The Legal Framework
A condensed guide to Law No. 5-A/2026 of 28 January (Lei n.º 5-A/2026), Portugal's framework on legitimate interest representation (representação legítima de interesses) — in force since 27 July 2026.
Object and definitions
The law lays down transparency rules for the interaction between private entities, Portuguese or foreign, and public entities, and creates the Transparency Register of Interest Representation (Registo de Transparência da Representação de Interesses — RTRI), operating within the Assembleia da República, the Portuguese Parliament (Article 1(1)). Legitimate interest representation means lawful activities aimed at influencing, directly or indirectly, public policies, legislative and regulatory acts, administrative acts or public contracts, and the decision-making of public entities — in one's own name, for specific groups or on behalf of third parties (Article 2(1)).
Included activities range from contacts with public entities in any form to correspondence and position papers, events and meetings, and participation in consultations on legislative proposals (Article 2(2)). Exclusions apply: acts reserved to lawyers and solicitors within the forensic mandate, social concertation, replies to requests from public entities, procedural rights under the CPA and the CCP, and the right of petition without remuneration (Article 2(3)).
Public entities covered
Article 3 lists eight categories of public entities, from the Presidency of the Republic, the Parliament and the Government to the Bank of Portugal, independent administrative entities and regulatory authorities, and the autonomous, regional and local administration, including inter-municipal entities. All eight are described on the Market page.
The RTRI
The RTRI is a single, public, free and open register, available through the Parliament's portal in machine-readable, searchable and open data formats, with personal data safeguarded under the GDPR — Regulation (EU) 2016/679 (Article 4(4)). Registration covers the entity's identification and corporate purpose; clients, interests and sectors where representation is for third parties; corporate bodies and share capital; the responsible person; annual income; and subsidies from European Union institutions or public entities (Article 5(1)). Data must be updated within 30 days (Article 5(4)).
Registrants fall into five categories (Article 13(3)), from private social partners — registered automatically and ex officio (Article 13(4)) — to representatives of third-party, business and collective interests.
Rights and duties of registered entities
Registered entities gain rights — contacting public entities, accessing public buildings under strict equality, being informed of ongoing public consultations (Article 6) — and assume duties: identifying themselves with their RTRI number before the officeholders addressed (Article 7(1)) and, for professional representatives of third-party interests, keeping a record of contractual relationships (Article 7(2)).
Hearings and disclosure
Entities subject to registration must appear in the RTRI before being granted a hearing (audiência) (Article 8(1)). Public entities disclose, at least quarterly, the meetings held with registered entities (Article 8(3)); the Parliament discloses its meetings monthly (Article 8(4)).
Legislative footprint
At the end of the legislative procedure, all consultations and interactions from the preparatory stage must be identified, and public entities must create specific legislative footprint (pegada legislativa) mechanisms (Article 10). Influence becomes traceable — which is why organised internal records matter on both sides.
Sanctions and cooling-off
Breaches of duties may lead to total or partial suspension of registration or of institutional contacts, access limitations for natural persons, and exclusion from public consultation procedures — each for up to 2 years (Article 11(1)). Sanctioning decisions are published on the Parliament's portal (Article 11(2)) and may be challenged before the administrative courts (Article 11(3)). Representation without prior registration, or the provision of false information, is reported to the Public Prosecutor's Office (Article 11(6)).
Holders of political offices and senior public positions, and staff and members of their offices, are barred for 3 years from representing interests before the legal person, ministry or body where they held office (Article 12(1)).
Code of Conduct
The law approves, as an annex forming part of it, a Code of Conduct (Código de Conduta) with 5 articles. Adherence is mandatory for the public entities of Article 3 and for registered representatives (Article 15(1)); public entities may densify its rules in their own codes, notably on gifts and hospitality (Article 15(2)).
Transitional regime and entry into force
Until the RTRI becomes operational, public entities must record and publicise the hearings they grant (Article 19(1)). Entities professionally engaged in representing third-party interests must register within 60 days of the RTRI becoming operational (Article 19(2)). The law entered into force 180 days after publication (Article 21) — that is, on 27 July 2026. [The RTRI operational start date is to be announced by notice of the Assembleia da República — Article 18(3).]
Foreign entities interacting with Portuguese public entities will find an English-language gateway at representacaodeinteresses.com.
From reading the law to implementing it
Understanding the framework is step one; operating under it is the real task.