Thirteen questions, thirteen sourced answers

Yes, where they carry out legitimate interest representation before Portuguese public bodies. Act no. 5-A/2026 expressly applies to private entities, national or foreign (Article 1(1)). Place of establishment is not the test.

Two. Act no. 5-A/2026 of 28 January, which approves the transparency rules and creates the RTRI, in force since 27 July 2026; and Act no. 37-A/2026 of 28 July, which establishes the governance of the RTRI, creates its Management Board, repeals Article 19 of the former and sets a staggered entry into force, in force since 29 July 2026.

It was repealed by Article 9 of Act no. 37-A/2026. It contained the original transitional regime, now set out in Article 8 of the latter. Most English-language commentary published before August 2026 still cites it, and is therefore out of date on the deadlines.

No, in no respect. Public procurement is excluded from the Act's scope (Article 2(3)(d)), the related procedural steps are carved out (Article 8(2)) and the Act confers no privileged access to decision-makers (Article 6(3)). Telling a client otherwise breaches Article 5(1)(b) of the annexed Code of Conduct.

Nothing. The RTRI is a public and free register operating within the Assembly of the Republic (Article 13(1)). What is chargeable is the private preparation, translation and support around it, which is optional.

The RTRI becomes fully operational on 1 January 2027 (Article 8(1) of Act no. 37-A/2026). Provisional registrations may be filed earlier, from publication of the notice declaring the platform operational in test mode (Article 8(2)). Entities professionally representing third-party interests have 60 days from 1 January 2027, expiring on 2 March 2027 (Article 8(4)). [The Assembly of the Republic announced publication of the notice for September 2026.]

Whichever legal person actually carries out the activity. The register covers the legal person and not the brand or trading name, which is a frequent source of error for groups operating in Portugal under a brand.

The six items of Article 5(1): identification and contacts; clients, interests represented and sectors, where representation is on behalf of third parties; the holders of corporate offices and of the share capital; the person responsible for the activity; annual income derived from the activity; and subsidies or financial support received from EU institutions or from national or foreign public bodies in the most recent closed financial year.

Yes. The RTRI is a single, publicly accessible register made freely available through the Assembly of the Republic's portal in machine-readable, searchable and open format, with personal data safeguarded under the GDPR (Article 4(4)).

Suspension from the register or from institutional contacts for up to two years, access restrictions for the individuals involved, and exclusion from public consultations (Article 11(1)); referral to the Public Prosecution Service where the activity is carried out without prior registration or false information is provided (Article 11(6)). The regime enters into force on 1 June 2027 (Article 8(8) of Act no. 37-A/2026).

Subject to limits. Holders of political and senior public office, and staff and members of their private offices, may not carry out interest representation before the legal person, ministry or body in which they served, for three years after leaving office (Article 12(1)). Further incompatibilities apply under Article 12(2). This should be checked before recruitment, not after.

The RTRI operates within the Assembly of the Republic and its working language is Portuguese. [The language requirements of the registration platform itself, and whether documents in other languages are accepted with or without certified translation, will only be known once the platform opens.] We handle the Portuguese-language interface on your behalf.

Yes, but later: to municipalities, their local undertakings and inter-municipal bodies from 1 June 2027, and to parishes from 1 January 2028 (Article 8(6) and (7) of Act no. 37-A/2026).