As a 42°C Heatwave Builds, Portugal Leans on Existing Labour Law for Worker Protection While the ACT Notifies 200,000 Employers of Their Duties

As the first serious heatwave of the summer pushed into Portugal on 1 July 2026 — with the Instituto Português do Mar e da Atmosfera (Portuguese Institute for Sea and Atmosphere, IPMA) forecasting highs above 40°C and touching 42°C in the Ribatejo and interior Alentejo from 3 July — the government's message to worried employees was that the law already has their back. What it conspicuously does not have is a temperature at which work must simply stop.

Speaking as the warning took hold, the government said Portugal's legal framework guarantees the rights of workers exposed to high temperatures, and pointed to the Autoridade para as Condições do Trabalho (Authority for Working Conditions, ACT), which said it had notified some 200,000 companies of their duties heading into the hot spell. The reassurance lands on a familiar Portuguese fault line: strong general obligations on paper, but no hard threshold of the kind Spain adopted when it moved to ban outdoor work during red-level heat alerts.

No maximum temperature — but a firm duty of care

Portuguese law does not fix a ceiling temperature above which a shift is called off. What it does impose, through the Código do Trabalho (Labour Code) and the Lei n.º 102/2009 (Law 102/2009) that governs health and safety at work, is a general duty on the employer to guarantee safe and healthy conditions — including workplace temperature and humidity kept "adequate to the human organism," taking account of the work methods and the physical effort involved.

In practice, that duty translates into things workers are entitled to ask for: proper ventilation or air conditioning, ready access to drinking water, and additional breaks or adjusted schedules where continuing would put their health at risk. The obligation to prevent harm sits with the employer, and failing it can carry consequences — but because the standard is framed around "adequacy" rather than a number, enforcement turns on the specifics of each workplace rather than a thermometer reading.

What the health authorities are asking companies to do

The Direção-Geral da Saúde (Directorate-General of Health, DGS) has issued recommendations for protecting workers exposed to extreme heat that go beyond the bare legal minimum. It urges companies to draw up a specific prevention plan for high-temperature events, to be activated during heatwaves, and to build in concrete measures rather than ad-hoc improvisation.

• Reduce the time workers spend in the heat, with recovery periods in cool or shaded areas.
• Schedule the most physically demanding tasks for the cooler hours of the day and, where necessary, adjust production targets.
• Train workers and supervisors to recognise the early signs of dehydration and heat exhaustion.
• Designate first-aid-trained staff on each shift so that a worker in trouble is spotted and helped quickly.

Those steps feed into the DGS's wider seasonal preparedness plan for 2026–2027, which coordinates the health response to summer heat. For anyone who does start to feel unwell on the job, our guide to medical emergencies in Portugal sets out when to call 112, when to use the SNS 24 line, and how the triage system works.

Who is most exposed

The workers with the least protection from a 42°C afternoon are the ones who cannot retreat indoors: construction crews, farm and vineyard labourers, delivery riders, road and rail maintenance teams, and warehouse staff in un-cooled buildings. Portugal recorded 120 fatal workplace accidents in 2024, a reminder that on-the-job safety is not an abstraction — and heat stress compounds the ordinary risks of physical trades.

The gap between Portugal's approach and Spain's has been a live debate for several summers. Madrid's rules can suspend outdoor work outright when the state weather agency issues its highest alerts; Lisbon has so far preferred to lean on the employer's general duty of care rather than legislate a hard stop. That choice leaves more discretion — and more responsibility — with individual companies, which is precisely why the ACT's pre-heatwave notifications matter.

If your employer does nothing

Where an employer fails to provide water, ventilation, breaks or any of the other reasonable protections, and does not respond to a request to fix it, workers can escalate to the ACT, on the basis that the conditions endanger their health. The authority can inspect and act. The route is not instant relief on a scorching afternoon, but it is the formal lever — and the fact that the ACT contacted 200,000 employers before the heat arrived signals it intends to be visible this summer.

What This Means for Expats

• You can ask, and you should: Water, ventilation or air conditioning, and extra breaks in extreme heat are reasonable requests grounded in the employer's legal duty of care — not favours. Raise them early and, ideally, in writing.
• There is no automatic day off: Portugal sets no temperature at which work legally stops, so do not assume a red-level IPMA warning cancels your shift. Protections are about how the work is done, not whether it happens.
• Know the escalation path: If your employer ignores a genuine health risk, the ACT is the body to contact. Keep a note of dates, temperatures and what you asked for.
• Outdoor and physical roles: watch the clock: The DGS advice to shift heavy tasks to cooler hours is your best template — push for early-morning starts and midday recovery periods if your job is physical.
• Feeling unwell is a health matter, not a performance one: Dizziness, cramps or nausea in the heat are warning signs. If a spell of illness follows, your employment rights around pay and leave are set out in our guide to your Portuguese employment contract and payslip and to claiming sick pay.