27 July 2026
Act no. 5-A/2026 of 28 January entered into force 180 days after publication (Article 21). Act no. 37-A/2026 followed on 29 July 2026.
For foreign entities
Portugal's interest representation regime applies to foreign entities too
Act no. 5-A/2026 governs transparency rules for private entities — national and foreign — carrying out legitimate interest representation before Portuguese public bodies. If your organisation seeks to influence Portuguese public decisions, it is covered, wherever it is established.
Legislative update of 28 July 2026. Act no. 37-A/2026 established the governance of the RTRI, created its Management Board, repealed Article 19 of Act no. 5-A/2026 and replaced the transitional regime with a staggered timetable. English-language commentary published before that date — including the earlier version of this website — is out of date. See the consolidated calendar.
The four dates that matter
Portugal's timetable is no longer uncertain. Act no. 37-A/2026 of 28 July replaced the original transitional regime with fixed dates — and repealed the provision on which most English-language commentary published before August 2026 still relies.
1 January 2027
The RTRI becomes fully operational and its Management Board — three independent members — takes office (Article 8(1) of Act no. 37-A/2026).
— days
2 March 2027
End of the 60-day period for definitive registration of entities professionally representing third-party interests (Article 8(4)).
— days
1 June 2027
The sanctions regime enters into force and the Act extends to municipalities, their local undertakings and inter-municipal bodies (Articles 8(6) and 8(8)).
Read this before anything else
Public procurement is not interest representation. This is the single most common misunderstanding among foreign entities, and it costs real money in unnecessary work. Article 2(3)(d) of Act no. 5-A/2026 expressly excludes the exercise of procedural rights, including public procurement procedures; Article 8(2) carves out the related procedural steps; and Article 6(3) states that the Act confers no privileged or differentiated access to public decision-makers.
Registering with the RTRI will not make your company eligible to supply the Portuguese State, will not improve your position in a tender, and telling a client otherwise breaches Article 5(1)(b) of the Code of Conduct annexed to the Act. The boundary is explained here.
Does the regime apply to your organisation?
Established abroad, active in Portugal
The Act applies to private entities, national or foreign, that seek to ensure legitimate interest representation before Portuguese public bodies (Article 1(1)). Place of establishment is irrelevant; what matters is the activity carried out before Portuguese bodies.
EU trade associations and federations
Bodies representing the legitimate interests of a set of other entities, or diffuse interests, fall under category (d) of Article 13(3) unless they benefit from automatic registration.
Public affairs consultancies serving Portuguese clients
Category (b): acting professionally on behalf of third parties. The heaviest duties and the only hard deadline — 2 March 2027.
Multinationals with Portuguese operations
Category (c) where the entity represents its own interests. Note that a Portuguese subsidiary and a foreign parent are distinct legal persons: the register covers whichever legal person actually carries out the activity.
Law firms
Acts reserved to lawyers in the exercise of forensic mandate are excluded (Article 2(3)(a)). [The exclusion covers reserved acts and does not turn every activity of a law firm before public bodies into an exempt one; the boundary depends on the acts performed.]
Suppliers to the Portuguese State
Tendering, seeking clarifications and taking part in prior hearings are procedural rights and fall outside the Act (Article 2(3)(d)). That does not mean you are not covered — only that procurement is not the reason.
How we help
Applicability Assessment
A reasoned opinion, in English, on whether the Portuguese regime applies to your organisation and under which category.
RTRI Registration
End-to-end preparation and filing, provisional and definitive, with the evidence file required by Article 5(1).
Compliance Extension
Extending your existing global compliance framework to the Portuguese requirements, rather than building a parallel one.
Ongoing Advisory
Regulatory alerts in English, periodic review and ad hoc qualification questions.
Compliance Toolkit
Ready-to-use templates and checklists, in English, for organisations acting on their own.
Training in English
Technical sessions for legal, compliance and public affairs teams that do not work in Portuguese.
A note on language and jurisdiction
The RTRI operates within the Assembly of the Republic and its working language is Portuguese. Registration is public and free of charge (Article 13(1)); what is chargeable is the preparation, translation and support around it. [The language requirements of the registration platform itself will only be known once the Assembly of the Republic publishes the notice opening the platform in test mode.]
Nothing on this website is legal advice, and it does not replace advice from a lawyer admitted to the Portuguese Bar Association on any specific situation.
Talk to us
Tell us where your organisation is established and what it does before Portuguese public bodies. We reply in English, with the applicable framing and the shortest path to compliance.
Request a Compliance Assessment
Tel.: (+351) 285 107 010 · info@representacaodeinteresses.com