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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

Solutions

Organised by the difficulties foreign organisations actually face

Each block starts from something we hear from counsel and compliance officers outside Portugal.

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 Act no. 37-A/2026 established the governance of the RTRI, created its Management Board, repealed Article 19 of Act no. 5-A/2026 and replaced the transitional regime with a staggered timetable. English-language commentary published before that date — including the earlier version of this website — is out of date.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

Difficulties and answers

«We are not established in Portugal — does this apply to us?»

It may well. The Act applies to private entities, national or foreign, that carry out legitimate interest representation before Portuguese public bodies (Article 1(1)). Place of establishment is not the test; the activity is.

«We assumed this was needed to bid for Portuguese contracts»

It is not. Public procurement is excluded by Article 2(3)(d) and registration confers no advantage (Article 6(3)). But that does not settle whether you are covered — only that this is not the reason. See the boundary.

«Which legal person has to register — the parent or the subsidiary?»

Whichever legal person actually carries out the activity. Groups operating in Portugal under a brand rather than a registered company name frequently get this wrong, and the register covers the legal person, not the brand.

«Our contracts are governed by foreign law and are confidential»

Disclosure of clients and interests represented is mandatory where representation is on behalf of third parties (Article 5(1)(b)). The work lies in delimiting the perimeter of that duty against confidentiality obligations, whatever law governs them.

«We already have a global lobbying compliance framework»

Then the sensible route is extension, not duplication. Most of what the Portuguese regime requires maps onto an EU Transparency Register filing; what does not map is the part worth working on.

«Nobody on our team reads Portuguese»

The RTRI operates within the Assembly of the Republic and its working language is Portuguese. We work in English and handle the Portuguese-language interface.

Talk to us

Tell us about your situation and we will reply with the shortest path to compliance.

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Tel.: (+351) 285 107 010 · info@representacaodeinteresses.com