Framework
The Portuguese interest-representation regime, in outline
What the register is, who must join it, what must be declared, what changes once registered and what happens to those who do not register.
rtri.pt is a private registration-support service operated by Audiqcer, Lda. It is not the official register. The RTRI operates within the Assembly of the Republic and registration is public and free of charge (Articles 4 and 13 of Act no. 5-A/2026).
Nature of the register
The RTRI is a single, publicly accessible and free register operating within the Assembly of the Republic (Article 13(1) of Act no. 5-A/2026). It is made freely available through the Assembly's portal in machine-readable, searchable and open data format, with personal data safeguarded under the General Data Protection Regulation (Article 4(4)).
This matters before anything else: what is declared becomes public. The register is designed for public scrutiny, so that any citizen can see who seeks to influence public decisions, on whose behalf and with what resources. Preparing the information to be declared therefore deserves the same care as a document intended for publication.
The register is managed by the RTRI Management Board, an autonomous body of three individuals of recognised standing who are independent in the exercise of their duties vis-à-vis the Assembly of the Republic (Articles 2 and 3 of Act no. 37-A/2026). Its members take office on 1 January 2027 and are competent for registration, cancellation and the imposition of sanctions.
What falls outside the Act
Under Article 2(3) of Act no. 5-A/2026, the following are not covered: acts reserved to lawyers and solicitors in the exercise of forensic mandate; the activities of social partners within social concertation and only in that context; responses to direct and individualised requests for information from public bodies, and individualised invitations to hearings or to legislative preparatory work; the exercise of procedural rights under administrative procedure legislation, including public procurement procedures, with a view to administrative acts or the conclusion of contracts; and the exercise of the right of petition and the submission of complaints or reports without remuneration.
The fourth exclusion is the one that most often causes confusion among foreign entities doing business with the Portuguese State. A dedicated page addresses it.
Mandatory content of the register
| Item (Article 5(1)) | In practice |
|---|---|
| (a) Identification and contacts | Name, corporate object where applicable, professional postal and electronic addresses, telephone, professional email and website. The register covers the legal person, not the trading name. |
| (b) Clients and interests represented | List of clients, interests represented and sectors of activity, where representation is carried out on behalf of third parties. |
| (c) Governing bodies and share capital | Names of the holders of corporate offices and of the share capital. |
| (d) Person responsible | Name of the person responsible for the interest-representation activity, where one exists. |
| (e) Annual income | Income derived from the interest-representation activity, which presupposes a documented allocation criterion. |
| (f) Subsidies and support | Subsidies or financial support received from EU institutions or from national or foreign public bodies in the most recent closed financial year. |
Duties, incompatibilities and sanctions
Registered entities must comply with their declaratory obligations and accept the public nature of what they declare; keep the information accurate and up to date, updating it within 30 days of the triggering facts (Article 5(4)); identify themselves, stating their RTRI registration number, before the office-holders they approach (Article 7(1)(e)); and refrain from obtaining information outside the proper channels. Those professionally representing third-party interests must additionally keep a record of all contractual relationships in that field (Article 7(2)).
Holders of political office and senior public office, as well as staff and members of their offices, may not carry out interest-representation activities before the legal person, ministry or body in which they served, for three years after leaving office (Article 12(1)).
Breach of duties may lead to suspension from the register or from institutional contacts for up to two years, access restrictions for the individuals involved and exclusion from public consultations (Article 11(1)). Carrying out the activity without prior registration, or providing false information, is reported to the Public Prosecution Service (Article 11(6)). This sanctions regime enters into force on 1 June 2027 (Article 8(8) of Act no. 37-A/2026).
Talk to us
Tell us who you are and what interests you represent. We will reply with the shortest path to compliance.