Framework
The regime, article by article, in English
A complete and sourced reading of Portugal's interest representation regime, written for foreign counsel and compliance officers who need to decide what to do.
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 Act no. 37-A/2026 established the governance of the RTRI, created its Management Board, repealed Article 19 of Act no. 5-A/2026 and replaced the transitional regime with a staggered timetable. English-language commentary published before that date — including the earlier version of this website — is out of date.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.
Scope and definition
Act no. 5-A/2026 of 28 January approves transparency rules governing the interaction between private entities — national or foreign — and public bodies that seek to ensure legitimate interest representation, and creates the Interest Representation Transparency Register (RTRI), operating within the Assembly of the Republic (Article 1(1)).
Interest representation covers activities carried out with the aim of influencing, directly or indirectly, the drafting or implementation of public policies, legislative and regulatory acts, administrative acts or public contracts, as well as the decision-making processes of public bodies, whether in one's own name, on behalf of specific groups or on behalf of third parties (Article 2(1)). It expressly includes contacts with public bodies in any form; sending and circulating correspondence, information material or position papers; organising events, meetings and conferences promoting the interests represented; and taking part in consultations on draft legislation or other regulatory acts (Article 2(2)).
The Act does not prejudice the framework of rights and duties laid down in the Constitution and the law for social concertation and for participation in public decision-making, nor does it prevail over the exercise of fundamental rights, including the right of petition, participation in public life, demonstration and freedom of expression (Article 1(2)).
Public bodies covered
Article 3 lists eight categories: the Presidency of the Republic, including the Civil and Military Households and the President's office; the Assembly of the Republic, including its bodies, services, parliamentary committees and the support offices of the Bureau, parliamentary groups and individual Members; the Government, including ministerial private offices; the self-government bodies of the autonomous regions; the Representatives of the Republic for the autonomous regions; the bodies and services of the direct and indirect administration of the State; the Bank of Portugal, independent administrative authorities and regulators; and the bodies and services of the autonomous, regional and local administration, including inter-municipal bodies.
The last category carries a timing caveat. Although covered from the outset, local government becomes subject to the regime only on 1 June 2027 (municipalities, their local undertakings and inter-municipal bodies) and on 1 January 2028 (parishes), under Article 8(6) and (7) of Act no. 37-A/2026.
Exclusions — what falls outside the Act
| Exclusion | Reach | Basis |
|---|---|---|
| Reserved acts of lawyers and solicitors | In the exercise of forensic mandate. [The exclusion covers reserved acts and does not exempt every activity of a law firm before public bodies.] | Article 2(3)(a) |
| Activities of social partners | As participants in social concertation, and only in that context. | Article 2(3)(b) |
| Responses to individualised requests and invitations | Direct and individualised requests for information from public bodies, and individualised invitations to public hearings or legislative preparatory work. | Article 2(3)(c) |
| Exercise of procedural rights | Including public procurement procedures, with a view to administrative acts or the conclusion of contracts, to which the transparency rules of the Administrative Procedure Code, the Public Contracts Code and access-to-documents legislation already apply. | Article 2(3)(d) |
| Petitions, complaints and reports | Submitted individually or collectively, without remuneration, within the right to participate in public life. | Article 2(3)(e) |
Mandatory disclosure under Article 5(1)
| Item | What it means in practice for a foreign entity |
|---|---|
| (a) Identification and contacts | Name, corporate object where applicable, professional postal and electronic addresses, telephone, professional email and website. The register covers the legal person, not the trading or brand name — a frequent source of error where a group operates under several brands. |
| (b) Clients, interests and sectors | Where representation is on behalf of third parties. The most sensitive item, requiring careful delimitation against contractual confidentiality obligations, including those governed by foreign law. |
| (c) Governing bodies and share capital | Names of the holders of corporate offices and of the share capital. [For foreign entities, the documentary evidence acceptable in place of a Portuguese commercial registry certificate is not specified in the Act.] |
| (d) Person responsible | The person responsible for the interest representation activity, where one exists. The annexed Code of Conduct additionally requires companies to publicly designate a person responsible for public institutional relations (Annex, Article 4). |
| (e) Annual income from the activity | Requires a documented allocation criterion, particularly where interest representation is ancillary to a broader business. |
| (f) Subsidies and public support | From EU institutions or from national or foreign public bodies, in the most recent closed financial year. Note that support received from non-Portuguese public bodies is expressly covered. |
Duties, incompatibilities and sanctions
Duties (Article 7). Comply with declaratory obligations and accept the public nature of what is declared; ensure accuracy and cooperate with requests for supplementary information; keep the information up to date on your own initiative, within 30 days of the triggering facts (Article 5(4)); submit any professional or sectoral codes of conduct to which you are bound; identify yourself, stating your RTRI registration number, before the office-holders you approach; observe the rules on movement within public buildings; refrain from obtaining preparatory information outside the proper channels; refrain from breaching or inciting breach of the rules; ensure non-discriminatory access to the information you provide, including to all political groups represented in Parliament; and ensure that documents handed over do not contain incomplete or inaccurate elements intended to manipulate or mislead.
Entities professionally representing third-party interests must additionally keep a record of all contractual relationships in that field, which the public body may ask to see before a contact takes place (Article 7(2)).
Hearings (Article 8). Entities subject to registration must appear in the RTRI before being granted a hearing or taking part in hearings convened by public bodies. Procedural steps under the Administrative Procedure Code and the Public Contracts Code are carved out (Article 8(2)).
Incompatibilities (Article 12). A three-year cooling-off period applies to holders of political and senior public office, and to staff and members of their private offices, in respect of the legal person, ministry or body in which they served. Representation on behalf of third parties is incompatible with holding sovereign office, political or senior public office, office in an independent administrative authority or regulator, or office in a ministerial private office. Those professionally engaged in interest-representation intermediation must adopt conflict-of-interest prevention measures (Article 12(3)).
Sanctions (Article 11). Following an investigative procedure with defence guarantees, conducted by the RTRI's management body: suspension, in whole or in part, from the register or from the possibility of establishing institutional contacts, for up to two years; access restrictions for the individuals who acted on the entity's behalf; and exclusion from public consultations, also for up to two years. Decisions are published and may be challenged before the administrative courts. Carrying out the activity without prior registration, or providing false information, is reported to the Public Prosecution Service (Article 11(6)). The sanctions regime enters into force on 1 June 2027.
Talk to us
Tell us about your situation and we will reply with the shortest path to compliance.
Request a Compliance Assessment
Tel.: (+351) 285 107 010 · info@representacaodeinteresses.com