Frequently Asked Questions
Direct answers to the questions international organisations ask most about Portugal's lobbying transparency regime under Law No. 5-A/2026 of 28 January (Lei n.º 5-A/2026, de 28 de janeiro), with references to the applicable articles.
Scope and applicability
Does the Portuguese regime apply to foreign entities?
Yes. The law approves transparency rules applicable to the interaction between private entities — national or foreign — and Portuguese public entities (Article 1(1)). The decisive factor is not where your organisation is established but whether it represents interests before the Portuguese public entities covered by the regime.
We only lobby EU institutions in Brussels — does this concern us?
The Portuguese regime covers representation before the Portuguese public entities listed in Article 3 — from the Government and Parliament to regulators and local authorities — not the EU institutions themselves. That said, many Brussels-focused organisations also interact with Portuguese ministries, regulators or members of the Assembleia da República on national implementation matters. The prudent course is to map those contacts before concluding that the regime does not apply to you.
Which activities are excluded?
Article 2(3) excludes acts reserved exclusively to lawyers and solicitors in the exercise of the forensic mandate; the activities of social partners in social concertation; responses to requests for information from public entities or to individualised invitations; the exercise of procedural rights under the Administrative Procedure Code (CPA) and the Public Contracts Code (CCP); and the right of petition and the filing of complaints or reports without remuneration. Everything else that aims to influence Portuguese public decision-making is likely to fall within Article 2(1)-(2).
Registration
Is registration mandatory?
Yes, for entities carrying out legitimate interest representation before the covered public entities (Article 13(2)). It is also a practical precondition of access: entities subject to registration must appear in the Transparency Register of Interest Representation (Registo de Transparência da Representação de Interesses — RTRI) before being granted a hearing (Article 8(1)).
How much does official registration cost?
Nothing. The RTRI is public and free of charge (Article 13(1)); no fee is payable for the official act of registration. Any fees quoted on this website relate solely to our professional support services, never to registration itself.
What must we declare?
Article 5(1) requires the identification of the entity and its corporate purpose; the enumeration of clients, interests represented and sectors of activity whenever representation is on behalf of third parties; the members of the governing bodies and the share capital; the person responsible for the representation activity; the annual income derived from it; and any subsidies or financial support from European Union institutions or public entities. The data must then be kept current, with updates within 30 days (Article 5(4)).
When does the register open?
[To be announced by notice of the Assembleia da República — Article 18(3).] The law provides that the Portuguese Parliament will publish a notice in the Diário da República setting the RTRI's start-of-operation date; we track that publication continuously for our clients.
What is the deadline?
Entities professionally engaged in representing third-party interests — the typical position of public affairs consultancies and agencies — must register within 60 days of the RTRI starting operation (Article 19(2)). The clock starts on the date set by the notice provided for in Article 18(3), which makes early preparation the safest strategy.
Obligations
Do we have to identify ourselves with a registration number?
Yes. Registered entities must identify themselves, stating their RTRI registration number, before the officeholders of the bodies they address (Article 7(1)(e)). In practice, the number should be embedded in your correspondence templates, meeting requests and event materials so that the duty is met in every institutional contact.
Will our meetings with Portuguese officials be disclosed?
Yes. Public entities must disclose, at least quarterly, the meetings held with entities listed in the RTRI (Article 8(3)). International organisations should assume that their interactions with Portuguese public entities will become publicly visible and align their internal records accordingly.
Is there a code of conduct we must follow?
Yes. A Code of Conduct (Código de Conduta) is annexed to the law and forms an integral part of it, and adherence is mandatory for registered representatives and for the covered public entities (Article 15(1)). Public entities may densify its rules in their own codes, notably on gifts and hospitality (Article 15(2)), so sector-specific variations should be monitored.
Sanctions
What are the penalties?
Article 11(1) provides for the total or partial suspension of the registration or of the ability to establish institutional contacts for up to 2 years, limitations on the access of natural persons for up to 2 years, and exclusion from participation in public consultation procedures, also for up to 2 years. Sanctioning decisions are published on the Parliament's portal (Article 11(2)), adding a reputational dimension, and representation without prior registration or the provision of false information is referred to the Public Prosecution Service (Ministério Público) (Article 11(6)).
Can decisions be challenged?
Yes. Sanctioning decisions may be challenged before the Portuguese administrative courts (Article 11(3)). A continuously documented compliance record is the best preparation for any challenge, which is one reason we emphasise evidence organisation in our advisory work.
Our services
What does the applicability assessment include?
The Regulatory Applicability Assessment maps your organisation's activities and contacts against Articles 1 to 3 of the law, determines whether registration is required and in which category of Article 13(3), and delivers a documented conclusion with recommended next steps. It is the natural entry point when the extent of your exposure is still unclear.
Can you register us remotely?
Yes. Our RTRI Registration Support for Foreign Entities is designed for organisations with no presence in Portugal: we prepare the registration content with your team in English, handle the Portuguese-language submission from Lisbon in articulation with rtri.pt, and support the 30-day update duty (Article 5(4)) thereafter.
Do you provide training in English?
Yes. We deliver a two-hour executive briefing and a three-hour hands-on registration workshop, both online and in English, plus in-company sessions — see the Training page. The full Portuguese-language catalogue is maintained at representacaodeinteresses.pt.
English renderings of legal concepts on this website are unofficial translations provided for convenience. The authentic text of Law No. 5-A/2026 is the Portuguese version published in the Diário da República.
Question not answered here?
Send us your question and we will respond with the applicable provisions and a practical recommendation.