Portugal

Approve a 90-day paid validation, tool trial and site-compliance design only. Require twelve-platform functional proof, a named HV lead, written fire/waste/insurer acceptance, two B2B anchors, 100 paid jobs and a credible path above EUR775,862 annual break-even revenue before a permanent six-bay lease.

ERSE reported about 357,000 electric vehicles in the second half/end of 2025, 58% pure electric and 42% hybrid. Because the shares are rounded, EVS treats about 207,060 BEVs and 149,940 PHEVs as approximate components, not exact register counts. The combined 357,000 plug-in pool is the core service baseline.

The regulator’s hybrid label is read in the electric-mobility context as plug-in hybrid, but the underlying register extract is not published on the cited page. EVS therefore sizes the combined pool and preserves the split only as an approximation. A clean IMT/ERSE M1-only extract is a pre-investment gate.

EAFO lists 7,493,960 M1+N1 light-duty vehicles in 2025. The plug-in pool is therefore still a minority of the broader parc. UVE estimates 243,954 BEV passenger cars at end-2025 from cumulative registrations, but explicitly cannot deduct scrappage or exports; EVS uses that only as an upper sensitivity, not the base.

ACAP new registrations, ERSE plug-in stock, UVE cumulative BEVs and EAFO alternative-fuel fleet are different populations. New sales do not equal active stock; M1 passenger cars differ from M1+N1; cumulative registrations overstate active stock if exits are unknown. No averaging hides these differences.

ACAP recorded 225,039 new passenger cars in 2025, up 7.3%. Passenger BEVs numbered 52,296, a 23.2% share and 25% year-on-year growth according to EAFO’s ACAP-derived summary.

EAFO reports 34,166 passenger PHEVs and a 15.1% passenger-car share, but the same page also contains contradictory all-segment PHEV totals of 33,884 and 28,346. EVS uses 34,166 only for the explicitly labelled passenger series because 34,166 / 225,039 reconciles to 15.2%; the all-segment totals are excluded.

Passenger BEVs increased from approximately 41,757 in 2024 to 52,296 in 2025. The combined 2025 plug-in passenger flow was 86,462, equal to 38.4% of passenger registrations before rounding. Imported used BEVs are material, but cumulative import tables are not treated as active fleet without exits.

In H1 2026, ACAP recorded 34,706 new passenger BEVs, up 38.7%, equal to 25.3% of 137,080 passenger registrations. June alone reached 7,572 and 28.7%.

H1 2026 is a partial-period flow and is not annualised into stock. Brand releases and Reuters are current signals only; final ACAP annual tables remain the registration authority used for the model.

From the rounded 357,000 end-2025 plug-in baseline, EVS applies five-year compound growth of 13%, 19% and 25%. The cautious, base and high cases produce approximately 657,749, 851,928 and 1,089,478 plug-in vehicles by end-2030.

These are planning scenarios, not official forecasts. Strong H1 2026 BEV uptake, expanding models and charging support growth; grant limits, urban charging access, income sensitivity, OEM warranty capture and classification uncertainty are downside factors.

ERSE reported approximately 13,000 public charging points across about 7,000 electricity delivery points in October 2025, plus 1,200 holders of private-access points connected to the network. EAFO reported 13,250 public points by October. Points, sites and connectors are not interchangeable.

Decree-Law 93/2025 and Regulation 7/2026 open the market to ad-hoc charging and new operator/service-provider roles, with legacy arrangements continuing through 31 December 2026. EVS must separate vehicle-service activity from regulated charge-point operation.

Apartment and condominium constraints make Lisbon and Porto public/semipublic charging especially relevant. Fleet depots, used-EV dealers, body shops and charging operators are better referral channels than a generic roadside location.

The service proposition should include charge-port, onboard-charger, communication, isolation and thermal diagnostics, with evidence reports that distinguish vehicle faults from charge-point faults.

Portugal’s passenger-car parc averaged 13.6 years in 2023 in ACEA-derived data, while ACAP reported 5.97 million passenger cars in the broader 2024 parc. The national parc is old, but the plug-in sub-parc is much younger; national age cannot be assigned to EVs.

Near-term EV demand is therefore driven by used imports, accident isolation, charging/thermal faults, battery-condition evidence, fleet returns and warranty-expiry cohorts. Battery pack opening is a later controlled capability, not a launch service.

Sourced fact: about 357,000 plug-in vehicles. EVS assumptions: 0.75 paid workshop jobs per plug-in per year; EUR260 average ticket; 48% independently addressable; 68% in priority clusters/services. Result: EUR69.615m TAM, EUR33.415m eligible pool and EUR22.722m SAM.

The base pilot case is 2,600 jobs at EUR340, or EUR884,000 revenue, equal to 3.9% of modelled SAM. It is a capacity case, not a forecast or market-share claim.

Lead with used-EV dealers/importers and buyers, insurers/body shops, rental and leasing fleets, corporate fleets, independent garages and premium warranty-expiry owners. Require paid evidence products and service-level agreements.

In 2025 Tesla led BEV registrations with 7,585, followed by BYD 4,938 and BMW 4,604. Mercedes led PHEVs with 8,597, BMW followed with 5,818 and Volkswagen with 2,916. Brand registrations are not the same as active stock.

The PHEV mix strengthens the case for Mercedes/BMW/VW Group diagnostic capability, but ICE-plus-HV complexity raises training, emissions and refrigerant scope. Publish only functions proven on exact VIN/platform combinations.

H1 2026 data show continued BEV growth and shifting brand shares. EVS should avoid a Tesla-only proposition and validate Tesla, VW Group, BMW/MINI, Mercedes, BYD, Stellantis, Renault/Dacia, Hyundai/Kia and Volvo/Polestar families.

OEM dealers retain warranty, parts and secure-function advantages. Salvador Caetano, SIVA, Grupo JAP and premium networks add national scale; Bosch Car Service, Norauto, Midas and Euromaster add independent coverage. EVS must win on cross-brand depth, evidence and escalation speed.

Lisbon North–Oeiras–Sintra is the preferred controlled hub for density, imports, premium owners, fleets and talent, with Setubal/Palmela as an industrial/referral corridor. Porto–Maia–Matosinhos is the second hub; Braga–Guimaraes and Algarve begin as collection/referral nodes.

The 2025 Fundo Ambiental call offered EUR4,000 to qualifying individuals buying a new BEV passenger car with scrappage, subject to a EUR38,500 cap or EUR55,000 for more than five seats. Budget exhaustion and annual renewal mean EVS must never assume live availability.

The official application tracker shows demand exceeding the 1,425 individual passenger-car allocation. Incentives affect sales timing, but EVS demand and economics are not grant-dependent.

BEVs are excluded from ISV and exempt from annual IUC. Qualifying PHEVs may receive an intermediate ISV rate subject to electric-range and emissions conditions. Confirm every VIN and current tax law; do not advertise a blanket PHEV benefit.

Portugal’s standard corporate income-tax rate is 19% from 2026; qualifying SMEs/Small Mid Caps face 15% on the first EUR50,000. Municipal and state surcharges, VAT and autonomous vehicle taxation require Portuguese tax advice.

AICEP’s contractual productive-investment scheme starts above EUR3m eligible capex and is not a normal single-workshop grant. IAPMEI, regional and skills programmes are project-specific; no subsidy is included in pilot economics.

Use a Portuguese limited-liability subsidiary with CAE 45200, Portuguese accounting, insurance and employment compliance. Form the entity only after a written activity/site licence matrix and three compliant premises options.

Vehicle maintenance and repair is CAE 45200. The core activity gateway is relatively straightforward, but planning/use, fire, drainage, noise, signage, hazardous storage, lifts, compressors, refrigerants and any body/paint or charge-point activity can trigger separate requirements.

If EVS installs or operates public charging, Decree-Law 93/2025, DGEG operator rules and ERSE Regulation 7/2026 apply. Workshop charging for service use must be legally classified before fit-out.

Periodic inspections, towing, dismantling, salvage, battery treatment, electrical installation and charge-point operation are outside ordinary repair scope unless separately authorised. Launch with repair/diagnostic scope only.

Portugal’s occupational-safety framework requires employer risk assessment, training, safe equipment and competent work organisation. The research found no single national EV-technician licence that substitutes for those duties.

Adopt a documented role ladder aligned with EN 50110 and recognised vehicle-HV training: identify, isolate, verify de-energised state, lock/tag, control access, use rated PPE/tools and quarantine damaged vehicles. ATEC offers DGUV 209-093-aligned training locally.

Do not infer technician supply or wages from course availability. Recruit a named HV lead, obtain signed offers and test diagnostic competence on target platforms before the lease.

EU Battery Regulation 2023/1542 and Portugal’s UNILEX framework govern batteries and waste batteries. Damaged traction batteries require written storage, transport, insurer and authorised-recipient pathways before acceptance.

Register and record relevant flows through APA/SILiAmb/e-GAR as applicable; use authorised systems for batteries, oils, tyres and end-of-life vehicles. EVS is not a dismantler or waste-treatment operator at launch.

EU Regulation 2024/573 governs F-gas work. Technician/company certification, recovery equipment, leak/quantity records and refrigerant-specific procedures must be confirmed before thermal-system service.

GDPR applies to customer, vehicle, telematics and diagnostic data. Establish lawful basis, retention, processor, cross-border transfer, access-control and breach procedures before CRM and remote support go live.

Launch with battery-condition and pre-purchase evidence, charging/thermal/HV diagnostic triage, tyres/chassis/brakes/12V, accident isolation, fleet-return reports and independent-garage escalation. Defer cell/module repair, salvage and public charging operation.

Portugal has no dedicated franchise statute. General contract/commercial law, Civil Code good faith, competition, consumer, IP, data and sector rules apply. Prepare Portuguese pre-contract information even without a statutory FDD and have performance claims independently reviewed.

Operate Lisbon and then Porto as company-controlled proof sites. Franchise only after two sites achieve twelve months of audited quality, access, safety and unit economics; the initial partner model should be referral/collection, not master franchise.

The six-bay model is assumption-led and excludes VAT, financing, tax, subsidies and pack remanufacture. Base revenue is EUR884,000, 58% contribution and EUR450,000 fixed cost, yielding EUR62,720 EBIT. Break-even revenue is EUR775,862.

The main risks are a young warranty-heavy fleet, OEM data/security restrictions, price-sensitive demand, HV talent, battery/fire events, site delays, fragmented classifications and incumbent response. Every risk has a measurable pre-lease gate.

Days 1–30: appoint Portuguese counsel/accountant and an HV lead; map CAE/site/fire/waste/insurance/RMI rules; screen three Lisbon sites; interview 25 fleets, dealers, body shops and garages; procure twelve-platform tool trials.

Days 31–60: run a mobile/partner-bay paid diagnostic clinic; validate battery and charging evidence; secure two B2B anchors; obtain waste, insurer, site and fire responses; record job time, ticket, conversion and comeback.

Days 61–90: reach 100 paid jobs; demonstrate at least 85% first-time fix and at most 3% comeback; validate ten of twelve platforms; finalise staffing and fit-out quotes; take the lease only if all gates pass.

The report prioritises Portuguese regulators, government, tax authority, ACAP, EAFO/EU law and official company networks. Stock, flows, vehicle scope and charging units are kept distinct. All commercial ratios, scenarios, regional scores and economics are labelled EVS assumptions.

No wage, rent, independent-market share, repair price or active PHEV register count was invented. ERSE’s rounded stock split, EAFO’s PHEV inconsistency and UVE’s cumulative-stock limitation are preserved. Legal, tax and permitting findings require live professional confirmation.

The package source registry records title, publisher, publication date, access date, URL and relevance notes. Source-count claims refer to unique linked records, not repeated citations.

Decision: proceed only to the paid Lisbon validation and compliance design. Do not sign a permanent site or sell a Portuguese franchise until demand, platform access, HV competence, waste/fire/insurance and break-even gates pass.