Lobbying Law: Publication of the framework on transparency in the representation of interests

The new law broadly defines the concept of legitimate representation of interests, encompassing all activities that seek to directly or indirectly influence the development of public policies, the drafting of legislation, the performance of administrative acts or the conclusion of public contracts. Everything is now subject to a transparent, regulated framework, from formal and informal contacts with public decision-makers, through to the submission of opinions and studies, or the organisation of events and conferences aimed at promoting certain interests.

The following are expressly excluded from the framework’s application: acts performed by lawyers and solicitors in the exercise of their legal mandate, the constitutional right to petition, complaints and reports submitted by citizens, and the activities of social partners in the context of social dialogue.

Entities representing legitimate interests – on their own behalf or on behalf of third parties – are now required to register with the RTRI (“Registo de Transparência da Representação de Interesses” or Transparency of Representation of Interests Register), which operates under the management of the Portuguese Parliament. This register will allow any citizen to know who represents which interests, the income generated by this activity, and what contacts are established with the public authorities.

The Lobbying Law requires public entities to disclose, at least quarterly, all meetings held with representatives of registered interests. It also introduces the Legislative Footprint Mechanism, which requires the disclosure of all consultations and interactions with bodies invested with legislative powers or the right of legislative initiative, held during the preparatory phase.

All registered entities are bound by a Code of Conduct found attached to the law itself, establishing high standards of honesty, rigour and transparency.

Non-compliance may result in cumulative sanctions, including:

• Suspension of registration and of the possibility of establishing institutional contacts – up to 2 years;
• Exclusion from participation in public consultation procedures – up to 2 years;
• Restrictions on access by individuals who have violated duties – up to 2 years.

The exercise of activity without prior registration or the provision of false information is reported to the Public Prosecutor’s Office, without prejudice to other penalties.

• The Lobbying Law enters into force on 27 July 2026, allowing for a 180-day period of preparation and adaptation.
• Until the RTRI comes into operation, all public entities covered must ensure the registration and publication of the hearings granted by them.
• Entities that already engage in professional lobbying must register within 60 days of the RTRI coming into operation. The date of entry into operation will be officially announced by the Parliament and published in the Official Gazette.

Now is the time to review internal procedures, assess whether your organisation is covered by these new requirements, and implement appropriate compliance programmes.