PORTUGAL Trends and Developments Contributed by: Ana Reis Mota and Lua Mota Santos, Rogério Alves & Associados
ishable by substantial fines. In severe or repeated cases, MENAC can refer the matter to prosecutorial authorities if there is evidence of criminal conduct. MENAC – Portugal’s National Anti-Corruption Agency As noted earlier, MENAC is responsible for overseeing the implementation of the RGPC and making sure that both public and private organisations comply with its rules. While the police and the Public Prosecutor’s Office handle the investigation and prosecution of crimes, MENAC focuses on prevention and compli - ance oversight. MENAC’s work covers three main areas: • Prevention the agency ensures that organisations have robust rules, processes, and internal controls to minimise the risk of corruption before it occurs. • Enforcement MENAC investigates failures to meet RGPC obligations and can impose administrative penalties when necessary. • Compliance monitoring – it regularly reviews the internal preventive systems of organisations, identi - fies weaknesses, and offers recommendations for improvement. A key aspect of MENAC’s mandate is its secure whis - tle-blower channel, which allows employees, con - tractors, and other stakeholders to report suspected corruption or irregularities safely and without fear of retaliation. Although MENAC was formally established some time ago, 2025 marks the year when it became fully opera - tional. It now has a defined organisational structure, clear oversight and investigative powers, and greater independence. Its operational model includes direct coordination with prosecutorial authorities and finan - cial regulators, which enables faster information shar - ing and reduces delays in urgent cases. In 2025, MENAC was also integrated into a broader national anti-corruption strategy, moving away from the previously fragmented approach to enforcement. This centralisation aims to provide a single point of contact for compliance matters, detect systemic vul - nerabilities across sectors, and promote ethical stand -
ards through guidance, training, and practical support for organisations. The Anti-Corruption Agenda In early 2025, the Portuguese government unveiled a structured and long-term anti-corruption strategy covering the period from 2025–30. This plan reflects both domestic political priorities and commitments undertaken at the European and international level, including obligations under EU anti-corruption frame - works and recommendations from bodies such as the Council of Europe’s Group of States against Corrup - tion (GRECO) and the OECD. The 2025–30 programme builds upon legislative reforms implemented in the previous years, most nota - bly the RGPC and the operationalisation of National MENAC. These are now considered the backbone of the national compliance and prevention framework. The government’s vision is that, by 2030, Portugal will have an anti-corruption ecosystem where prevention and enforcement are integrated, public trust is rein - forced, and the cost of engaging in corrupt practices – whether legal, reputational, or operational – is sig - nificantly increased. The plan emphasises not only the repression of offences already committed but also the creation of a culture of integrity within both the public and private sectors. Law No 26/2025 of 19 March Law No 26/2025, of 19 March, introduced targeted yet substantial amendments to both the Portuguese Criminal Code and the Code of Criminal Procedure, reflecting a concerted legislative effort to enhance the protection of public servants and other professionals whose work places them at heightened risk of aggres - sion. The law represents a clear policy shift toward recognising the societal value and vulnerability of cer - tain professions and ensuring that offences commit - ted against these individuals are met with both stricter sanctions and more efficient procedural handling. Regarding the Criminal Code: • Article 132 (Qualified Homicide) – the scope of qualified homicide was broadened to include a wider set of protected victims. In addition to the
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