The new Lobbying Law

First Regulation on Interest Representation Approved in Portugal, Entering into Force in July 2026. Find out what changes for your company.

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First Regulation on Interest Representation Approved in Portugal, Entering into Force in July 2026. Find out what changes for your company.

On 28 January 2026, Law no. 5-A/2026 was published, establishing, for the first time in Portugal, a general transparency framework applicable to the legitimate representation of interests, commonly referred to as lobbying. This statute represents a historic milestone in the Portuguese legal system, aligning the country with European best practices on transparency and integrity in the relationship between public authorities and private entities.

The new law, which will enter into force 180 days after its publication (July 2026), introduces a set of new obligations and duties that require timely preparation by companies, consultancies, law firms and other organisations that interact with public decision-makers.

What is “Legitimate Representation of Interests”?

The law defines lobbying as any activity aimed at influencing, directly or indirectly, public policies, legislation, regulations, administrative acts or public contracts. This includes contacts by any means, the submission of documents, the organisation of events, and participation in public consultations during the preparatory stages of initiatives.

Key Points of the New Law

Mandatory Register (RTRI)
Creation of the Transparency Register for Interest Representation, a free and public register managed by the Portuguese Parliament. Registration is mandatory in order to hold meetings or participate in hearings with public authorities.

Code of Conduct
Establishment of a binding code of conduct imposing duties of transparency, integrity and honesty. Representatives must identify themselves, declare the interests they represent, and refrain from obtaining information through improper means.

Cooling-off Period
Introduction of a three-year cooling-off period during which former political office holders, senior public officials and cabinet members may not professionally engage in lobbying activities before the entity where they previously served.

Legislative Footprint
Public entities will be required to create a “legislative footprint”, recording and disclosing interactions with interest representatives during the preparatory phase of legislative or regulatory initiatives, thus ensuring traceability of the decision-making process.

Incompatibilities
Holding political office, or performing functions within regulatory authorities or independent administrative bodies, is considered incompatible with engaging in interest representation activities on behalf of third parties.

Who Does It Apply To?

The framework applies to a wide range of entities, including companies from all sectors, communication and public affairs consultancies, law firms (except for activities strictly related to legal representation in court), business and sectoral associations, non-governmental organisations, and other entities seeking to influence public decision-making.

How to Prepare

The entry into force of the Lobbying Law requires a proactive approach. Companies and organisations should begin to:

• Assess their activities: identify which interactions with public entities fall within the scope of the new framework.

• Define responsibilities: appoint an internal officer responsible for institutional relations and compliance with the new obligations.

• Create internal policies: develop or adapt internal codes of conduct, particularly regarding gifts and hospitality.

• Train teams: ensure that all employees who interact with the public sector are aware of the new rules.

• Prepare registration: gather the necessary information to register with the RTRI as soon as it becomes operational.

Conclusion

The new Lobbying Law is not intended to hinder relations between the private sector and public decision-makers, but rather to enhance their value and transparency. Adapting to this new framework is essential to ensure legal compliance, mitigate reputational risks, and strengthen the legitimacy of interest representation before political and administrative authorities.

Our firm is closely monitoring the implementation of this new regime and remains fully available to assist your company with the interpretation and application of the new law.

#LobbyingLaw #Transparency #Compliance #Law #Portugal #LegalServices #GlobalLawyers #LegalAdvisory

This legal alert is of a general nature and does not replace the need to seek specialised legal advice for your specific case.

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