Compliance Programme Extension — Portugal Chapter

Identification

Compliance Programme Extension — Portugal Chapter: the adaptation of an existing EU or global public affairs compliance programme to the requirements of Law No. 5-A/2026 of 28 January (Lei n.º 5-A/2026, de 28 de janeiro), Portugal's regime on legitimate interest representation (representação legítima de interesses).

Target audience

Multinational companies, international consultancies and European associations that already maintain transparency policies, registers of interactions and conduct rules — typically anchored in Brussels practice — and need those arrangements to cover Portugal without building a parallel system.

Regulatory basis

The Portugal chapter addresses the requirements that are specific to the Portuguese regime: registration content and 30-day updates (Article 5(1) and 5(4)); the duty to identify oneself with the RTRI registration number before the office-holders addressed, and the record of contractual relationships for professional third-party representatives (Article 7(1) and 7(2)); prior registration as a condition for audiences and the quarterly and monthly publication of meetings (Article 8(1), 8(3) and 8(4)); the legislative footprint (pegada legislativa) mechanism (Article 10); the sanctions regime, with suspensions of up to 2 years and communication to the Public Prosecution Service (Article 11); the 3-year cooling-off period (Article 12(1)); and the Code of Conduct (Código de Conduta) annexed to the law (Article 15). [A detailed mapping against the EU Transparency Register is to be validated against the official sources before publication.]

Scope and deliverables

We review your existing policies, procedures and registers; identify the gaps against the Portuguese regime; and design the Portugal chapter that closes them. Deliverables include a gap-analysis report in English; a Portugal annex to your public affairs policy; operating procedures for meeting logging, disclosure reconciliation and 30-day updates; a responsibility matrix assigning each Portuguese obligation to a named owner; and an implementation plan with training touchpoints.

Methodology

Three phases: documentary gap analysis of the existing programme; design of the Portugal chapter with your compliance function; and implementation support, including a briefing for the teams that will operate the new procedures. Work is performed remotely with our Lisbon and Brussels teams.

Indicative duration

Typically four to eight weeks, depending on the maturity and documentation of the existing programme.

Indicative investment

[Fees to be confirmed — each engagement is scoped and priced on proposal.]

English renderings of legal concepts on this page 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.