Anti-Corruption 2026

PORTUGAL Trends and Developments Contributed by: Ana Reis Mota, Rogério Alves & Associados

Portugal’s Anti-Corruption Trajectory Portugal is undergoing an intense period of reassess - ing how to prevent, detect and punish corruption. Over the past three to four years, a pattern has emerged: on one hand, institutional and regulatory reforms have been proposed and, in several cases, implemented; on the other, public perception and high-visibility cas - es have intensified pressure for rapid improvements. The result is a mixed landscape: concrete technical progress in certain areas (political finance checks, a government anti-corruption agenda, new transpar - ency proposals), but persistent weaknesses in oth - ers (public procurement, enforcement speed, political culture). These are going to shape Portuguese anti- corruption policy for the immediate future. Perception v Reform Two complementary facts help explain the current policy push. First, international indicators show Por - tugal performing reasonably well compared with many jurisdictions but slipping in recent rankings; this has prompted political and media pressure for reform. The Transparency International Corruption Perceptions Index (CPI) places Portugal in the upper half of ranked countries, but it also recorded a decline in Portugal’s score in the most recent CPI, signalling that public perceptions of progress has stalled or reversed. Second, multilateral bodies (notably the OECD and the Council of Europe’s anti-corruption monitoring mechanisms) have publicly highlighted gaps in Por - tugal’s framework ‒ especially regarding prevention at the central government level, transparency in pro - curement and lobbying regulation ‒ and recommend - ed concrete steps. These external assessments have dovetailed with domestic pressure to adopt an “anti- corruption agenda” and to prepare a renewed national strategy. The Anti-Corruption Agenda and Strategic Planning A landmark development was the government’s approval (in mid-2024) of a formal Anti-Corruption Agenda: a compact set of measures intended to jump-start reform across multiple fronts ‒ legislation, enforcement, transparency and institutional co-ordi - nation. The agenda is explicitly framed as comple -

mentary to the forthcoming National Anti-Corruption Strategy (planned to succeed the 2020–2024 strat - egy). It prioritises deliverables, such as improved whistle-blower protections, stronger rules for public procurement transparency, and steps to regulate lob - bying and political finance more tightly. The agenda is of political and technical importance: it packages measures that courts, prosecutors and administrative agencies can implement in parallel, while indicating to international partners Portugal’s willingness to act. The plan prioritises prevention, transparency, and the strengthening of public policies, as well as educa - tion and the effectiveness of repressive measures to ensure that corruption does not pay off. Main measures Prevention • Adoption of Codes of Conduct: The government has approved a Code of Conduct applicable to government members, senior public administra - tion officials, and managers of public institutes and companies. The Code serves as an ethical guide for public action and promotes good governance practices. • Risk Prevention Plan: within 180 days of the Code of Conduct’s publication, the government will adopt a risk prevention plan to reduce conflicts of interest and promote transparency among gov - ernment members and staff, in line with GRECO recommendations. • Whistle-blower channel: The government will implement a unified whistle-blower channel, acces - sible via the Government Portal, ensuring the integ - rity and confidentiality of reports. Transparency and public administration • Mandatory judicial sales via e-auction platform: amendments to the Insolvency and Corporate Recovery Code and the Civil Procedure Code will make judicial sales through the e-leilões platform mandatory, enhancing transparency in asset sales. • Active monitoring of the III National Open Adminis - tration Action Plan (2024-27): The government will actively monitor the implementation of this plan, which promotes transparency, citizen empower - ment, anti-corruption, and the use of new technol - ogies in public administration. Special attention will

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