Further to our previous alert of 16 July 2026, in which we confirmed that the new INEM (Instituto Nacional de Emergência Médica) organic law maintained the insurance levy at 2.5% (rejecting the increase to 3.5% flagged in our 8 June 2026 alert), the financing of INEM through insurance premiums has returned to the agenda in the context of the 2027 State Budget.
The Budget Report accompanying the proposal assumes that INEM’s revenue from insurance levies will increase by €117.5 million in 2027. Two mechanisms are reportedly under consideration to achieve this: a scope extension, broadening the contribution base so that home (household) insurance also contributes to INEM financing, in addition to the Life, Health, Accident and Motor premiums currently charged at 2.5%; or, alternatively, a rate increase from 2.5% to 4%.
By way of a compliance reminder, the INEM levy is a parafiscal charge that is reported and paid monthly to the ASF (Autoridade de Supervisão de Seguros e Fundos de Pensões), the Insurance and Pension Funds Supervisory Authority.
We would stress that, at this stage, this is speculation. The projected revenue figure is a budgetary assumption only, the Government has not clarified the basis for it, no supporting legislative text has been published, and the measure required to give effect to either mechanism remains undefined. Any change would therefore need to be introduced through separate legislation yet to be drafted.
Sovos is monitoring the progress of this measure and will issue a further update as soon as any draft legislative text is published.
