Order No. 3118/2026published on March 11, changes, once again, the “rules of organization and management of the National User Registry (RNU) and the conditions for registration in primary health care”. Now, according to the clarification note sent to newsrooms by the Central Administration of the Health System (ACSS), with the objective of “improving access to healthcare”, “strengthening the quality of information systems used in the NHS”, “updating and improving RNU registration typologies”, “adjusting the conditions for registration in primary healthcare” and “improving the process of assigning and maintaining a family doctor”.
A change that is already generating reactions from professionals on the ground, namely the Portuguese Association of General and Family Medicine (APMGF), which says it is “concerned” about the effects that the measure may have on the activity of health centers.
The vice-president of APMGF, António Luz, highlights to DN that “the objective of the measure seems to be to understand whether users who have not seen their family doctor for five years are in national territory or not, but the issue is that there may be users residing in Portugal without needing care during this period, but at any time they may need it and have been eliminated from their doctor’s list. And our concern is to avoid this exclusion”.
Because, “a family doctor’s job, in addition to having to be available to the user when they need it, is also to be proactive in other areas, namely in vaccination and the control of some diseases. And if these users are removed from the lists, the family doctor no longer has the ability to alert to perform this role and be able to alert the user to update vaccines or carry out screenings.”
But there is another side effect that APMGF fears. “Whenever there are changes of this type there is a rush to appointments at health centers by users who don’t even remember if they haven’t been there for two, three, four or five years. This always happens, because users try in this administrative way to ensure that they don’t lose their family doctor.”
Asked by DN whether another change to the RNU was necessary, the vice-president of the APMGF recalls that “in recent years we have seen several updates to the national registration regulations, when the ideal would be for us not to have such frequent changes. First we had changes relating to the lack of updated data on those who were resident or had an address abroad, now the issue is contact with the National Health Service and the removal from the lists of family doctors”, reinforcing that “There should be greater predictability in this regulation, because the most important thing for any healthcare professional is to be able to provide care to the population in need. And, in this case, it is essential that we ensure that this cleansing of users does not suppress the rights of these users”.
António Luz also argues that with this change “it seems more like they want to reduce the number of users without a family doctor, not by attracting more family doctors to work in the SNS and with a better organization of health services in Portugal, but administratively, by removing existing users, who have health needs, and who from then on end up being left out of what is patient management by the family doctor”.
Published order changes two others in force since 2024 and 2025
The order published on Wednesday, March 11th, and which comes into force this Thursday, 12th, and with practical effect after 90 days, in mid-June, changes two other documents, Order No. 14830/2024, relating to the organization and management rules of the RNU, and the Order No. 40/2025, relating to the rules for enrollment in primary healthcare.
In the clarification note, ACSS guarantees that service to users is not in question and that the objective “is to provide a doctor to those waiting”, explaining that the order in question changes articles 6 and 14.
The first referring to “registration typologies” creates a new designation, “updated non-resident registration”, applicable to Portuguese citizens who do not reside in Portugal, and maintains the three other existing ones – “ongoing registration”, “incomplete registration” and “historical registration”. The second concerns the “burdens that entities assume for healthcare”.
In relation to the registration of users in primary health care, the changes now require the following clarification in the RNU: “updated registration” or “updated non-resident registration”.
In article 4, for example, “registration for the assignment of a family doctor now requires that, within the dimension previously contracted with the units in relation to the lists of users with assigned family doctors: − there is availability of family doctor vacancies in the user’s local health unit; − the user is registered in the SUS with the “updated registration” typology.
But it is article 5 that brings the biggest changes with regard to updating primary health care lists. As the ACSS says, “users with a family doctor who have not had contact with the SUS for more than five years release their respective vacancy to the list of users with a family doctor, without, however, losing registration and access to primary health care, as long as they have the ‘updated registration’ type”.
In other words, users do not stop being registered with the SUS, but they lose a family doctor. And it is in this aspect that the APMGF argues that the methodology used by those who supervise the SUS should be different, namely “direct contact with these users by telephone or other means to identify their situation, and not be an administrative cleaning”.
ACSS guarantees that changes do not discriminate against users or limit access
The ACSS guarantees in its explanations that this change in the RNU “will not discriminate against the Portuguese or limit their access to the SNS”, arguing that “it is just an additional type of registration in the RNU that allows improving the administrative classification and management in the RNU, reinforcing compliance with the General Data Protection Regime”, also arguing that it is a way of providing “also a greater quality and reliability of data and better articulation between information systems that ensure the provision of health care to users”.
On the other hand, it assumes that the impact of this measure is that more than 121 thousand users will leave the lists “freeing up vacancies for assigning family doctors to users who are waiting”.
ACSS data reveal that, at the moment, there are 10,003,2026 registered in the SUS and that of these 121,959 users have not had contact with the Health Center or Family Health Unit for more than five years. The vast majority of users are between 18 and 64 years old (108,777), followed by those over 65 years old (7,593) and, finally, those between zero and 17 years old (5,589). In the latter case, and as explained, there are only minors who “belong to a household in which all members have not had contact with the SUS for more than five years”.
As referred to by the ACSS, “the The objective of the current measures is to ensure that users currently without a family doctor can benefit from regular monitoring in primary health care, promoting effective and equitable access to health care”.
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