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The introduction of Portugal’s new interest representation regime brings additional transparency requirements to the relationship between businesses, associations, consultants and public bodies, requiring organisations to reconsider how they identify, document and manage their institutional contacts.
In an opinion article, Francisco Pimenta, Senior Associate in the Compliance & Regulatory practice at CCA Law Firm, examines the impact of the new rules governing lobbying activities and the main challenges organisations will face when implementing them.
The new regime does not prevent businesses from participating in public decision-making processes, but requires greater clarity as to who is making contact, whose interests are being represented, the matters being discussed and the purpose of the interaction. In this context, Francisco Pimenta notes that “The relevant question is no longer ‘can we have this meeting?’ but ‘can we describe its subject matter, the interests involved and its purpose without asking the public to take it on trust?’ - transparency means being able to withstand the second question.”
The article also considers the distinction between interest representation and contacts excluded from the regime, the protection of confidential information and trade secrets, the new sanctions framework and the timetable for the implementation of the different obligations.
With the Interest Representation Transparency Register due to become fully operational on 1 January 2027 and the sanctions framework taking effect from 1 June 2027, the article highlights the importance of using the implementation period to map relevant contacts, define internal responsibilities and establish procedures that enable organisations to demonstrate the purpose and context of their interest representation activities.
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- Observador