Anti-Corruption 2026

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

Political influence, such as informal networks and the movement of officials into private roles (and vice versa), continues to be a risk factor, especially where disclosure and cooling-off rules are weak or poorly enforced. Addressing these issues therefore requires not only legal change but also durable administrative and cul - tural shifts, such as stronger internal controls, better procurement design, sustained civil society oversight and depoliticised enforcement. Practical Recommendations and Key Steps Looking ahead, the most productive steps for Por - tugal involve both technical and political measures. • Prioritise measurable milestones in the 2025–2028 National Anti-Corruption Strategy: the strategy should include clear KPIs (eg, percent of procure - ment contracts published in machine-readable form, average time from complaint to investigation, number of whistle-blower reports resolved) and regular progress reports. • Strengthen procurement transparency through mandatory, standardised e-procurement portals, improved access to subcontracting chains and routine red-flag analytics to detect irregular bidding patterns. • Finalise and implement lobbying and political- finance reforms with enforceable registers, legisla - tive-footprint obligations and strong sanctions for non-compliance; ensure independent monitoring of compliance. • Boost prosecution capacity by investing in special - ised financial-forensics teams, cross-border co- operation agreements and training for judges and prosecutors on complex economic crime.

• Protect and operationalise whistle-blowing chan - nels with guaranteed anonymity, legal safeguards and a clear route from report to investigation. • Empower civil society and media through legal access to data, support for investigative journal - ism and partnerships with oversight agencies to convert open data into cases and public policy changes. Portugal is at an inflection point. Portugal has rein - forced its anti-corruption policy architecture through programmatic priorities, institutional integrity meas - ures, expansion of whistle-blowing channels, and explicit 2024–2028 commitments to regulate lobbying and establish a legislative footprint. EU frameworks around funding transparency, digital services, and AML continue to shape national priorities, particularly in areas where Portugal must demonstrate account - ability for the use of public and EU resources. The trajectory suggests a consolidation phase in which policies will be operationalised via concrete regulations, registries, and compliance obligations across public and private sectors. For practitioners, the direction is clear: embed robust integrity practic - es, prepare for transparency obligations in influence activities, maintain whistle-blower protections, and align with EU-informed governance standards. These steps will be crucial in translating policy commitments into tangible reductions in corruption risk and sus - tained improvement in public trust.

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