1. Introduction
Transmission services used in the provision of M2M services are
growing in importance. As a result, in May 2019 ANACOM (the
Portuguese communications regulatory authority) launched a public
consultation1 to collect input on the possible creation
of a specific range in the national numbering plan (plano
nacional de numeração - PNN) to accommodate
these services. According to ANACOM, the aim of opening this range
would be to respond to the significant increase in demand for
numbers for machine-to-machine (M2M) services.
The European Electronic Communications Code ("EECC")
approved in 2018 was only incorporated into Portuguese law in
August 2022. However, the public consultation conducted by ANACOM
in 2019 was already aligned with the EECC. It states that the
possibility of granting rights of use of numbering resources should
be taken into account, considering the significant increase of
several services of the Internet of Things
("IoT").2
