Law no. 5-A/2026, of 28 January, created the Transparency Register for Interest Representation. Twenty-one articles, an annexed code of conduct, and one simple idea behind all of it: whoever talks to the State will have a name, an address and a known client.
It entered into force on 27 July 2026. The next day, the Assembly of the Republic published another law postponing the parts with teeth.
I. What the law calls interest representation
The definition sits in Article 2 and is deliberately broad. Legitimate interest representation is any activity meant to influence, directly or indirectly, public policy, legislative and regulatory acts, administrative acts, public contracts, or simply the decision-making process of a public body. In your own name, on behalf of a group, or for third parties.
The law gives examples: contacts with public bodies in any form, sending and circulating correspondence and position papers, organising events, meetings and conferences, taking part in consultations on legislative proposals.
In any form is the phrase that matters. It covers the scheduled meeting, but also the phone call, the email and the coffee.
On the other side, the list in Article 3 leaves little out: the Presidency of the Republic, the Assembly of the Republic, the Government, the self-governing bodies of the autonomous regions, the Representatives of the Republic, the State's direct and indirect administration, the Bank of Portugal, regulators and independent administrative entities, autonomous, regional and local administration, inter-municipal entities.
II. Who is left out
Paragraph 3 of the same article opens five exits.
Acts exclusive to lawyers and solicitors in the exercise of a forensic mandate. The action of trade unions and employer or business associations in social dialogue, and only within that framework. Responses to direct and individualised requests for information, or to invitations to hearings and preparatory work. The exercise of procedural rights in administrative proceedings, including public procurement, where transparency rules already exist. And the right of petition, along with complaints and denunciations.
The last one deserves a second look. The exclusion only holds where the petition or complaint is made without any remuneration. Written by someone who is paid to write it, it falls back inside the law.
And Article 1 holds a safeguard worth remembering: this law does not override the right of petition, the right to take part in public life, the right of assembly or freedom of expression. It regulates a professional activity, and leaves out the citizen who writes to their MP.
III. Who has to register
This is where a hurried reading trips up.
Article 13 sorts registrants into five categories. The second is the expected one: those acting professionally as representatives of the legitimate interests of third parties, whether as a main or ancillary activity. The public affairs consultancy, the institutional relations office, the professional working alone.
The third is the one that catches half the market off guard: business interest representatives, that is, legal persons defending their own interests in their own name. You do not have to sell the service to anyone. It is enough for the company to talk to the regulator about the rule that will affect it.
Three remain. Private social partners and bodies whose consultation is constitutionally or legally mandatory, registered automatically and ex officio. Institutional representatives of collective interests. And a residual category for whatever does not fit the rest.
And one rule closes the most obvious escape route. Entities whose representation is carried out through an intermediary must register all the same. The name of whoever sends them still appears.
IV. The three dates that replaced one
Law no. 5-A/2026 entered into force on 27 July 2026, one hundred and eighty days after publication. It stood alone for a single day.
On 28 July came Law no. 37-A/2026, in force since the 29th. It gave the register the governance structure it lacked, revoked Article 19 of the earlier law and rewrote its transitional regime.
The result is a stepped calendar. The RTRI only comes into full operation on 1 January 2027, when the three members of the Management Council take office. The sanctions framework only takes effect on 1 June 2027. Municipalities, their local companies and inter-municipal entities come in on that same date. Parishes, only on 1 January 2028.
Meanwhile, once the Assembly of the Republic's notice is published in the Diário da República, provisional registration is already possible. The Assembly expected to publish it in September 2026. Which is to say, now.
V. The sixty days
The deadline that gives this article its title is in paragraph 4 of Article 8 of Law no. 37-A/2026. Those already professionally engaged in representing the legitimate interests of third parties when the law entered into force have sixty days, counted from the register's full entry into operation, to register definitively.
The Assembly of the Republic has already done the arithmetic: it starts on 1 January 2027 and ends on 2 March 2027.
Anyone who read July's newspapers and concluded they were already in breach read the wrong date. So did anyone who concluded there are years to go. The clock is not running today, but the provisional register opens this month.
VI. No registration, no hearing
Of all the rules in this law, this is the one that changes daily life.
Paragraph 1 of Article 8 says that entities subject to registration must appear in the RTRI before being granted a hearing or taking part in hearings held by public bodies. Registration works as a condition of entry, and has to be in place before the door opens.
Excluded are the hearings and procedural steps under the Administrative Procedure Code, the Public Contracts Code and other administrative legislation, where the entity is an interested or counter-interested party. There the usual regime still applies.
The other side of the table writes too. Public bodies publish on their websites, at least every three months, the meetings they held with registered entities, with date and subject matter. The Assembly of the Republic and its bodies do so in the following month.
And Article 10 adds the legislative footprint: at the end of each legislative procedure, every consultation and interaction from the preparatory phase must be identified. Where secrecy or confidentiality justify it, disclosure can wait until the procedure closes.
VII. What gets recorded
Article 5 is the part of the law that some will find hardest.
The entity's name and corporate purpose, professional addresses and contacts. The holders of its corporate bodies and share capital. The person responsible for the activity, where there is one. Clients, interests represented and the sectors in which representation happens, where the work is for third parties. Annual income from the activity. And any grants or financial support received from European Union institutions or from public entities, national or foreign, in the last closed financial year.
Any change must be reported within thirty days. Accuracy is the responsibility of whoever declares, not of the register. And registration can be cancelled on request, when the activity ends, or for breach of duties.
Put another way: the client and the fee end up on the same line, in plain view of anyone who cares to look.
VIII. Ten duties, and a book of contracts
You often read that Article 7 imposes five duties. It imposes ten.
Meeting the declaratory obligations and accepting that what is declared is public. Ensuring the information is correct and cooperating when more is requested. Keeping it current without waiting to be asked. Sending the register any codes of conduct you are bound by. Always identifying yourself, with your registration number, stating clearly who you are and what you have come for.
Observing the rules for moving around public buildings. Not fetching preparatory documents outside the proper channels for access to public information. Not breaking the rules, nor inviting public bodies, their officeholders or staff to break them. Giving the same information, without discrimination, to every interested party and to every political force with a seat in parliament. And not handing over documents with omissions or inaccuracies designed to mislead the decision-maker.
There is a further duty outside that list which usually goes unnoticed. Anyone professionally representing third-party interests must keep a record of every contractual relationship in that activity. And the public body they want to talk to may ask to see it.
Article 15 closes the set with the Code of Conduct annexed to the law, binding on both sides of the table.
IX. The incompatibilities and the three years
Article 12 deals with what everyone recognises on sight: the revolving door.
Anyone who held political or senior public office, and likewise the officials and members of their support offices, is barred for three years from representing interests before the ministry, body or legal person where they served. Three years counted from the day they left.
And while you are inside, you do not do both. Representing third-party interests is incompatible with holding a sovereign body office, a political office or a senior public office, with functions in an independent administrative entity or regulator, and with working in an office supporting those officeholders.
Those who make a profession of it must also prevent conflicts of interest, avoiding simultaneous or successive representations that undermine independence, impartiality and objectivity, or distort the information given to public bodies.
Article 6 handles the rest in one dry sentence: access to public buildings is on strictly equal terms with other citizens, and no one may invoke having held public office to get in. Registration, the same provision says, grants no privileged access to decision-makers. It exists only so that we know who walked in.
X. When the law is breached
The sanctions regime in this law does without fines and reaches for what hurts more.
After an investigative procedure with guarantees of defence, conducted by the register's management body, breaching the duties can cost the total or partial suspension of the registration, or of the ability to establish institutional contacts, for up to two years. It can cost access restrictions for the individuals who acted for the entity. It can cost exclusion from public consultation procedures, also for up to two years.
Decisions are published on the Assembly of the Republic's portal and on that of the public body concerned, and may be challenged before the administrative courts. Suspension does not apply to those registered automatically and ex officio.
And then there is a consequence that is no longer administrative. Carrying out the activity without prior registration, or giving the register false information, is reported to the Public Prosecutor's Office.
One date is worth keeping: this sanctions framework only enters into force on 1 June 2027.
Before January 2027
If your organisation talks to public bodies, and nearly all of any size do, waiting for March 2027 is the worst available strategy.
The work is different, and it is now. Working out which of your contacts fall within the definition in Article 2 and which are saved by the exclusions in paragraph 3. Deciding which Article 13 category you register under. Gathering what Article 5 will ask for, including the uncomfortable part about income and support received. Checking whether anyone in the house is still inside the three years of Article 12. And, if you want to book meetings in January without surprises, registering provisionally as soon as the notice appears.
If you are on the other side, the clock is already running. Since 29 July 2026, public bodies covered by Article 3 must record and publicise the hearings they grant, identifying who was received and what the meeting was about. The regulatory rules defining that procedure must be approved by 30 November 2026. Municipalities, their local companies and inter-municipal entities have until 30 April 2027; parishes, until 30 November 2027. In the autonomous regions the register applies, without prejudice to the regional legislative decree adapting it to the self-governing bodies and the regional administration.
Horacio Baptista Ladera follows this regime closely and supports companies, associations and public bodies in Lisbon, Porto and Funchal in preparing registration and the rules for publicising hearings.
The lobby law entered into force in July 2026. The register that gives it substance opens in January 2027. And the sanction that gives it teeth, only in June.
© 2026 Horacio Baptista Ladera. All rights reserved. Reproduction prohibited without prior authorization.
