COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Portugal Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union

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EUROPEAN
COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 922 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in Portugal
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Rule of Law Report
The rule of law situation in the European Union
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1
ABSTRACT
In Portugal, significant steps have been taken to improve the human resources allocated to the
justice system, thanks to new recruitments and legislative changes. The early end of the
legislature had an impact on some reforms, such as those related to the system of case
allocation, the efficiency of complex criminal cases, and access to judgments, which could
not be finalised. The High Council for the Judiciary has called for a reflection on possible
mechanisms to ensure its stability and safeguard its independence. The efficiency of
Administrative and Tax Courts improved in first instance, while serious concerns remain
regarding the disposition time in second instance courts, especially among businesses. The
working conditions and security in court and prosecution premises affect the functioning of
the courts. Changes to the legal aid system were introduced to address the low level of
remuneration of legal aid providers, with the Bar Association calling for further changes.
The National Anti-Corruption Strategy 2020-2024 is still to be evaluated, and a new anti-
corruption strategy is expected to be developed. Steps were taken to improve the resources of
the Anti-Corruption Mechanism (MENAC), and further changes were made to improve its
structure and functioning. New measures were introduced to ensure sufficient resources for
preventing, investigating and prosecuting corruption. While corruption cases remain a
priority, investigation, prosecution and adjudication of high-level corruption cases face
delays. The effective monitoring and verification of asset declarations by the Transparency
Entity improved significantly. Shortcomings in the integrity framework are expected to be
addressed under the new legislature. Despite efforts under the previous legislature, lobbying
remains unregulated. The system of preventive audit over EU-funded projects was amended.
The Media Regulatory Authority continues to carry out its task with reinforced financial
resources. The conclusion of a high-profile case concerning a merger suspension prompted
new proposals and discussions regarding the legal framework on transparency of media
ownership. A new Media Action Plan comprising 30 measures was presented. A concession
contract for public service media has been signed and its financial resources improved
following the updating of the audiovisual tax. The LUSA News Agency is now nearly fully
owned by the state. Some steps were taken to improve working conditions for journalists,
such as the adoption of an action plan for journalists’ safety, while the number of incidents
affecting journalists has decreased.
Due to the early termination of the legislature, it was not possible to finalise the planned
reforms to improve the transparency of law-making. The Office of the Ombudsperson
continues to perform effectively, despite continuing to deal with a high number of complaints
related to administrative delays. Civil society space continues to be considered as open, and
there were further improvements regarding access to financing for civil society organisations.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Portugal has
made:
• Significant progress in stepping up efforts to ensure adequate human resources of the
justice system, in particular regarding judicial clerks, and some further progress in
continuing efforts to improve its efficiency, in particular of Administrative and Tax
Courts.
• Some progress in ensuring the adequacy of the general criminal procedure legislation to
efficiently deal with complex criminal proceedings.
• Significant progress in continuing efforts made to ensure sufficient resources for
preventing, investigating and prosecuting corruption, and some further progress in
ensuring sufficient resources for the new Anti-Corruption Mechanism.
• Significant progress in ensuring the effective monitoring and verification of asset
declarations by the Transparency Entity.
• No progress in finalising the reforms to improve the transparency of law-making,
particularly on the implementation of impact assessment tools.
On this basis, and considering other developments that took place in the period of reference,
and in addition to recalling the relevant commitments made under the Recovery and
Resilience Plan and the relevant country-specific recommendations under the European
Semester, it is recommended to Portugal to:
• Step up efforts to improve the efficiency of the justice system, in particular of
Administrative and Tax Courts.
• Take forward measures to ensure the adequacy of the general criminal procedure
legislation to efficiently deal with complex criminal proceedings.
• Adopt rules on the regulation of lobbying, including the creation of a comprehensive
public lobbying registry.
• Finalise the reforms to improve the transparency of law-making, particularly on the
implementation of impact assessment tools.
3
I. JUSTICE SYSTEM1
Independence
The level of perceived judicial independence in Portugal continues to be average among
the general public and is now low among companies. Overall, 58% of the general
population and 32% of companies perceive the level of independence of courts and judges to
be ‘fairly or very good’ in 20252
. The perceived judicial independence among the general
public has increased in comparison with 2024 (53%) and has significantly increased in
comparison with 2021 (48%). The perceived judicial independence among companies has
significantly decreased in comparison with 2024 (44%) and has decreased in comparison with
2021 (39%).
The High Council for the Judiciary has called for a reflection on possible mechanisms to
ensure its stability and safeguard its independence. The Council continues to call for
changes to the legislative framework governing its organisation and functioning, but no
follow-up has been given so far to its proposals3
. The Council has also initiated discussions
on potential challenges to its institutional stability and independence stemming from the
impact on its composition of the successive dissolutions of Parliament in 2021, 2024, and
2025, which led to the early termination of the four-year terms of office of the seven
members elected by Parliament. The concerns raised include the risks of possible greater
political influence in the Council, as well as the risk of undermining its effectiveness in
supervising and managing the justice system4
. The Council has thus called for a reflection on
possible mechanisms to ensure stability and safeguard its independence, such as minimum
periods of tenure of the members appointed by Parliament5
. To note that the High Council for
the Judiciary and the High Council for Administrative and Tax Courts are not composed by a
net majority of judges elected by their peers, which continues to be raised as a concern by
stakeholders6
. European standards state that not less than half of the members of judicial
councils should be judges chosen by their peers from all levels of the judiciary and with
respect for pluralism inside the judiciary7
.
The legislative process aimed at making the case allocation system more operational
could not be finalised due to the early end of the legislature. The system of electronic
allocation of cases continues to be applied, ensuring its transparency8
. However, concerns
1
An overview of the institutional framework for all four pillars can be found here.
2
Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The
level of perceived judicial independence is categorised as follows: very low (below 30% of respondents
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%).
3
ENCJ, written input, p. 4. See also 2024 Rule of Law Report, Portugal, p. 4.
4
The Council has important competences, particularly in the selection process for judicial appointments,
appraisals and promotions, and disciplinary proceedings. ENCJ, written input, p. 36.
5
Country visit Portugal, High Council for the Judiciary.
6
EAJ, written input, p. 10; MEDEL – Portugal, written input, p. 8.
7
In December 2023, the Council of Europe’s Group of States Against Corruption (GRECO) recalled their
recommendation to Portugal that not less than half the members of the two councils should be judges
chosen by their peers, GRECO (2024a). See also Committee of Ministers of the Council of Europe (2010),
para. 27; Venice Commission, (2020), para. 44; Consultative Council of European Judges (CCJE) (2021),
para. 29; (2007), paras. 15 ff.
8
2024 Rule of Law Report, Portugal, pp. 3-4.
4
remain regarding the administrative burden it creates for courts9
. Following stakeholders’
requests10
and in line with the conclusions of an evaluation of the system11
, in February 2025
the Government adopted a proposal aimed at making the system more operational12
, which
was generally welcomed13
. While the proposal was transmitted to Parliament, its dissolution
in March 2025 and subsequent end of legislature meant that no immediate follow-up could be
ensured14
. Stakeholders expect the proposal to be followed up in the next legislature.
Quality
The recruitment of new legal clerks, and the reform of the criteria for access to the
judiciary and prosecution have contributed to significant progress in improving
adequate human resources for the justice system15. Important steps have been taken to
address the deficit of legal clerks, with concerns about vacant posts16
, a high number of
retirements17
, and a need to address unequal distribution18
. A new recruitment procedure for
legal clerks has resulted in over 500 new clerks taking office19
. Progress was also achieved in
the revision of the Statute of Legal Clerks, which came into force in April 202520
. This also
allowed to put an end to clerks’ strikes that had been ongoing since 2023. While stakeholders
highlight that further measures are still necessary21
, they consider this was an essential step to
make the career more attractive. Regarding legal and technical advisers, while new
recruitments took place at the level of the Supreme Court of Justice and lower instance
judicial courts22
, there has been no reinforcement for second instance Administrative and Tax
9
Which requires judges and prosecutors to be present in the room while the legal clerks electronically
allocate cases, even though they do not influence the actual allocation and do not perform any formal
control over it.
10
The trade unions representing judges, prosecutors and legal clerks, as well as the Bar Association, presented
a joint position to the Minister of Justice, requesting the amendments of the requirements of physical
presence legally imposed.
11
The implementing regulation of the system of allocation required an evaluation of the system within six
months of its full operationalisation, finalised in July 2024 (2024 Rule of Law Report, Portugal, pp. 3-4).
12
Portuguese Government (2025a).
13
Country visit Portugal, Judges’ Union, Prosecutors’ Union, Union of ‘Funcionários Judiciais’.
14
The dissolution of Parliament in March 2025, and consequent early termination of the legislature, has
suspended a number of reforms across areas covered in the Rule of Law Report, such as: the reform of the
case allocation system; the revision of the age of retirement in the judiciary; the reform of Administrative
and Tax Courts; changes to the criminal procedure legislation; the implementation of the Anti-corruption
Agenda, and measures envisaged therein; the implementation of the Media Action Plan; and the reforms
related to legislative transparency, both at Parliament and Government level.
15
The 2024 Rule of Law Report recommended to Portugal to: “[s]tep up efforts to ensure adequate human
resources of the justice system, in particular regarding judicial clerks (…)”.
16
As of February 2024, there were over 1 100 vacancies in first instance ordinary courts and 59 vacancies in
first instance Administrative and Tax Courts (Directorate-General for the Administration of Justice (2024)).
17
ENCJ, written input, p. 34; Country visit Portugal, Unions of ‘Oficiais de Justiça’ and ‘Funcionários
Judiciais’.
18
In particular, the courts of the metropolitan area of Lisbon and Prosecution Services (Country visit Portugal,
High Council for Public Prosecution, Unions of ‘Oficiais de Justiça’ and ‘Funcionários Judiciais’).
19
Portuguese Government, written input, p. 5; Country visit Portugal, Ministry of Justice. A new recruitment
procedure for 51 new clerks was initiated in April 2025, to fill the vacant posts.
20
Including adoption of new remuneration tables and career structure. Country visit Portugal, Ministry of
Justice. The revision of the Statute of Legal Clerks is also a reform under the Portuguese RRP (Milestone
18.10).
21
In particular regarding career progression, also in light of the Constitutional court’s judgment nr. 892/2023,
which declared unconstitutional some of the provisions pertaining to the rules of career progression.
22
Country visit Portugal, Supreme Court of Justice and High Council for the Judiciary.
5
Courts and Prosecution23
. As regards judges and prosecutors, further steps were taken to
increase their number as new rules were adopted which broadened access to initial training24
,
reduced the complexity of the selection procedure, and made the career more attractive25
.
Moreover, a new training centre for judicial professions has been operationalised, which is
also expected to attract more applicants26
. Stakeholders broadly welcomed these changes as a
first step to address concerns regarding the increasing workload of judges and prosecutors27
.
The revision of the mandatory age of retirement, which would allow for the completion of
terms for senior positions in the judiciary, as well as provisions establishing minimum
periods of tenure were under consideration by the Government, following calls from
stakeholders, however these could not be completed. Overall, given the steps taken, there has
been significant progress in stepping up efforts to ensure adequate human resources of the
justice system, in particular regarding judicial clerks.
Working conditions and security in court and prosecution premises affect the
functioning of the courts. Stakeholders report that working conditions in court and
prosecution premises continue to deteriorate28
, despite recent investment in the maintenance
and renovation of some buildings deemed a priority29
. Their poor condition often leads to
postponement of procedural acts, with an impact on the efficiency of the justice system30
.
Concerns regarding security in court and prosecution premises31
, including those used by the
EPPO32
, also remain, and in several buildings there are no suitable dedicated lawyers’ rooms
to guarantee professional secrecy33
. While the expenditure in the justice system in 2023
registered a small increase, it remains one of the lowest in the EU34
. According to European
standards, States allocate adequate resources, facilities and equipment to courts to enable
them to work efficiently35
.
While further efforts to improve digitalisation are being made, online access to
judgments remains limited. The use of digital technologies by courts and prosecution
23
Country visit Portugal, High Council for Administrative and Tax Courts, High Council for Prosecution.
24
In particular, the completion of a master’s in law in no longer mandatory.
25
New recruitments are already taking place under the new rules, and the number of applicants has increased.
Portuguese Government, written input, p. 6. Country visit Portugal, High Council for the Judiciary.
26
Country visit Portugal, Ministry of Justice. Whereas the initial training for the 23 new judicial court judges
and 23 new prosecutors will already take place in the new centre, the training for Administrative and Tax
Courts judges will continue to take place exclusively in Lisbon, raising concerns that this will further lower
the attractiveness of this jurisdiction (Country visit Portugal, High Council for the Administrative and Tax
Courts).
27
EAJ, written input, p. 31; ENCJ, p. 36; MEDEL – Portugal, p. 10. See also 2024 Rule of Law Report,
Portugal, p. 9. In an open letter of 12 June 2025 signed by over 1 000 prosecutors, the Union of Prosecutors
raised concerns regarding the excessive workload and working conditions of prosecutors, in particular in
light of the rules on appointments approved in June 2025, which the Union deems to lower the level of
specialisation (Union of Prosecutors (2025)).
28
EAJ, written input, 23; MEDEL – Portugal, written input, p. 10.
29
2024 Rule of Law Report, Portugal, p. 9.
30
ENCJ, written input, pp. 34-35.
31
Country visit Portugal, Judges’ Union, Prosecutors’ Union, Union of ‘Funcionários Judiciais’, Union of
‘Oficiais de Justiça’.
32
EPPO, written input, p. 44.
33
Country visit Portugal, Bar Association.
34
Figure 33, 2025 EU Justice Scoreboard. The expenditure on law courts as a percentage of GDP further
decreased in 2023, remaining average (Figure 34, 2025 EU Justice Scoreboard).
35
Committee of Ministers of the Council of Europe (2010), para. 33.
6
remains generally widespread36
, while the digital solutions in criminal cases remain
comparably more limited37
. Further efforts to improve digitalisation are being made,
including in the context of the Recovery and Resilience Plan, in particular as regards
electronic notifications and communications38
, as well as a new information system to handle
electronically the judicial proceedings, including in criminal proceedings39
. While the Anti-
corruption Agenda adopted in June 2024 listed the publication of judgments of all instances
as a priority40
, this project could not be finalised41
, and online access to published judgments
remains among the lowest in the EU42
.
The legal aid system was revised to address the low level of remuneration of legal aid
providers, with the Bar Association calling for further changes. In September 2024, the
legal aid system was amended through Government ordinance, allowing courts, prosecution
services, and police authorities to designate as State-appointed-lawyer any lawyer who
signals availability. These amendments address the need to ensure the provision of legal aid,
in case the Bar Association does not prepare the lists of available lawyers, and were prompted
by protests against the low level of remuneration of legal aid providers43
, which included the
halting of the preparation of those lists by the Bar Association. The amendments triggered
further protests, with the Bar Association expressing concerns regarding legislative
transparency44
, as well as the impact on the autonomy of the Bar and the quality of legal
aid45
. Further amendments were introduced in February 2025, broadening the cases for which
legal aid is available and amending the table of remuneration of legal aid providers46
. These
new rules have been broadly welcomed, nevertheless the Bar Association called for further
changes, considering that some of the amendments may translate, in practice, into a reduction
to the remuneration of lawyers47
.
Efficiency
There has been some further progress in increasing the efficiency of Administrative and
Tax Courts at first instance, while serious concerns remain regarding the disposition
time in second instance in particular among businesses48. The efficiency in first instance
Administrative and Tax Courts has improved, with a decrease in disposition time at 597 days,
and further improvement of the clearance rate, which rose to 120%49
. However, the situation
36
Figures 41 and 42, 2025 EU Justice Scoreboard.
37
Figure 45, 2025 EU Justice Scoreboard.
38
Portuguese RRP, Milestone 18.3. Portuguese Government, written input, p. 6.
39
Portuguese RRP, Milestone 18.7.
40
Portuguese Government, written input, p. 8.
41
Country visit Portugal, Ministry of Justice.
42
Figure 47, 2025 EU Justice Scoreboard. A GRECO recommendation in this regard remains only partially
implemented.
43
The remuneration of legal aid providers is among the lowest in the EU (Figure 25, 2025 EU Justice
Scoreboard). CCBE, written input, p. 162.
44
The Bar Association, which was not consulted in the legislative process, argued that the Law on Legal Aid
was overturned through a lower ranking legislative act (regulatory ordinance).
45
CCBE, written input, p. 162.
46
The new rules will come into force in August 2025. Ministry of Justice (2025).
47
In particular, in cases where a resolution is reached through court conciliation, without reaching the hearing
phase (Country visit Portugal, Bar Association).
48
The 2024 Rule of Law Report recommended to Portugal to: “[…] continue efforts to improve its efficiency,
in particular of Administrative and Tax Courts”.
49
Figures 5, 10 and 13, 2025 EU Justice Scoreboard.
7
has deteriorated in second instance, where 1 200 days are needed to resolve a case50
. The
High Council for Administrative and Tax Courts proposed to the Ministry of Justice
measures aimed at increasing the efficiency of these courts, and which will still need to be
taken up51
. The creation of a new second instance is provided for by law, but its
operationalisation remains pending, making it difficult to reduce the high number of pending
cases per judge and to improve the low level of clearance rate52
. While efficiency is higher in
civil and commercial cases, the disposition time in first instance has slightly decreased, the
clearance rate fell below 100%, and the case backlog registered an increase53
. Stakeholders
consider that the efficiency shortcomings in the justice system are a long-term obstacle to
investment and the business environment54
. In fact, a significant number of cases pending
before Administrative and Tax Courts have a high economic value55
. Portugal remains under
enhanced supervision by the Committee of Ministers of the Council of Europe for the
excessive length of proceedings before both civil and administrative jurisdictions56
. Given
that there has been some improvement at first instance, but serious concerns remain regarding
second instance, there has been some further progress in increasing the efficiency of
Administrative and Tax Courts.
There has been some progress in ensuring the adequacy of the general criminal
procedure legislation to efficiently deal with complex criminal proceedings57. The need to
ensure the efficient handling of complex criminal cases, commonly referred to as ‘mega
procedures’, continues to be considered as a priority by stakeholders58
. In this context, the
High Council for the Judiciary created a working group, tasked with identifying the main
causes of delays in these cases and proposing solutions that promote efficiency. The working
group’s proposals were transmitted to the Minister of Justice in January 202559
. The Anti-
Corruption Agenda also includes measures expected to contribute to this purpose60
, and
legislative changes directly aimed at avoiding the creation of such ‘mega procedures’ were
also included among the major initiatives of the previous legislature61
. However, none of
these measures could be pursued further, due to the early end of the legislature and it remains
to be seen how the steps taken will be advanced further. Given the steps taken, there has been
some progress on this recommendation.
50
Figure 8, 2025 EU Justice Scoreboard.
51
Country visit Portugal, High Council for the Administrative and Tax Courts.
52
338 cases per judge and a resolution rate of 97% in the North Central Administrative Court; 725 cases per
judge and a resolution rate of 88% in the South Central Administrative Court.
53
Figures 5, 10 and 13, 2025 EU Justice Scoreboard.
54
2024 European Semester, Portugal, p. 14.
55
In 2023, 636 new cases with an economical value over EUR 1 million were registered in Administrative
and Tax Courts; it is estimated that the total number of tax cases pending before these courts amount to
EUR 12 000 million (Jornal de Negócios (2025)).
56
Committee of Ministers (2025).
57
The 2024 Rule of Law Report recommended to Portugal to: “[t]ake measures to ensure the adequacy of the
general criminal procedure legislation to efficiently deal with complex criminal proceedings.”
58
Country visit Portugal, High Council for the Judiciary. 2024 Rule of Law Report, Portugal, pp. 12-13.
59
Proposals include: amending the code of criminal procedure to avoid excessive delays in proceedings;
amending the criminal investigation phase, promoting greater efficiency and speed; strengthening
procedural management practices and promoting a culture of efficiency in the courts; combating dilatory
procedural acts; providing adequate technological and human resources to courts to deal with the
complexity of mega procedures (High Council for the Judiciary (2025)).
60
Including changes to the instruction phase of the process, and granting judges more powers to deter dilatory
procedural acts, which contribute to procedural delays.
61
Portuguese Government (2025), written input, pp. 9-10.
8
II. ANTI-CORRUPTION FRAMEWORK
The perception among experts, citizens and business executives is that the level of
corruption in the public sector remains relatively high. In the 2024 Corruption
Perceptions Index by Transparency International, Portugal scores 57/100 and ranks 15th
in the
European Union and 43rd
globally62
. This perception has deteriorated over the past five
years63
. The 2025 Special Eurobarometer on Corruption shows that 91% of respondents
consider corruption widespread in their country (EU average 69%) and 64% of respondents
feel personally affected by corruption in their daily lives (EU average 30%). As regards
businesses, 75% of companies consider that corruption is widespread (EU average 63%) and
50% consider that corruption is a problem when doing business (EU average 35%).
Furthermore, 32% of respondents find that there are enough successful prosecutions to deter
people from corrupt practices (EU average 36%), while 23% of companies believe that
people and businesses caught for bribing a senior official are appropriately punished (EU
average 33%)64
.
The National Anti-Corruption Strategy 2020-2024 is still to be evaluated, and the new
anti-corruption strategy remains to be developed. While bills on lobbying were prepared
by political groups in the Parliament, most of the measures set out in the Anti-corruption
Agenda adopted in June 202465
– which includes 32 measures based on four pillars: effective
punishment, procedural speed, public sector protection, and prevention – were not yet put in
place66
. The ad hoc Parliamentary Committee67
created in October 2024 to follow up on the
implementation and monitoring of the Anti-corruption Agenda has not discussed a legislative
file68
, and it has not yet been renewed under the new legislature. The National Anti-
Corruption Strategy 2020-2024, expected to be evaluated by 30 November 202469
, remains to
be assessed70
. A new National Anti-Corruption Strategy, together with a specific action plan
to ensure its implementation, are further expected71
.
Some further progress was achieved with regard to the resources of the Anti-
Corruption Mechanism (MENAC), and further changes were made to improve its
62
Transparency International (2025). The level of perceived corruption is categorised as follows: low (the
perception among experts and business executives of public sector corruption scores above 79); relatively
low (scores between 79-60), relatively high (scores between 59-50), high (scores below 50).
63
In 2020 the score was 61, while, in 2024, the score is 57. The score significantly increases/decreases when
it changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively stable
(changes from 1-3 points) in the last five years.
64
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
65
Portuguese Government (2024).
66
The Anti-Corruption Agenda remained in place only for 9 months which did not allow for progress on other
listed measures.
67
Resolution 72-A/2024.
68
Country visit Portugal, Assembly of the Republic.
69
Art. 215, Law No 82/2023.
70
According to the OECD criteria, Portugal scores 4 out of 15 (below the EU average) on the adequacy of
implementation structures and reporting; OECD (2024).
71
According to Art. 285, 2025 State Budget Law, the new Strategy is expected to foresee rules on its
monitoring, objectives, repartition of competences between authorities, the timetable and deadlines for
implementation as well as the publication of delivery indicators. Civil society looked forward to the new
strategy: Country visit Portugal, Observatory of Economy and Fraud Management, Transparency
International – Portugal.
9
structure and functioning72. In the second year of its activity, MENAC73
issued four
recommendations to the Government, inspectors and entities under the General Corruption
Prevention Regime74
and supported educational activities. Its current activities remain limited
to overseeing compliance with the General Corruption Prevention Regime75
, while its
mandate is wide, extending to evidence-based analyses, tailored recommendations for sector-
specific risks, or guidance in view of the legislative reforms76
. In 2024, MENAC received
152 reports denouncing corruption77
. In November 2024, the electronic platform for the
reception, automatic processing and storage of compliance instruments became operational78
.
MENAC informed on the upcoming focus on private sector entities for the effective
implementation of the General Regime for the Prevention of Corruption in the areas of
climate and energy, in particular concerning the issuance of official permits and the
relationship with Directorate-General of Energy and Geology79
. In December 2024, MENAC
and the National Association of Portuguese Municipalities signed a working protocol to
implement measures to promote transparency, integrity and prevention of corruption and
related offences80
. Amendments to the structure and functioning of MENAC81
, which entered
into force in May 202582
, were made to address challenges regarding resources83
and
coordination with authorities84
. These amendments led to the creation of a Board of Directors
and establish new rules for the recruitment of MENAC’s staff, which will no longer depend
on secondments. These changes are intended to address concerns voiced by stakeholders
related to MENAC’s effectiveness and limited operational activities85
. In light of these
developments, some further progress was made to ensure sufficient resources for MENAC.
Significant progress was made to ensure sufficient resources for the handling
corruption cases86. As regards the Criminal Police, between 2022 and 2025, it is expected
that 1 100 new inspectors will have been recruited, strengthening careers in criminal
investigations, scientific policing and security87
. While these resources will be allocated
72
The 2024 Rule of Law Report recommended to Portugal to: “[c]ontinue efforts made to ensure sufficient
resources for preventing, investigating and prosecuting corruption, including for the new Anti-Corruption
Mechanism”.
73
It is an independent entity with administrative and financial autonomy, whose mission is to promote
transparency and integrity in public action and to ensure the effectiveness of policies to prevent corruption
and related offences. Ministerial Implementing Order No. 155-B/2023.
74
MENAC (2025), Recommendations 1/2024 (updated and expanded in 2025), 7/2024, 8/2024, 9/2024.
75
Decree-Law No. 109-E/2021.
76
National Anti-Corruption Strategy 2020-2024, 2024 Rule of Law Report, Portugal, p. 17.
77
MENAC, 2024 Annual Report, p. 9.
78
It allows organisations with 50 or more employees to submit documents essential to compliance with the
General Regime for the Prevention of Corruption, such as corruption prevention plans and implementation
reports. So far, 12 000 entities notified their obligations through the platform. MENAC (2025), p. 31.
79
Country visit Portugal, MENAC.
80
This is particularly important as local government remains a risk area for corruption. Portuguese
Government, written input, p. 15.
81
Decree-Law approving the institutional restructuring of the National Anti-Corruption Mechanism
(MENAC). Portuguese Government (2025).
82
The President of the Republic promulgated the Government’s Decree-Law on 10 April 2025.
83
On 31 December 2024, 12 members of staff were recruited while 15 vacancies were unfilled. MENAC
(2025), pp. 20-22.
84
Country visit Portugal, MENAC.
85
Country visit Portugal, Observatory of Economy and Fraud Management, Transparency International –
Portugal.
86
The 2024 Rule of Law Report recommended to Portugal to: “[c]ontinue efforts made to ensure sufficient
resources for preventing, investigating and prosecuting corruption […]”.
87
Portuguese Government, written input, p. 14.
10
across criminal law areas, it is expected that this will contribute to better investigating
corruption cases, which requires long periods of training, and where difficulties in retaining
staff continue to be reported88
. The authorities inform that the Central Investigation and
Prosecution Department (DCIAP) has also received reinforced resources to work on anti-
corruption matters89
. Resources foreseen for fighting foreign bribery have also increased in
202490
. As regards the financial resources of the Inspectorate General of Finance (IGF), an
increase of 7% is foreseen for 2025 compared to 2024. It is also planned to hire 30 new
inspectors in 2025 and 15 more in 2026 for the specific task of preventing and combating
corruption in local authorities91
. Stakeholders acknowledge the positive impact of the
measures that have been implemented in the last years92
, with some noting however that the
shortage of prosecutors and clerks93
, lack of specialised advisers and outdated IT equipment94
has an impact on handling corruption cases by the prosecution. Overall, given the tangible
efforts made to recruit new staff and various further measures in the pipeline, significant
progress has been made to ensure sufficient resources for preventing, investigating and
prosecuting corruption.
While corruption cases remain a priority, there are challenges in ensuring the timely
investigation, prosecution and adjudication of high-level corruption cases. Generally,
corruption cases, including those on foreign bribery95
, are handled efficiently and as a matter
of priority96
. In parallel, the authorities continue to face difficulties in handling high-level
corruption cases in a timely manner, which poses the risk that these cases become time-
barred97
. Significant delays were noted in relation to some high-level corruption cases, some
of them pending for over a decade and remaining in pre-trial stage. In 2024, for the first time,
the authorities had recourse to a procedure against delaying manoeuvres, which allowed to
proceed in a more expedite manner with these cases98
. The EPPO investigated 8 corruption
cases, which account for 5% of the total number of EPPO cases in Portugal99
.
88
Country visit Portugal, Criminal Police, Office of the Prosecutor General.
89
Country visit Portugal, DCIAP.
90
This relates also to the resources to fight foreign bribery. Implementing OECD (202x), p. 5.
91
These will integrate the IGF and the Inspectorate-General for Agriculture, Sea, Environment and Spatial
Planning.
92
Country visit Portugal, Criminal Police, IGF.
93
See also Pillar I – Quality.
94
Country visit Portugal, Office of the Prosecutor General and the Criminal Police.
95
While there have so far been no convictions or sanctions imposed for foreign bribery, the authorities inform
on seven ongoing cases and indictment of eight natural persons and one company in two complex ongoing
cases. OECD (2024).
96
In 2024, 504 reports on corruption were submitted (41% from anonymous complaints, 22% from
whistleblowing submissions). Also in 2024, corruption charges were brought in 81 cases, 16 convictions
were taken and 2 acquittals. In 2024, the average time for proceedings leading to a judgment was 6.8 years.
MENAC (2025), pp. 62, 70, 77. In 2023, charges were brought against 74 natural persons and 3 legal
persons (in comparison to 117 natural persons in 2022). Also in 2023, 47 convictions against natural
persons were taken (in comparison to 87 natural persons in 2022). In terms of sanctions imposed for
corruption offences in 2023, there were 49 sanctions (in comparison to 87 in 2022). Portuguese
Government (2025), written input. Country visit Portugal, Secretariat General of the Presidency of the
Council of Ministers.
97
2024 Rule of Law Report, Portugal, p. 13.
98
Art. 670, Code of Civil Procedure.
99
EPPO (2025), p. 49.
11
There was significant progress in ensuring effective monitoring and verification of asset
declarations by the Transparency Entity100. In 2024, the reform entrusting monitoring and
verification of asset declarations of political and senior public officials to the Transparency
Entity101
entered into force, and the Electronic Platform, which enabled political office
holders to fulfil their reporting obligations, started operating102
. Since then, 2 626 single
declarations were submitted via the Electronic Platform103
, and 789 of them were completed.
In parallel, 158 notifications on possible non-compliance were issued. Whereas the
Anticorruption Agenda envisaged an evaluation of the functioning of the Entity to assess the
need of amendments to its legislative framework104
, this could not be finalised before the end
of the legislature. While the declarations remain publicly accessible upon request, civil
society considers that the interpretation of the law regarding public access to the declarations
is too narrow105
. Despite some remaining concerns106
, the ongoing first task of ensuring
effective monitoring and verification of asset declarations by the Transparency Entity has
been progressing well so far107
. In view of the above, significant progress has been made to
ensure the effective monitoring and verification of asset declarations by the Transparency
Entity.
Shortcomings in the integrity framework remain to be addressed under the new
legislature. The existing shortcomings and lack of efficiency of the existing rules on integrity
have been widely criticised108
. The code of conduct adopted in 2024, in line with GRECO
recommendations, addressed the main issues. It however did not include a clear enforcement
mechanism for non-compliance with the code. Moreover, concerns have been raised
regarding the lack of publication of the registry of interests of the members of the
Government109
. While reporting channels for whistleblowing within the Government have
been established, the risk prevention plan, which had been announced in the Anti-corruption
100
The 2024 Rule of Law Report recommended to Portugal to: ‘[e]nsure the effective monitoring and
verification of asset declarations by the Transparency Entity’.
101
Article 5 of Organic Law No. 4/2019.
102
Members of the Assembly of the Republic, members of the Government and heads of cabinet of members
of the Government who have ceased or commenced office following the parliamentary elections of 10
March 2024, as well as Members of the European Parliament who ceased or commenced office following
the elections to the European Parliament of 9 June 2024. Currently, the staff was raised to 10 persons and
procedures are ongoing for 3 other posts. Portuguese Government, written input, pp. 13-14. Country visit
Portugal, Entity for Transparency.
103
In addition, 298 requests for consultation of the information contained in the declarations were submitted
(269 were accepted and 4 were rejected) as well as 21 requests from the officeholder to object access to the
information contained in the declaration (4 were granted, 2 partially granted, 8 rejected and 6 were
concluded on other grounds for terminating the procedure). Portuguese Government (2025), written input,
p. 14.
104
Portuguese Government, written input, p. 14.
105
The Entity reports that requests for access to declarations have increased by 41%. Country visit Portugal,
Transparency Entity. Observador (2024). Expresso (2024).
106
In particular, in relation to the dependence on the Constitutional Court, its geographical distance from the
Constitutional Court, the current lack of the interoperability of the platform, in particular with the Bank of
Portugal, and the potentially burdensome manual checks of the information inserted in the platform. 2024
Rule of Law Report, Portugal, pp. 21-22.
107
It is expected that following the parliamentary elections on 18 May 2025 and the submission of the relevant
declarations by the new Members of Parliament and members of the Government within 60 days from the
date they enter office, the Transparency Entity will monitor and verify them.
108
2024 Rule of Law Report, Portugal, p. 20.
109
The latest available publication refers to the Government that ceased functions in March 2024; Parliament
(2024).
12
Agenda, is only now starting to be implemented110
. On 22 May 2025, MENAC issued a
recommendation to the new Government to adopt the tools for the prevention of corruptions
risks within 60 days of taking up office111
. Stakeholders also consider that the remaining gaps
should be addressed through tailor-made rules under the new legislature112
.
Initial efforts were made under the previous legislature to address lobbying, which so
far remains unregulated. Despite political consensus in line with the Anti-Corruption
Agenda113
, initial efforts to introduce a lobbying bill114
were cut short by the early
termination of the legislature115
. As a consequence, lobbying remains unregulated, despite
long standing GRECO recommendations116
and criticism from civil society117
. Particular
concerns have been raised in relation to areas considered as high-risk for corruption,
including urban planning, also in the context of the discussion of legislative proposals, for
example those on the legal framework for territorial management instruments118
. The
importance of introducing rules on lobbying is underlined also by recent high-level
corruption investigations involving holders of public office, at national, local and regional
level119
. The system of preventive audit over the EU-funded projects was amended.
Businesses’ attitudes towards corruption in the EU show that 20% of companies in Portugal
(EU average 25%) think that corruption has prevented them from winning a public tender or
a public procurement contract in practice in the last three years120
. 68% of companies
perceive the level of independence of the public procurement review body (Administrative
and Tax Courts) as very or fairly good121
. The Single Market and Competitiveness
Scoreboard on access to public procurement in Portugal reports 21% of single bids for 2023
(29% EU average). In December 2024, with the aim to speed the execution of the EU-funded
projects122
, new rules came into force which amend the Court of Auditors’ preventive control
over contracts financed or co-financed by European funds, with no time or value limit123
.
110
Country visit Portugal, Secretariate-General of the Presidency of the Council of Ministers. The risk
prevention plan was published on 5 June 2025 (Portuguese Government (2025b)).
111
The rules are to be subject to an annual assessment. They are to be applicable to the members of the
government, members of their cabinets, senior managers of the direct administration of the State, heads of
public institutes and public managers.
112
Country visit Portugal, Observatory of Economy and Fraud Management, Transparency International –
Portugal.
113
Portuguese Government (2024), which includes a Code of Conduct for lobbying, as well as a register of
interest representatives and meetings that took place with public officials.
114
The legislative procedures relating to the proposals already presented in this legislature in Parliament are
underway, namely bills no. 179/XVI/1a (PAN), 190/XVI/1a (IL), 346/XVI/1a (PSD) and 366/XVI/1a (CH).
115
Country visit Portugal, Services of the Assembly of the Republic.
116
GRECO (2024), para. 70.
117
Country visit Portugal, Observatory of Economy and Fraud Management, Transparency International –
Portugal.
118
Country visit Portugal, Services of the Assembly of the Republic. While the President of the Republic
promulgated the Decree-Law, it was highlighted that the corruption prevention aspects still need to be
further developed (President of the Republic (2025)).
119
2024 Rule of Law Report, Portugal, p. 20.
120
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 5
percentage points below the EU average.
121
Figure 59, 2025 EU Justice Scoreboard.
122
The implementation of the RRP suffered delays, which, given the short deadlines for using the funds,
generated strong pressure and incentives to speed up its execution. Portuguese Government (2024a).
123
Law 20/XVI/l amending Law 30/2021 which approves special public procurement measures. While the
Court of Auditors was consulted during the legislative process, this was only in the initial phase and
subsequent changes included broadening to include all EU funded projects, without a new consultation of
the Court.
13
While such contracts remain subject to the preventive control of the Court of Auditors, the
suspending effect of a control of projects was limited to exceptional instances. Stakeholders
pointed out that the new rules may lead to an increase in corruption risks124
.
III. MEDIA PLURALISM AND MEDIA FREEDOM
The Media Regulatory Authority continues to carry out its tasks and has reinforced
financial resources. Examples of recent activity by the Media Regulatory Authority (ERC)
are its ongoing collaborations with the Ministry of Justice on the preparatory work for the
transposition of the EU anti-SLAPPs Directive and projects with the OSCE Representative on
Freedom of the Media, such as the Safety of Journalists Toolbox125
. Regarding resources,
ERC is to receive an overdue amount from two preceding years of around EUR 3 million.
This amount stems from the net profits of the share participation in the fees for use of the
radio spectrum paid to ICP-ANACOM (the national regulatory authority for postal
communications and electronic communications) as remuneration for use of a public asset. Its
recoup, in addition to the increase of state budget funding proportionate to the increased
number of taxpayers, is noted positively by the regulator, in contrast with previously reported
shortcomings126
. A legislative amendment envisaged by the transition Government allowing
the direct transfer from ANACOM instead of via the State Treasury is also perceived as a
needed improvement contributing to stabilising the regulator’s funding model, ensuring
greater predictability and responding to operational needs more quickly and efficiently127
.
Regarding the resources allocated to the media regulator, the MPM 2025 for Portugal
considers that adequate budgetary conditions to strengthen ERC’s activity are still lacking128
.
A comprehensive Media Action Plan was presented by the Government. A Media Action
Plan including 30 measures was presented by the Government in October 2024129
. Among the
planned measures are the codification of national media laws, an action plan for journalists’
safety and commitments to support regional and local media130
. There is a consensus among
stakeholders that this plan is a positive step forward, although it may not be sufficient to
address all existing challenges131
.
A new concession contract with the public service media provider has been signed and
its resources strengthened and streamlined. Following a public consultation, a new
124
Country visit Portugal, Observatory of Economy and Fraud Management, Transparency International –
Portugal. The estimated value of EU-funded projects affected by the new rules is considerable, in particular
only 31% of projects received the visa in 2024. IMPIC (2024). Between 20 June 2021 and 30 June 2024,
the Court received information on the conclusion of 1582 contracts involving a total amount of 238.8
million euros, in addition to 50 contracts subject to preventive inspection, for a total amount of 89 million.
Court of Auditors (2024a).
125
Country visit Portugal, ERC.
126
Country visit Portugal, ERC.
127
Country visit Portugal, PT Media Lab and ERC.
128
Media Pluralism Monitor (2025), p. 7.
129
Country visit Portugal, PT Media.
130
Portuguese government (2024b), p. 37.
131
Country visit Portugal, Union of Journalists, the Journalists Professional License Commission, ICNOVA
and Private media association. The measures proposed in the plan are regarded as insufficient, for example,
to address competition by digital platforms or to address local asymmetries in terms of media presence,
notably radios; some are also considered risky due to their execution by local authorities, which may create
undue dependencies. The absence of an accompanying study to support the proposals included in the plan
was also noted.
14
concession contract with Rádio e Televisão de Portugal (RTP) was signed in March 2025, 10
years after its last revision132
. The state budget foresees a financing increase for RTP that
corresponds to the amount of cumulated loss of income of around EUR 80 million resulting
from the inflation update of the annual audiovisual tax that had not been done since 2017133
,
in addition to the continuous increase in the number of people from whom the audiovisual tax
is collected. In contrast, a proposal to cut commercial advertising by two minutes per hour
that was included in the Government’s Media Action Plan134
was rejected during the voting
of the budget in Parliament. Moreover, as foreseen in the Media Action Plan and made
possible by the state budget for 2025,135
RTP has started a staff restructuring in March 2025,
whereby around 250 employees are to leave the public service media on the basis of amicable
termination of contracts, with 80 employees already doing so as of December 2025136
.
According to RTP, both the new concession contract and the ongoing staff restructuring
reflect the need to modernise the offer of the public service media provider, particularly with
regard to non-linear services and in view of new consumption habits, including those of
younger audiences, which requires a more skilled workforce137
.
The LUSA News Agency is now nearly fully owned by the state. The Government has
increased its stake in the news agency to 95.86% while envisaging to acquire the remainder
of the shares138
. A new governance model including a multi-sectorial Supervisory Board is
foreseen by the Government’s Media Action Plan with the objective of guaranteeing LUSA’s
editorial independence139
. Although the new governance model is yet to be further defined,
the state budget funding allocated to LUSA has increased to EUR 21.5 million in 2025 from
EUR 18.1 million in 2024140
. These developments are regarded as positive, especially in light
of the market role played by the news agency, even if their impact on matters like staffing,
salaries, transparency, independence and pluralism is still to be assessed141
.
Following the unprecedented suspension of voting and property rights within one media
group, the national regulator submitted to Parliament and the Government proposals to
amend the legislative framework. ERC is responsible for the monitoring of transparency of
media ownership142
. In July 2024, the regulator presented the Parliament and the Government
with proposals to amend the Media Transparency Law, notably regarding the mechanism for
the suspension of voting and property rights in cases of lack of transparency of ownership143
.
This provision was used for the first time in the Global Media Group case144
. According to
132
Portuguese Government (2025), written input, p. 25; Country visit Portugal, PT Media Lab and RTP.
133
Law No. 45-A/2024 of December 31. 2024 Rule of Law Report, p. 26.
134
Portuguese Government (2024b), p. 10.
135
Portuguese Government (2024b), p. 11.
136
Country visit Portugal, RTP.
137
Country visit Portugal, RTP.
138
Portuguese Government (2024b), p. 13. Country visit Portugal, PT Media Lab.
139
Portuguese Government (2024b), p. 13.
140
Media Pluralism Monitor (2025), p. 6.
141
Country visit Portugal, Union of Journalists, the Journalists Professional License Commission, ICNOVA
and Private media association.
142
Law No. 78/2015, which regulates the promotion of transparency of ownership, management, and financing
of entities that carry out media activities. ERC collects and verifies the information reported by entities
under the legal provisions of transparency and displays it in the Transparency Portal.
143
Country visit Portugal, PT Media Lab and ERC.
144
Media Pluralism Monitor (2025), pp. 8-9. 2024 Rule of Law Report, Portugal, p. 27. Country visit Portugal,
PT Media Lab and ERC.
15
ERC, this decision, although seen as coming late145
, was prioritised and took nearly one year
to adopt due to the complexity of the case146
. Overall, this outcome is regarded by
stakeholders as a positive result of the existing legal framework. The amendments are also
seen as needed to facilitate future decisions147
. The MPM 2025 for Portugal has adjusted its
score from high risk to very high risk when it comes to media plurality since the media
landscape in Portugal remains highly concentrated148
.
Some steps have been taken to address concerns about the precarity of journalists’ posts
and deteriorating working conditions. The outcome of the Global Media Group case,
namely the conclusion of the restructuring process whereby several of Global Media Group’s
outlets were acquired by Portuguese investors149
, is positively evaluated by stakeholders since
it avoided layoffs150
. Nevertheless, issues are still reported regarding low salaries and the
enforcement of the collective labour agreement for the press151
. Moreover, the Media Action
Plan commits to new incentive mechanisms aimed at the hiring of more journalists and the
creation of more jobs with permanent contracts for all media152
. While generally the Media
Action Plan was positively received by journalists’ associations, some points of criticism
relate, for instance, to the allocated budget and to the limitation of the type of entities who
may apply to the financial incentives foreseen153
. In addition, the announced subsidising of
digital subscriptions and free digital subscriptions for high school students, intended to boost
the media sector’s competitiveness, are regarded as insufficient in themselves to ensure the
sustainability of news media154
.
The number of incidents affecting journalists has decreased, while some concerns
regarding restrictions hindering journalistic reporting have emerged. The Council of
Europe Platform to promote the protection of journalism and safety of journalists has
registered one alert since the adoption of the 2024 Rule of Law Report, relating to physical
attacks and harassment of journalists155
. The Media Freedom Rapid Response monitor for
Portugal reported ten alerts since July 2024, relating, respectively, to intimidation,
threatening or physical injury, and access to information156
. No SLAPP cases were reported
since the publication of the 2024 Rule of Law Report157
. Overall, stakeholders deem that the
number of alerts is not alarming158
. As regards access to information, the Journalists’ Union
145
2024 Rule of Law Report, Portugal, p. 27.
146
Which implied the need to consult all interested parties and gather all relevant information in order to
susbtantiate with certainty a strong limitation of shareholders rights that are protected by the Portuguese
Constitution (Country visit Portugal, ERC).
147
Country visit Portugal, Union of Journalists, the Journalists Professional License Commission, ICNOVA
and Private media association.
148
Media Pluralism Monitor (2025), p. 21.
149
Diário de Notícias (2024).
150
Estimated between 150 and 200. Country visit Portugal, Union of Journalists, the Journalists Professional
License Commission, ICNOVA and Private media association.
151
Country visit Portugal, Union of Journalists.
152
Portuguese Government (2024b), pp. 20, 21.
153
Country visit Portugal, Union of Journalists.
154
Country visit Portugal, Union of Journalists, the Journalists Professional License Commission, academia
and a private media association.
155
Council of Europe Platform to promote the protection of journalism and safety of journalists (2025). In both
instances, the Portuguese authorities have replied.
156
Media Freedom Rapid Response monitor (2025). For example, on 17 August 2024, authorities in Madeira
reportedly obstructed the work of journalists covering the forest fires on the island.
157
Country visit Portugal, Union of Journalists.
158
Country visit Portugal, Union of Journalists and the Journalists Professional License Commission.
16
expressed specific concerns about the restrictive interpretation of the law allowing access to
politicians’ asset declarations by the Transparency Entity, arguing that it poses a threat to
press freedom159
. Moreover, there have been reports of difficulties in the recognition of
professional credentials, hindering access to and coverage of events at venues like football
stadiums and Parliament160
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
With the early end of the legislature, no progress was made in finalising the reforms to
improve the transparency of law-making161. Due to the dissolution of Parliament on 20
March 2025, it was not possible to proceed with the implementation of ex ante impact
assessment tools, as envisaged in the Parliament’s Rules of Procedure162
, and the process for
reviewing and updating the Parliament’s legal drafting technical guide could not be
completed. The Parliament’s new tool for citizens’ participation in the legislative procedure
was launched in March 2025, but it has not yet been implemented, and its functioning will be
assessed under the new legislature163
. Whereas the Anti-Corruption Agenda adopted in June
2024 included measures expected to improve the transparency of the legislative processes led
by the Government, including the finalisation of the ‘legislative footprint’ system164
, these
could not be implemented before the end of the legislature165
. No further steps could be taken
to increase ex post impact assessment, which remained limited to selected acts166
. Overall,
due to the dissolution of the Parliament and limited duration of the legislature, there has been
no progress in finalising the reforms to improve the transparency of law-making, particularly
on the implementation of impact assessment tools.
Less than half of the companies surveyed in Portugal express confidence in the
effectiveness of investment protection. 44% of companies are very or fairly confident that
investments are protected by law and courts167
. The main reason among companies for their
lack of confidence is the difficulty to obtain a fair compensation or to protect property when
something goes wrong (31%)168
. As regards authorities relevant for economic operators, 70%
of companies perceive the level of independence of the national competition authority
(Portuguese Competition Authority) as very or fairly good169
. A number of judicial
mechanisms are in place at the level of the Supreme Administrative Court to ensure the
implementation of administrative court judgments, including fines for responsible officials
159
Under the provisions of Law No. 52/2019, any citizen seeking access to these declarations must now submit
a “reasoned request”. Expresso (2024a).
160
Country visit Portugal, Journalists' Professional License Committee.
161
The 2024 Rule of Law Report recommended to Portugal to: “[f]inalise the reforms to improve the
transparency of law-making, particularly on the implementation of impact assessment tools”.
162
Country visit Portugal, Services of the Assembly of the Republic. See also 2024 Rule of Law Report,
Portugal, p. 29.
163
Country visit Portugal, Services of the Assembly of the Republic.
164
Establishing the mandatory recording of any intervention of external entities in the legislative process (2024
Rule of Law Report, Portugal, pp. 29-30).
165
Country visit Portugal, Secretariat General of the Presidency of the Council of Ministers.
166
Ex ante impact assessment of Government legislative drafts continued to be ensured. Portuguese
Government (2025), written input, pp. 27-28.
167
Figure 54, 2025 EU Justice Scoreboard. See also 2025 European Semester, Portugal, pp. 10-11.
168
Figure 55, 2025 EU Justice Scoreboard. 20% and 23% of the surveyed investors respectively perceive the
frequent changes in legislation or concerns about the quality of the law-making process and the quality,
efficiency or independence of justice as a reason for the lack of confidence in investment protection.
169
Figure 60, 2025 EU Justice Scoreboard.
17
for non-compliance, the possibility to substitute the annulled administrative act, and to award
direct damages and compensation170
.
On 1 January 2025, Portugal had 19 leading judgments of the European Court of
Human Rights pending implementation, an increase of 3 compared to the previous
year171. At that time, Portugal’s rate of leading judgments from the past 10 years that had
been implemented was 48% (compared to 56% in 2024; 52% remained pending), and the
average time that the judgments had been pending implementation was 5 years and 6 months
(compared to 5 years and 9 months in 2024)172
. The oldest leading judgment, pending
implementation for over 13 years, concerns the fairness of criminal proceedings173
. As
regards the respect of payment deadlines, on 31 December 2024 there were 8 cases in total
awaiting confirmation of payments (compared to 16 in 2023)174
. On 16 June 2025, the
number of leading judgments pending implementation had decreased to 18175
. Following
discussions with the Department of Execution of Judgments of the European Court of Human
Rights regarding the high number of cases concerning freedom of expression176
, the
Government has proposed to the Centre for Judicial Studies (CJS) to include specific training
on the right to freedom of expression and the European Court of Human Rights’ related case-
law in the training plan for judges and prosecutors. The translation of selected European
Court of Human Rights rulings concerning Portugal and Article 10 ECHR is being prepared,
and this compendium will be added to the CJS syllabus177
.
The Office of the Ombudsperson continues to deal with a high number of complaints
regarding administrative delays. The Ombudsperson was re-accredited with ‘A’ status by
the UN Global Alliance of National Human Rights Institutions (GANHRI) in May 2024178
. In
2024, the Ombudsperson continued to receive a high number of complaints submitted by
foreign nationals, particularly regarding long processing times of residence permits by the
administration179
. The institution has raised concerns that the number of urgent judicial
proceedings to compel the administration to decide in such cases may lead to further pressure
on the justice system180
. Following citizens’ complaints, the Office of the Ombudsperson has
launched an investigation on alleged violations of the principles of the rule of law and human
dignity, in the context of a large-scale police raid occurred in December 2024. The
investigation is ongoing181
. Despite the high number of complaints, the institution reports that
170
Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in place at
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower
instance administrative courts.
171
For an explanation of the supervision process, see the website of the Council of Europe.
172
All figures calculated by the European Implementation Network (EIN) and based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 7.
173
Judgment of the ECtHR, 19808/08, Moreira Ferreira v. Portugal, pending implementation since 2011.
174
Council of Europe (2025), p. 157.
175
Data according to the online database of the Council of Europe (HUDOC).
176
Council of Europe, written input, p. 2.
177
Country visit Portugal, Ministry of Justice.
178
Global Alliance of National Human Rights Institutions (GANHRI), Sub-Committee on Accreditation
(SCA) (2024).
179
ENNRHI (2025), p. 367.
180
ENNRHI (2025), p. 366. While the Ombudsperson’s mandate does not cover the functioning of the justice
system, the Office reports that it received a high number of complaints concerning delays in judicial
proceedings (Country visit Portugal, Office of the Ombudsperson). See also 2024 Rule of Law Report,
Portugal, p. 31.
181
Country visit Portugal, Office of the Ombudsperson. Público (2025).
18
it can effectively fulfil its mandate. The Ombudsperson reports good cooperation with the
authorities and continues to play an active role in legislation and policy making182
.
Civil society organisations continue to operate without constraints, and new measures to
improve access to financing have been introduced. The civil society space continues to be
considered as open183
. However, isolated cases of harassment of members of civil society
organisations (CSOs) active in the support of minorities continue to raise particular
concerns184
. The rights of human rights defenders are well protected under general laws185
.
CSOs continue to be able to participate in decision making processes, and are actively
involved in consultative and participatory bodies, and in the discussion of sector-specific
national strategies and actions plans186
. Stakeholders report that the number of funding
opportunities launched by the Government have further increased, and CSOs have welcomed
the increase in the amount of annual tax payments that taxpayers can allocate to CSOs187
.
Targeted funding aimed at supporting CSOs’ technical and financial capacities is also
available188
.
182
ENNRHI (2025), p. 363.
183
Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed
and closed.
184
Country visit Portugal, Platform NGOD. 2024 Rule of Law Report, Portugal, pp. 31-32. Civil Society
Europe (2025), written input, p. 11.
185
FRANET (2025), p. 14.
186
ENNHRI (2025), p. 364; FRANET (2025), p. 6.
187
Country visit Portugal, Platform NGOD.
188
FRANET (2025), p. 9.
19
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2025 Rule of Law report
can be found at https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en.
Centre for Media Pluralism and Media Freedom (2025), Monitoring Media Pluralism in Europe in the
year 2024, Country report Portugal.
Civicus (2025), Monitor tracking civic space – Portugal, https://monitor.civicus.org/country/portugal.
Civil Society Europe (2025), Contribution from the Civil Society Europe for the 2025 Rule of Law
Report.
Constitutional Court, judgment of 19 December 2023, 892/2023.
Council of Bars and Law Societies of Europe (CCBE) (2025), Contribution from the Council of Bars
and Law Societies of Europe (CCBE) for the 2025 Rule of Law Report.
Council of Europe: Committee of Ministers (2022), H46-20 Vicente Cardoso group v. Portugal
(Application No. 30130/10) – Supervision of the execution of the European Court’s judgments DH-
DD(2022)1119.
Council of Europe: Committee of Ministers (2010), Recommendation CM/Rec(2010)12 of the
Committee of Ministers to member states on judges: independence, efficiency and responsibilities.
Council of Europe: Committee of Ministers (2025), Supervision of the execution of judgments and
decisions of the European Court of Human Rights, 18th Annual Report of the Committee of Ministers,
https://rm.coe.int/gbr-2001-18e-rapport-annuel-2024/1680b4d77d.
Council of Europe: Consultative Council of European Judges (CCJE) (2021), Opinion No. 24 (2021)
on the evolution of the Councils for the Judiciary and their role in independent and impartial judicial
systems.
Council of Europe: Venice Commission (2022), Bulgaria - Urgent Interim Opinion on the draft new
Constitution (CDL-AD(2020)035-e).
Court of Auditors (2024), Monitoring Report on Public Procurement covered by the Special Measures
provided for in Law no. 30/2021 (Acompanhamento da Contratação Pública abrangida pelas
Medidas Especiais previstas na Lei n.º 30/2021 – 3.º Relatório), https://www.tcontas.pt/pt-
pt/ProdutosTC/Relatorios/relatorios-oac/Documents/2024/rel-oac001-2024-all.pdf.
Court of Auditors (2024a), Newsletter of December 2024 (Boletim mensal de fiscalização prévia -
dezembro de 2024), https://www.tcontas.pt/pt-
pt/Documents/Boletins%20Mensais%202024/BMFP_2024_dez.pdf.
Diário de Notícias (2024), Global Media and Páginas Civilizadas sell their shares in Lusa (Global
Media e Páginas Civilizadas vendem participação na LUSA), https://www.dn.pt/sociedade/global-
media-e-paginas-civilizadas-vendem-participacao-na-lusa.
Directorate-General for the Administration of Justice (2024), Staff map (Mapa de Pessoal Oficiais de
Justiça), https://dgaj.justica.gov.pt/Tribunais/Funcionarios-deJustica/Mapas-de-pessoal-oficiais-de-
justica.
20
Draft Law No 179/XVI/1.A (PAN) regulating lobbying and establishing a transparency register and a
legislative footprint mechanism.
Draft Law No 190/XVI/1.A (IL) regulating lobbying in Portugal and establishing the transparency
system for public authorities.
European Association of Judges (EAJ) (2025), Contribution from EAJ for the 2025 Rule of Law
Report.
European Centre for Press and Media Freedom (2025), Mapping Media Freedom, Portugal country
profile.
European Commission (2025), 2025 EU Justice Scoreboard.
European Commission (2025a), 2025 European Semester Country Report for Portugal.
European Commission (2025b), Flash Eurobarometer 557 on Businesses’ attitudes towards
corruption in the EU.
European Commission (2024), 2024 EU Justice Scoreboard.
European Commission (2024), 2024 Rule of Law Report, Country Chapter on the rule of law situation
in Portugal.
European Commission (2024), 2024 European Semester Country Report for Portugal.
European Commission (2024), Special Eurobarometer 561 on Corruption.
European Court of Human Rights, judgment of 5 July 2011, Moreira Ferreira v. Portugal, 19808/08.
European Implementation Network (2025), Contribution from the European Implementation Network
(EIN) for the 2025 Rule of Law Report.
European Network of Councils for the Judiciary (2025), Contribution from the European Network of
Councils for the Judiciary (ENCJ) for the 2025 Rule of Law Report.
European Network of National Human Rights Institutions (2025), Contribution from the European
Network of National Human Rights Institutions for the 2025 Rule of Law Report.
European Public Prosecutor’s Office (EPPO) (2025), Contribution from EPPO for the 2025 Rule of
Law Report.
European Public Prosecutor’s Office (EPPO) (2025), Annual report.
Expresso (2024), New law limits access to politicians' asset declarations (Nova lei limita acesso às
declarações de patromónio dos políticos), https://expresso.pt/politica/2024-08-14-nova-lei-limita-
acesso-as-declaracoes-de-patrimonio-dos-politicos-50e26a84.
Expresso (2024a), Journalists' Union considers new law limiting access to politicians' wealth
declarations “serious” (Sindicato dos Jornalistas considera grave nova lei que limita acesso às
declarações de património dos políticos), https://expresso.pt/politica/2024-08-15-sindicato-dos-
jornalistas-considera-grave-nova-lei-que-limita-acesso-as-declaracoes-de-patrimonio-dos-politicos-
1056a808.
Franet, Centre for Social Studies (2025), Civic space in the EU: Mapping of national approaches to
civic space monitoring, participation and protection – Portugal, EU Agency for Fundamental Rights.
21
Global Alliance of National Human Rights Institutions (GANHRI), Sub-Committee on Accreditation
(SCA) (2024), Report and Recommendations of the Session of the Sub-Committee on Accreditation
(SCA), Online, 26-28 March 2024 Geneva, 29 April-3 May 2024.
GRECO (2024), Fifth Evaluation Round, Evaluation Report on Portugal on Preventing corruption
and promoting integrity in central governments (top executive functions) and law enforcement
agencies.
GRECO (2024a), Fourth Evaluation Round – Third Interim compliance report on Portugal on
preventing corruption in respect of members of parliament, judges and prosecutors.
High Council for the Judiciary (2025), Megaprocedures and criminal procedure: charter for efficiency
and better justice – Working group presents conclusions to the CSM plenary(“Megaprocessos e
processo penal: carta para a celeridade e melhor justiça” – Grupo de trabalho apresenta conclusões
ao Plenário do CSM), https://csm.org.pt/megaprocessos-e-processo-penal-carta-para-a-celeridade-e-
melhor-justica-grupo-de-trabalho-apresenta-conclusoes-ao-plenario-do-csm/.
IMPIC (2024), 2023 Annual Report on Public Procurement in Portugal (Relatório Annual de
Contratação Pública em Portugal), https://www.base.gov.pt/Base4/pt/noticias/2024/relatorio-anual-
de-contratacao-publica-em-portugal-2023/.
Jornal de Negócios (2024), Big procedures pending in Tax Courts amount to over 12 thousand million
(Grandes processos parados nos tribunais fiscais somam mais de 12 mil milhões),
https://www.jornaldenegocios.pt/economia/justica/detalhe/grandes-processos-parados-nos-tribunais-
fiscais-somam-mais-de-12-mil-milhoes.
Magistrats Européens pour la Démocracie et les Libertés (MEDEL) (2025), Contribution from
Magistrats Européens pour la Démocracie et les Libertés (MEDEL) – Portugal for the 2025 Rule of
Law Report.
MENAC (2025), Annual Report 2024 (Relatório Annual 2024).
Ministry of Justice (2025), Government reviews payment table for state-appointed (Governo revê
Tabela de honorários dos advogados oficiosos), https://justica.gov.pt/Noticias/Governo-reve-Tabela-
de-honorarios-dos-advogados-oficiosos.
Observador (2024), Transparency entity makes access to politicians' statements more difficult
(Entidade da Transparência tona acesso às declarações dos pólíticos mais difícil),
https://observador.pt/especiais/entidade-da-transparencia-torna-acesso-as-declaracoes-dos-politicos-
mais-dificil/.
OECD (2024), Working Group on Bribery, Phase 4 evaluation of Portugal.
Parliament (2024), Registry of interests of the members of the Government (Registo de interesses de
Membros do Governo) https://www.parlamento.pt/RegistoInteresses/Paginas/Arquivo-
RegistoInteressesMG.aspx
Portuguese Government (2022), National Anti-Corruption Strategy 2020-2024 (Estratégia Nacional
Anticorrupção 2020-2024), https://justica.gov.pt/Estrategia-Nacional-Anticorrupcao-2020-2024.
Portuguese Government (2024), Anti-corruption Agenda (Agenda Anti-corrupção).
Portuguese Government (2024a), Government to take decisions to speed up implementation of
European funds (Governo vai tomar decisões para acelerar execução de fundos europeus),
22
https://www.portugal.gov.pt/pt/gc24/comunicacao/noticia?i=governo-vai-tomar-decisoes-para-
acelerar-execucao-de-fundos-europeus.
Portuguese Government (2024b), Media Action Plan (Plano de Ação para a Comunicação Social),
https://www.portugal.gov.pt/pt/gc24/comunicacao/documento?i=plano-de-acao-para-a-comunicacao-
social.
Portuguese Government (2025), Input from Portugal for the 2025 Rule of Law Report.
Portuguese Government (2025a), New rules for case allocation: maximum Transparency and
efficiency in Justice – Questions and Answers (Novas regras na distribuição de processos judiciais:
transparência máxima e celeridade na Justiça Perguntas & Respostas),
https://www.portugal.gov.pt/download-
ficheiros/ficheiro.aspx?v=%3D%3DBQAAAB%2BLCAAAAAAABAAzNDExNQAAi7agggUAAA
A%3D.
Portuguese Government (2025b), Resolution of the Council of Ministers 102/2025, of 5 June 2025.
Público (2025), Complaint to the Ombudsperson about PSP operation in Martim Moniz gathers over
700 signatures (Queixa à Provedora de Justiça sobre operação da PSP no Martim Moniz reúne mais
de 700 assinaturas), https://www.publico.pt/2025/01/05/politica/noticia/queixa-provedora-justica-
operacao-psp-martim-moniz-reune-600-assinaturas-2117645.
Renascença (2024), Operation Marquês. Ten years of statute of limitations, appeals and no trial of
Sócrates (Operação Marquês. Dez anos de crimes prescritos, recursos e sem julgamento de Sócrates),
https://rr.sapo.pt/noticia/pais/2024/11/21/operacao-marques-dez-anos-de-crimes-prescritos-recursos-
e-sem-julgamento-de-socrates/402424/.
Transparency International (2025), Corruption Perceptions Index 2024.
Union of Prosecutors (2025), Open letter (Carta Aberta), https://smmp.pt/wp-
content/uploads/2025/06/Carta-Aberta-Versao-Final.pdf .
23
Annex II: Country visit to Portugal
The Commission services held virtual meetings in April 2025 with:
• Association of Private Media
• Bar Association
• Central Department of criminal action and investigation (DCIAP)
• Constitutional Court
• Court of Auditors
• High Council for the Administrative and Tax Courts
• High Council for Public Prosecution
• High Council for the Judiciary
• ICNOVA – Nova University of Lisbon
• Inspectorate-General of Finance
• Journalists’ Professional License Committee
• Journalists’ Union
• Judiciary Police (Polícia Judiciária)
• Judges Union (ASJP)
• Media Authority – Regulatory Entity for Social Communication
• MENAC (Anti-corruption Mechanism)
• Ministry of Foreign Affairs
• Ministry of Justice
• Observatory of Economy and Fraud Management
• Office of the Prosecutor General
• Office of the Ombudsperson
• Platform of NGOD
• Political Accounts and Financing Entity
• Portugal MediaLab
• Prosecutors Union (SMMP)
• RTP – Radio and Television of Portugal
• Secretariat General of the Presidency of the Council of Ministers
• Services of the Assembly of the Republic
• Supreme Administrative Court
• Supreme Court of Justice
• Transparency Entity
• Transparency International – Portugal
• Union of ‘Funcionários Judiciais’
• Union of ‘Oficiais de Justiça’
* The Commission also met the following organisations in a number of horizontal meetings:
• Amnesty International
• Araminta
• Civil Liberties Union for Europe
• Civil Society Europe
24
• European Civic Forum
• European Partnership for Democracy
• European Youth Forum,
• International Commission of Jurists
• International Federation for Human Rights (FIDH)
• JEF Europe
• Philea – Philanthropy Europe Association.
• Transparency International