Conflicts of interest: ending the grey areas in Public Administration*
There are subjects everyone recognizes as important, yet for various reasons they keep slipping off the agenda. Conflicts of interest are one of those cases. Not because they are ignored, but because they are often pushed into grey areas that are difficult to turn into daily practice.
In August 2026, however, they cease to be a diffuse risk and become an explicit legal requirement: the adaptation period established by Decree-Law no. 109-E/2021 comes to an end, and all public entities (and private companies with 50 or more employees performing public functions) will be required to have processes, systems and practices fully prepared to collect, store and verify the Declaration of Absence of Conflicts of Interest (DACI, DICI in Portuguese) in all sensitive procedures.
This means that whenever a process involves procurement, licenses, subsidies or decisions with economic impact, the impartiality of those involved can no longer be assumed; it must be verified. And that requires method, record-keeping, and software solutions capable of sustaining practices that may have been informally adjusted over time but now gain a new level of structure and formalization.
The scope of the legislation is broad and covers ministries, municipalities, public institutes, public companies, regulatory entities and any organization managing public funds. It also extends to private companies that provide services to the State or execute contracts financed by public resources. In practice, all these organizations will need to review internal processes, clarify responsibilities and ensure that every decision is documented, auditable and immune to suspicion.
For many entities, the greatest challenge will not be filling out the declarations themselves, but the absence of processes capable of integrating them into everyday workflows. The DICI requires identifying every stakeholder in a procedure, ensuring that each one declares the absence of conflicts, and guaranteeing that all information is recorded in a coherent, secure and traceable way. Without digital systems to support this routine, the risk of failures, omissions or dispersed declarations is high; and the impact potentially severe.
From a management perspective, however, 2026 should not be seen as a threat; on the contrary, it represents a turning point. Requiring the declaration of conflicts places integrity at the core of decision-making. It strengthens processes before doubts arise, reduces room for informal pressures, and introduces a level of discipline that (when properly implemented) increases the confidence of all involved: citizens, suppliers, internal teams and political decision-makers.
As a Product Manager at Quidgest, a technology company experienced in working with the public sector, I believe the challenge does not lie in the law itself, but in how organizations need to adjust their processes to comply with it. Entities that have already begun mapping workflows, defining responsibilities and digitalizing their processes are experiencing this transition as a natural step forward. Those that postpone it inevitably face operational strain and reputational risk.
The DICI arrives to reinforce trust in a system that can only function when decisions are clear, ethical and verifiable. And 2026 will be the year in which Public Administration is assessed not only by what it decides, but by what it can prove about how those decisions were made.
This article was originally published in Link to Leaders.
