Portugal's Insurance and Pension Funds Supervisory Authority issues reporting template for annual right to be forgotten and anti-discrimination report

Portugal's Insurance and Pension Funds Supervisory Authority (ASF) published Circular No. 2/2026 setting out the form and reporting instructions for the annual “Report on the right to be forgotten and discriminatory practices”, supporting the periodic reporting duty introduced by Regulatory Standard No. 12/2024-R on the right to be forgotten and the prohibition of discriminatory practices. The reporting template applies to insurers that enter into insurance contracts linked to mortgage credit and consumer credit (as defined in Law No. 75/2021) and to insurers writing contracts subject to Article 15 of the Insurance Contract Legal Regime. The report is due by 15 April each year for the preceding year and must be submitted via the Operator Portal using existing access credentials. Required content includes a description of implementation and adequacy of the relevant code of conduct, the number of contracts by line, type or modality that include conditions due to disability or aggravated health risk, and a summary of the key risk factors considered crucial, also segmented by line, type or modality.