Organ Donation in Portugal in 2026: A Practical Guide to Presumed Consent, the RENNDA Non-Donor Register, and the Four Working Days Before an Objection Counts

If you live in Portugal, the law already counts you as an organ donor. You did not sign anything, you were not asked, and nothing on your Cartão de Cidadão records the fact. Portugal runs a presumed-consent system: everyone is a potential donor after death unless they have said otherwise, in writing, on a national register.

That register is the RENNDA, the Registo Nacional de não Dadores (National Register of Non-Donors). This guide explains who the rule applies to, exactly how to opt out if you want to, what a partial objection looks like, what happens in a hospital when someone dies, and what the separate rules are for donating while you are alive.

Who the presumption applies to

Article 10 of Lei n.º 12/93, de 22 de abril, the law governing the collection and transplantation of human organs and tissues, says that all Portuguese nationals, stateless people and foreigners resident in Portugal are considered potential post-mortem donors if they have not registered with the Ministry of Health as non-donors.

The scope article, Article 2, sets out the same boundary from the other direction. The law applies to nationals, stateless people and foreigners resident in Portugal. For foreigners without permanent residence in Portugal, the legal regime governing these acts is their personal statute, meaning the law of their own country rather than Portuguese law.

The practical reading for a foreign resident is straightforward. Once you are living here with residence, the presumption covers you exactly as it covers a Portuguese citizen. A residence permit, a certificate of registration or a residence card puts you inside the rule. A tourist or a short-term visitor is outside it.

How to register as a non-donor

The mechanics come from Decreto-Lei n.º 244/94, de 26 de setembro, which regulates the register, and they have barely changed since.

You fill in a standard Ministry of Health form, the impresso RENNDA, and hand it in, in person or through someone representing you, at any health centre or health unit. The member of staff receiving it checks what you have written against your identity document; SNS 24 says the Cartão de Cidadão is all you need to bring. They then give you back a signed copy confirming the form has entered the system, which is worth keeping.

There is no charge.

The registration takes effect four working days after the form is received, not on the day you hand it in. That gap is written into Article 3 of the decree-law, and it is the single most commonly missed detail in the whole procedure.

You can register at any time, and there is no window or deadline.

Saying no to only some of it

An objection does not have to be all or nothing. Article 10(2) of the law provides that where the unavailability for donation is limited to particular organs or tissues, or to particular purposes, those restrictions must be expressly recorded in the register and on the card.

In practice that means you can decline specific organs or tissues, or decline donation for a specific purpose while accepting it for another. The form asks which organs, tissues or purposes are excluded, and the register stores exactly that. The non-donor card then has to carry the restrictions too, under Article 14(4) of the decree-law.

SNS 24 notes the counterweight to this: because organs for transplant are scarce, total donation is what the system is set up to expect, so a partial objection has to be stated explicitly to exist at all.

Minors and people who cannot decide for themselves

For minors and for adults who lack capacity, the objection is registered by their legal representative. Article 10(3) adds that a minor who has the capacity to understand and to express a will may also state the objection themselves.

If you are a parent and you want your children covered, you have to register each of them. Your own registration does not extend to your family.

The non-donor card

Everyone who registers is issued an individual non-donor card. The decree-law gives a maximum of 30 days from receipt of the form for the card to be issued and sent out, and requires it to carry the holder's identifying details and any restrictions.

The decree-law names the Instituto de Gestão Informática e Financeira da Saúde as the body responsible. That institute no longer exists under that name, and SNS 24 states that the card is now issued and posted by the SPMS, Serviços Partilhados do Ministério da Saúde (Shared Services of the Ministry of Health), within the same 30-day limit.

There is a digital route to the same information. SNS 24 sets out the path: log in to the Portal SNS 24, open "Documentos e certificados" in the side menu and select "Cartão de não dador" to see your RENNDA registration details. If you already use the portal for your número de utente and family doctor assignment, this sits in the same place.

Changing your mind

The decision is not permanent. Article 5(2) of the decree-law provides that any change to the stated unavailability for donation, and any updating of the recorded data, is made by filling in the same form again. The route back is the route in: a new form, at a health centre, with the same four working days before it takes effect.

What is recorded, and for how long

The data held under Article 5 is: name, address, place of birth, nationality, date of birth, sex, the identity document number and date, and the organs, tissues or purposes that are not being donated. SNS 24's current version of the list refers to the Cartão de Cidadão in place of the old bilhete de identidade.

Records are kept for ten years after the registered person dies.

Two rights sit alongside that. Article 10 of the decree-law gives anyone the right to know what the register holds about them, and to receive an exact reproduction of it free of charge, with any codes and abbreviations explained. Article 11 gives the right to demand correction of errors, deletion of anything wrongly recorded and completion of anything missing. Everyone handling RENNDA data is bound to professional secrecy, and breaching it is both a disciplinary and a civil wrong.

What happens in the hospital

The register is only worth anything if it is consulted, and the law is specific about that.

Under Article 15 of the decree-law, public and private hospitals that carry out post-mortem collection must check the RENNDA for any objection or restriction before the collection begins. They do this through the organ collection and transplantation coordination offices and the histocompatibility centres, which are permanently connected to the register. Forensic medicine institutes may only collect tissue after checking the register in the same way. Every consultation is logged in a form that can later prove it happened and what it returned.

Article 13 of the law requires the doctors who carry out the collection to draw up a formal record, in duplicate, naming the deceased, the day and hour death was verified, the fact that the RENNDA and the individual card were consulted, the absence of objection, the organs or tissues taken and where they went. The doctor who verifies death may not be part of the transplant team. One copy stays with the hospital and one goes to the Ministry of Health for statistical purposes.

Two further points are worth knowing. Article 16 of the decree-law allows the objection to be proved by the receipt copy from the health centre or by the non-donor card, if either is produced or found among the deceased's effects before collection begins. And Article 13(6) of the law says that where a body could not be identified, non-objection is presumed unless the surrounding circumstances suggest otherwise.

What can be donated, and who can

SNS 24 lists the organs that can be donated as the kidneys, liver, heart, pancreas and lungs. Tissues that can be taken from an organ donor include bone and tendon structures, corneas, heart valves, vascular segments and skin.

There is no upper age limit. What decides whether an organ can be used is its quality and function, not the donor's age.

There is, however, a practical condition that surprises people. For organ donation to be possible at all, death generally has to occur in a hospital intensive care unit, because that is where organs can be preserved and the necessary assessment of the potential donor carried out. That is one reason the route into hospital matters, and why it is worth knowing how 112, INEM and the SNS 24 line fit together before you need them. Donation must also be ruled out where the donor has a disease transmissible through the organ or tissue. Portugal has been performing more of these operations rather than fewer: the country set all-time records for heart and lung transplants in 2025.

Donating while you are alive

Living donation is a separate regime with its own protections, and the RENNDA has nothing to do with it. SNS 24 gives the baseline as being 18 or over and physically and mentally healthy.

The law adds the conditions. Collection from a living person is only permitted in the therapeutic interest of the recipient, and only where no suitable organ or tissue from a deceased donor is available and no alternative treatment of comparable effectiveness exists. Where the organ or tissue is non-regenerable, admissibility depends on a favourable opinion from the EVA, the Entidade de Verificação da Admissibilidade da Colheita para Transplante (Entity for Verifying the Admissibility of Collection for Transplant), which sits as a section of the ethics committee of the hospital where the collection takes place.

Donation and collection of non-regenerable organs or tissues from minors or others lacking capacity is prohibited outright. Regenerable tissue or cells from a minor or a person lacking capacity may only be taken where all three of the following hold: there is no compatible donor with capacity, the recipient is the donor's brother or sister, and the donation is necessary to preserve the recipient's life. Donation is also always prohibited where it would probably cause serious and permanent damage to the donor's physical integrity or health.

One rule applies specifically to foreigners. Donation and collection of non-regenerable organs or tissues involving foreigners without permanent residence in Portugal requires judicial authorisation.

Consent must be free, informed and unequivocal, and the donor may name the beneficiary. It is given before a doctor designated by the hospital's clinical director, and for non-regenerable organs that doctor must not belong to the transplant team. It is always given in writing and is freely revocable at any point. The doctor has a standing duty under Article 7 to explain the possible risks, the consequences of the donation and the treatment, the side effects and the aftercare, in terms the person can actually understand.

Payment is prohibited. Donation cannot be remunerated in any circumstances and commercialisation is banned; hospitals and clinicians may be paid for the service performed, but the calculation may not attribute any value to the organ or tissue itself.

The donor has the right to medical care until fully recovered, and to compensation for harm suffered in the course of the donation and collection, regardless of fault, including the expenses the donation caused. Those duties fall on the hospital.

Time off work for living donors

This is the provision most likely to matter to an employed reader, and it is recent: Article 9.º-A was added to the law by Lei n.º 75-B/2020, de 31 de dezembro.

Absence from work for preparatory consultations and tests, for the hospital stay and for convalescence until the living donor's full physical and psychological recovery counts, for all legal purposes, as time actually worked, with no loss of pay. The absence is justified by a declaration from a doctor at the health unit responsible for the collection, specifying the hours or days involved.

Donors on the convergent social protection regime keep their full pay for the whole period, with no meal allowance paid. Donors registered in the general Segurança Social regime are entitled to a subsidy equivalent to sickness benefit, set at 100 percent of their reference pay, for as long as the absence lasts, again with no meal allowance.

Things people get wrong

Telling your family is not the same as registering. The only objection the hospital is required to check is the RENNDA. A family's word is not the legal instrument, and the collection record has to state that the register and the card were consulted.

The register is for saying no, not for saying yes. There is no donor card to apply for and no box to tick. If you want to be a donor, you do nothing at all.

The four working days are real. Registration does not take effect on the day you hand the form in.

It is not the same thing as a living will. An objection to donation after death is a separate instrument from the testamento vital and the RENTEV register, which deal with the treatment you want while you are alive. Registering one does nothing about the other.

Foreign residents are covered. Being a citizen of another country makes no difference once you are resident here. If you want to be outside the presumption, register.

Sources

This guide is written from official Portuguese and EU sources.

• Procuradoria-Geral Distrital de Lisboa, Lei n.º 12/93, de 22 de abril (colheita e transplante de orgaos e tecidos de origem humana), consolidated text (Portuguese only. Articles 2, 5 to 10, 13 and 9.º-A)
• Procuradoria-Geral Distrital de Lisboa, Decreto-Lei n.º 244/94, de 26 de setembro (Registo Nacional de nao Dadores), consolidated text (Portuguese only. Articles 2 to 5, 9 to 11 and 14 to 17)
• SNS 24, Registar como nao dador (service page, updated 3 February 2026) (Portuguese only)
• SNS 24, Doacao (Dadiva e transplante) (Portuguese only)
• Servico Nacional de Saude, Impresso RENNDA, the Ministry of Health non-donor registration form (PDF, Portuguese only)