🇵🇹 Data and documents in Portugal

General overview

The Portuguese corporate information system offers high-quality data that is accessible online, albeit through a distinctive framework that differs from many other European jurisdictions. While the websites may not be the most intuitive to navigate, the information is centralized through the Ministry of Justice, which manages the country's business registries.

This cost structure can be challenging for entities conducting due diligence on multiple Portuguese companies, as the expenses quickly accumulate.

Official Registers Sources

Portugal's corporate information is managed through several official registers, each with different purposes and access conditions.

Portal da Justiça (Justice Portal)

This is Portugal's official journal for company information. Available at https://publicacoes.mj.pt, this portal publishes official notices on company documents and changes. The portal allows public searches with free access to these notices, mainly using the company's NIPC as a search parameter.

However, the portal has significant limitations. In addition to its somewhat complicated navigation, it does not present an up-to-date company extract. This means that to find out the basic information about a company, its directors and shareholders, you'll need to retrieve all the notes on the company in question, analyze them in their entirety and then reconstruct the up-to-date version of the company.

Despite these limitations, Portal da Justiça remains a valuable tool for tracking corporate events without purchasing certificates.

Registo Comercial Online

Registo Comercial Online (https://registo.justica.gov.pt) is Portugal's central register for official company documentation. This platform provides access to permanent certificates, articles of association and other official documents that form the backbone of thorough due diligence.

The register offers comprehensive and up-to-date official information, but at a high price. A certified extract from the register, for example, costs 25 euros, while status documents cost 20 euros.

Registo Central do Beneficiário Efetivo (RCBE)

The Registo Central do Beneficiário Efetivo (RCBE), accessible at https://rcbe.justica.gov.pt, is Portugal's central register of beneficial owners. Created to comply with European anti-money laundering directives, this register theoretically increases transparency of ownership, but has practical obstacles to access.

Access to the register is limited to Portuguese nationals and authenticated professionals. This limitation is a major obstacle for international compliance teams.

The UBO register covers all companies, with the exception of listed entities (which are subject to separate transparency requirements).

With Semaphore

All data and documents are available through the Semaphore API

Available data

When conducting due diligence on Portuguese companies, compliance professionals typically require access to several types of data. Here's what's available and how it can be accessed.

Company profile data

• Company name
• Legal form
• Registered address
• Tax identification number (NIPC)
• Date of incorporation
• Business activity codes
• Share capital
• Current status (active, dissolved, etc.)

Legal representatives

Data available about company directors includes:

• Names of legal representatives
• Management structure
• Directors' appointments and terminations
• Powers of representation

Shareholders

Data available about company shareholders includes:

• Names of shareholders
• Percentage of ownerships
• Name of intermediary company

Ultimate Beneficial Ownership (UBO) Data

Portugal maintains a central UBO register (Registo Central do Beneficiário Efetivo or RCBE), but with significant access restrictions:

• Basic UBO information is supposed to be publicly accessible
• Detailed UBO data is only available to authenticated professionals
• In practice, both levels of access require Portuguese nationality or authorized local representatives
• For foreign entities performing due diligence, working with local authorized professionals is necessary

Available documents

Certidão Permanente (Permanent Certificate)

Similar to an up-to-date certified register extract, the certidão permanente this is an official, detailed document showing details of the company's registration, management and status.

It is continuously updated electronically and is available to the public through Registo Comercial at a cost of 25 euros on the registry. The permanent certificate contains complete information on the legal entity.

Estatutos Atualizados & Pacto Social (Articles of Association & Company)

This document establishes company structure, rules, and shareholder agreements. It is available as a permanent certificate for €20 on the registry.

Relatório e Contas (Annual Report and Accounts)

These financial statements and management reports are available for €5 on the registry and accessible through the Justice Ministry portal. The Relatório e Contas is a standardized document where the balance sheet and the income statements are always displayed.

Beneficiário Efetivo (UBO Declaration)

This Beneficiario Efetivo document provides information on beneficial owners. Despite restrictions, it is accessible and can help you in your data collection process.

Strengths & limitations

Strenghts:

1. Data Quality: Company information is of good quality and centralized through the Ministry of Justice
2. Up-to-date Information: The permanent certificate system ensures that information is continuously updated
3. Comprehensive Coverage: All registered entities are included in the system
4. Digital Transformation: Portugal has made significant progress in digitizing its corporate registries
5. Standardized Format: Information is presented in a consistent format across all companies

Limitations and Challenges:

1. Cost Barriers: The subscription-based model makes comprehensive due diligence expensive
2. Access Restrictions: Many services require Portuguese nationality or digital authentication
3. UBO Access Limitations: Beneficial ownership information is particularly difficult for foreign entities to access
4. User Experience: Website navigation can be challenging, with multiple platforms handling different aspects