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In force Act no. 5-A/2026 in force since 27-07-2026 RTRI fully operational on 01-01-2027 Registration deadline: 02-03-2027 Sanctions from 01-06-2027 Sources verified on 3 September 2026

Calendar

The consolidated timetable, after Act no. 37-A/2026

Act no. 37-A/2026 of 28 July repealed the original transitional regime and replaced it with a staggered timetable. This page gathers every applicable date and flags what remains unconfirmed.

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 Act no. 37-A/2026 established the governance of the RTRI, created its Management Board, repealed Article 19 of Act no. 5-A/2026 and replaced the transitional regime with a staggered timetable. English-language commentary published before that date — including the earlier version of this website — is out of date.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.

A repealed provision is still widely cited

Most English-language commentary on Portugal's lobbying law was published between February and July 2026 and cites Article 19 of Act no. 5-A/2026 as the basis for the deadlines. That provision was repealed by Article 9 of Act no. 37-A/2026 on 29 July 2026. The transitional regime is now set out in Article 8 of the latter. If a briefing gives you deadlines based on Article 19, it predates the amendment — and that included the earlier version of this website, corrected in this release and recorded in the imprint.

Timeline

28 January 2026

Act no. 5-A/2026 published

Official Gazette, 1st series, Supplement no. 19.

27 July 2026

Act no. 5-A/2026 enters into force

180 days after publication (Article 21).

29 July 2026

Act no. 37-A/2026 enters into force

Establishes the governance of the RTRI, creates the Management Board and repeals Article 19 of Act no. 5-A/2026. From this date, central government bodies record and publish the hearings they grant by their own means (Article 8(3)).

30 November 2026

Public bodies adopt their regulations

General deadline for adopting the regulations governing publication of hearings (Article 8(5)).

1 January 2027

RTRI fully operational

The Management Board — three independent members — takes office, with competence for registration, cancellation and sanctions (Article 8(1)).

2 March 2027

Registration deadline for professionals

End of the 60-day period running from 1 January 2027 for entities professionally representing third-party interests (Article 8(4)).

30 April 2027

Local authorities adopt their regulations

Municipalities, local undertakings and inter-municipal bodies (Article 8(6)).

1 June 2027

Sanctions and local government

The sanctions regime enters into force (Article 8(8)) and the Act extends to municipalities, their local undertakings and inter-municipal bodies (Article 8(6)).

30 November 2027

Parishes adopt their regulations

Article 8(7).

1 January 2028

The Act extends to parishes

Article 8(7).

What a foreign entity should do in each window

WindowActionWhy now
Until the notice is publishedDetermine applicability and category; identify the legal person that must register; gather and validate the Article 5(1) information; build the evidence file.None of this depends on the platform, and for a foreign group the identification and corporate-documentation work alone takes longer than expected.
From the notice to 31 December 2026File the provisional registration; designate and publish the person responsible for public institutional relations; adopt and publish the code of conduct.Provisional registration allows the filing to be tested and corrected before it has definitive effect.
1 January to 2 March 2027Convert to definitive registration; obtain the registration number; start stating it in every institutional contact.Statutory deadline for professional representatives of third-party interests (Article 8(4)).
Until 1 June 2027Review internal procedures, brief the teams, organise the contractual-relationship record and the conflict-of-interest apparatus.Last window to correct without exposure to the sanctions regime.

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