Please note: The translations of the preceding excerpts are unofficial and for informational purposes only. Only the original legal texts in Portuguese are legally binding.)

 

[See Order No. 14830/2024 of 16 December, the Regulation of the National User Registry and Decree-Law No. 85-B/2025 of 30 June

6
6. What are the differences between registration types regarding financial responsibility and enrolment in primary healthcare?

Registration in the RNU does not imply that the National Health Service (SNS) will automatically cover all costs arising from the provision of healthcare.

Financial responsibility depends on the type of registration in the RNU.

 

Financial responsibility for healthcare costs:

For foreign nationals with “updated registration”, financial responsibility is generally assumed by the SNS, regardless of entitlement under any public subsystem.

For foreign nationals with “registration in progress” or “incomplete registration”, the responsibility for costs lies with the individual or a third party financially liable, except for healthcare specifically provided under paragraph 7 of Informative Circular No. 12/DQS/DMD of the Directorate-General of Health (DGS), namely:

    • Maternal and child healthcare and reproductive health services, including access to family planning consultations, voluntary termination of pregnancy, monitoring and supervision of women during pregnancy, childbirth, and the postpartum period, and healthcare for newborns;
    • Healthcare for minors residing in Portugal, as defined in Decree-Law No. 67/2004 of 25 March;
    • Vaccination, according to the current National Vaccination Programme;
    • Foreign nationals in family reunification situations, when a household member makes duly verified Social Security contributions;
    • Individuals in situations of social exclusion or proven economic hardship, as certified by Social Security Services.

For this set of healthcare services, foreign nationals have access on the same terms as the general population and are subject to the same principles and general rules regarding payment and exemption from co-payments, in accordance with the applicable legislation.

 

Enrolment in primary healthcare:

Enrolment in primary healthcare requires an updated registration in the RNU and is carried out at a health centre of a local healthcare unit.

For further information on the different types of registration in the RNU, please consult the Frequently Asked Questions on Access to Primary Health Care (Primary Health Care Units).

[See Order No. 14830/2024 of 16 December, Order No. 40/2025 of 2 January, the Regulation of the National User Registry, the Regulation of the National User Registry – Enrolment in Primary Healthcare and the Informative Circular No. 12/DQS/DMD of the Directorate-General of Health (DGS)]

7
7. If a foreign citizen does not present a residence permit, does accessing healthcare entail costs?

Yes.

However, if a foreign citizen without a residence permit presents a declaration issued by the Parish Council (Junta de Freguesia) confirming that they have been residing in national territory for more than 90 days, they may access urgent and life‑saving healthcare with financial responsibility assumed by the National Health Service (SNS).

This declaration must be presented each time the individual accesses a SNS healthcare unit, in order to confirm their status at the time of healthcare access. It ceases to be used once the individual presents a valid residence permit and this information is recorded in their RNU user record.

In the case of foreign nationals who neither hold a residence permit nor a declaration from the Parish Council confirming residence in national territory for more than 90 days, Informative Circular No. 12/DQS/DMD of the Directorate-General of Health (DGS) establishes that, for the specific set of healthcare services referred to in Frequently Asked Question No. 6, foreign citizens have access on the same terms as the general population, being subject to the same principles and general rules regarding payment and exemption from co-payments, in accordance with the applicable legislation.

  

[See the Regulation of the National User Registry and the Informative Circular No. 12/DQS/DMD of the Directorate-General of Health(DGS)]

8
8. What happens if a foreign citizen’s registration in the RNU is not complete?

If a foreign national’s registration in the RNU is not complete, the record will be classified as:

 

 “Registration in progress”: for a maximum duration of 180 days, whenever the conditions for “updated registration” are not met.

“Incomplete registration”: occurs after the 180-day period if the missing information is not provided.

 

In these cases:

Financial responsibility is no longer assumed by the SNS;

Enrolment in primary healthcare becomes impossible.

 

[See Order No. 14830/2024 of 16 December and the Regulation of the National User Registry]

9
9. Does a foreign minor need a residence permit to be registered in the RNU under the “updated registration” type?

No. A foreign minor, up to 17 years and 364 days of age, does not require a residence permit or a Tax Identification Number (NIF) to obtain an updated registration. After this age, an additional period of 90 days is granted to regularise their situation.

 

[See Order No. 14830/2024 of 16 December e Regulation of the National User Registry]

10
10. What should a foreign citizen do if they have questions about their registration in the RNU or need assistance to update their information?

A foreign citizen should contact a National Health Service (SNS) healthcare unit for guidance and assistance.

 

[Cf. Order No. 14830/2024 of 16 December and the Regulation of the National User Registry]

11
11. What should be done if a foreign citizen’s rights regarding access to healthcare in the SNS are not being respected?

If, for any reason, a foreign citizen encounters difficulties in exercising their rights and their access to healthcare is restricted, they should first seek clarification from the healthcare provider concerned.

If doubts persist, the individual may submit an information request to ERS using the  online form. 

 

Should the obstacles remain unresolved, a complaint may also be submitted directly to ERS. 

 

For further information, the following entities may also be consulted:

  • The Agency for Integration, Migration and Asylum (AIMA)
  • The Directorate-General of Health (DGS)
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