Portugal’s Anti-Corruption Trajectory

Portugal is undergoing an intense period of reassessing 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 cases 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 transparency proposals), but persistent weaknesses in others (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 Portugal 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 Portugal’s framework ‒ especially regarding prevention at the central government level, transparency in procurement and lobbying regulation ‒ and recommended 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-ordination. The agenda is explicitly framed as complementary to the forthcoming National Anti-Corruption Strategy (planned to succeed the 2020–2024 strategy). It prioritises deliverables, such as improved whistle-blower protections, stronger rules for public procurement transparency, and steps to regulate lobbying 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 education 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 administration 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 government members and staff, in line with GRECO recommendations.
• Whistle-blower channel: The government will implement a unified whistle-blower channel, accessible via the Government Portal, ensuring the integrity 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 Administration Action Plan (2024-27): The government will actively monitor the implementation of this plan, which promotes transparency, citizen empowerment, anti-corruption, and the use of new technologies in public administration. Special attention will be given to the commitment to disseminate and provide training on the General Regime for Corruption Prevention (RGPC).
• Proactive disclosure of administrative documents and data: the government will further advance the “open government” principle by proactively making administrative documents and data available to the public, including legal frameworks, citizens’ rights and obligations, procedural guides, updated price tables, and contact forms for complaints and suggestions.

Education

• Promotion of integrity culture: the plan emphasises the role of education for younger generations and training for public decision-makers in fostering a culture of integrity and civic responsibility, protecting the public sector from corrupt practices.

Repression

• Strengthening repressive measures: the plan proposes measures to increase the effectiveness of criminal prosecution, ensure faster judicial processes, and guarantee effective punishment for corruption crimes, reinforcing the principle that corruption does not pay.

Legislative Focus: Procurement, Lobbying and Whistle-Blowing

In terms of legal reform, several fronts have been particularly active, as set out below.

Public procurement

Public procurement has been a recurrent source of corruption risk in Portugal (as in many EU countries). Reforms have concentrated on digitalising procurement processes, adopting stricter reporting rules and improving the transparency of contract awards and subcontracting chains. The EU and OECD have repeatedly signalled that procurement transparency remains a core area where Portugal must improve to reduce opportunities for favouritism and bid-rigging.

Lobbying and transparency

From 2024 onwards, Portugal’s anti-corruption agenda becomes increasingly explicit and operational, moving from general integrity commitments towards concrete transparency instruments for policymaking and influence activities. Programmatic policy anchors call for regulation of lobbying, a governmental legislative footprint, and reforms that leverage digitalisation to reduce bureaucratic opacity. In parallel, sectoral authorities have strengthened whistle-blowing channels and institutional integrity systems. EU-level requirements on transparency and accountability ‒ especially those tied to the use of EU funds and digital regulation ‒ continue to shape national priorities.

The major policy statement for the period is the commitment to regulate lobbying and establish a legislative footprint. The national planning instrument explicitly calls for:

• regulating the activity of influence upon public decision-makers, including concepts, principles, procedures, and sanctions, with a mandatory public registry of lobbyists and represented entities; and
• implementing the government’s legislative footprint, publishing accessible information on the stages of executive legislative and regulatory processes.

These commitments are recorded in the national Major Options for 2024–2028, under the transparency and anti-corruption policy axis.

For practitioners, this signals a decisive shift towards codified transparency obligations for influence activities and policy formation, with implications for compliance frameworks, record-keeping, and public reporting.

Whistle-blower protection

Strengthening whistle-blower protection has been a policy priority because protected reporting is crucial to uncovering corruption in sectors where audits or media scrutiny are weak. Legislative advances have aimed at better legal protection for reporters inside public and private organisations, secure channels and guarantees against retaliation, aligning domestic law with EU directives on whistle-blower protection.

Detecting and deterring corruption relies on robust reporting mechanisms. Sectoral authorities have expanded whistle-blowing channels, as detailed below.

• The competition authority (AdC) maintains external and internal whistle-blowing systems, with a confidential, independent external channel and an internal reporting mechanism designed to protect whistle-blowers from retaliation.
• Digitalisation of case management improves auditability and the integrity of enforcement operations. These channels support anti-corruption by facilitating early detection of misconduct across markets and public procurement environments.

AML-Related Preventive Registries

Preventing corruption often overlaps with AML controls. Portuguese authorities have pursued consultations and regulatory measures for registries of professional service providers to companies, reinforcing identification, oversight, and preventive mechanisms against illicit finance that co-occur with corruption. While the referenced consultation precedes 2024, its regulatory rationale remains pertinent to the development of registries and compliance frameworks expected in 2024–2028.

As lobbying regulation introduces registries of influence, parallel AML-style registries can synergise, enabling comprehensive transparency across high-risk interfaces.

Enforcement, Prosecution and High-Profile Cases

Legal reforms matter only if enforcement follows. Portugal’s criminal justice system has the capacity to pursue complex corruption cases, and prosecutors have pursued several notable investigations in recent years. High-profile political and ethical scandals ‒ some involving senior political figures or business interests linked to politics ‒ have put enforcement under the spotlight and generated intense public debate about impartiality and the political will to prosecute. Media coverage of such scandals has, in turn, contributed to the decline in public trust measured by international indices.

A central challenge remains the length and complexity of investigations. Corruption cases often involve cross-border elements, complex financial engineering and long trails of subcontracting which demand specialised forensic accounting and international co-operation. Portugal has signalled stronger co-operation with EU and international partners, but the technical and resource constraints in public prosecution persist, and swift, high-quality case handling remains a bottleneck.

Prevention Through Transparency and Open Data

A conspicuous development is the increasing use of digital transparency tools and open data to pre-empt corruption. Digital portals for procurement, registers of public officials’ interests, and (proposed) registries of lobbying and beneficial ownership are intended to make it harder for corruption to hide in the shadows. Civil society organisations and investigative journalists have also used open data to trace suspicious deals and push for accountability.

However, open data is not a silver bullet: its impact depends on data quality, user-friendliness and the legal framework that allows society and oversight bodies to act on the information. The “last mile” problem ‒ turning published datasets into investigations and policy changes ‒ remains an implementation challenge.

International Co-operation and Standards

Portugal’s trajectory is shaped by obligations and peer reviews from international organisations: OECD, GRECO (Council of Europe), the EU and bilateral partners. These actors provide comparative diagnostics, best-practice templates and pressure to align with international anti-bribery and integrity standards. Recent OECD country notes and GRECO follow-ups have both praised progress in some technical areas and urged stronger implementation and supervision. That external scrutiny is a major driver of the domestic policy agenda: the government’s Anti-Corruption Agenda and planned strategy explicitly reference OECD and GRECO recommendations.

Persistent Gaps and Political Economic Constraints

Despite measurable progress, a number of structural challenges persist. Public procurement complexity and subcontracting opacity create opportunities for preferential treatment and hidden value extraction. 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 cultural 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 Portugal 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 procurement 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, legislative-footprint obligations and strong sanctions for non-compliance; ensure independent monitoring of compliance.
• Boost prosecution capacity by investing in specialised financial-forensics teams, cross-border co-operation agreements and training for judges and prosecutors on complex economic crime.
• Protect and operationalise whistle-blowing channels 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 journalism and partnerships with oversight agencies to convert open data into cases and public policy changes.

Portugal is at an inflection point. Portugal has reinforced its anti-corruption policy architecture through programmatic priorities, institutional integrity measures, 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 accountability 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 practices, 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 sustained improvement in public trust.