Portugal’s lobbying law: an overview
Law no. 5-A/2026, of 28 January, came into force on 27 July 2026. For the first time, Portugal regulates interest representation before public entities and creates a mandatory register for those who carry it out: the Transparency Register of Interest Representation (RTRI), managed by the Assembleia da República.
Scope
The law applies to any entity, Portuguese or foreign, that seeks to influence public policy, legislation, regulations, administrative acts or public contracts, whether acting on its own behalf or for third parties. Interest representation covers contact in any form: meetings, correspondence, events or participation in legislative consultations.
On the public side, the scope runs from the Presidency and Parliament to the Government, regulators, the Bank of Portugal and local authorities.
The following do not count as interest representation under this law:
- acts reserved to lawyers and solicitadores in the exercise of their forensic mandate;
- the activity of social partners within social concertation, and only in that setting;
- responses to individualised information requests or invitations from public entities;
- the exercise of rights within administrative and public procurement procedures, which already have their own transparency rules;
- the right of petition and the filing of complaints without remuneration.
In practice, a licensing procedure, a clarification request to the Portuguese tax authority or a residency application processed under the Administrative Procedure Code remains outside this regime.
Registration in the RTRI is public and free of charge. It makes accessible, among other data, the clients and interests represented, the holders of corporate offices and share capital, the annual income from the activity and any public funding received. Once the system is fully operational, unregistered entities cannot be granted meetings by the public entities covered.
Breaching the duties set out in the law can lead to suspension from the register, restrictions on institutional contacts or exclusion from public consultations, for periods of up to two years. Carrying out the activity without prior registration is reported to the Public Prosecutor’s Office.
The law also sets a cooling-off period: former holders of political office and senior public positions may not represent interests before the entity where they served for the following three years.
Key dates
27 July 2026: the law comes into force. Until the RTRI is up and running, public entities must record and publish the meetings they grant.
1 January 2027: the RTRI becomes fully operational. Those already active in the field then have 60 days to register.
1 June 2027: the sanctions regime takes effect, and the law extends to municipalities and intermunicipal entities.
1 January 2028: extension to parish councils.
Our comments
For companies, associations and international clients engaging with Portuguese institutions, the RTRI becomes the formal channel for that dialogue, at the cost of considerable public exposure. Before 2027, it is worth mapping existing institutional contacts and checking whether they fall within the regime or under one of the exclusions. The line between a forensic mandate and interest representation, in particular, will need case-by-case analysis.
For questions on the new rules, contact our team.
Disclaimer
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