Portugal’s Insurance & Pension Supervisor Advances Anti-Corruption Framework

Key Takeaways

• Portugal’s ASF Approves PPR 2025: The Insurance and Pension Funds Supervisory Authority has approved its updated Corruption and Related Offenses Risk Prevention Plan for 2025.
• Part of National Anti-Corruption Framework: The plan forms one of the required compliance elements under Portugal’s Regime Geral de Prevenção da Corrupção (RGPC).
• Clearer Risk Ownership: The new plan refines how responsibilities are assigned across ASF units, ensuring each organizational unit is accountable only for the risks directly tied to its activities.
• Guided by MENAC: The update incorporates guidance from the National Anti-Corruption Mechanism (MENAC).
• Part of a Broader Integrity Program: PPR 2025 operates alongside codes of conduct, ethics oversight, training, and whistleblowing channels to support a culture of prevention.

Deep Dive

Portugal’s Insurance and Pension Funds Supervisory Authority (ASF) has approved its updated Corruption and Related Offenses Risk Prevention Plan for 2025, the latest step in the agency’s effort to strengthen internal governance and reinforce public confidence in the supervision of Portugal’s insurance and pension fund sectors.

The new plan builds on the framework introduced in 2022 and revised in 2023. ASF said this year’s update reflects lessons learned from applying the earlier version, along with changes in its internal structure and new guidance from the National Anti-Corruption Mechanism (MENAC), which supports public bodies in implementing anti-corruption programs.

While the plan fulfills obligations under Portugal’s Regime Geral de Prevenção da Corrupção (RGPC), ASF emphasized that it is meant to be more than a compliance document. The agency described it as a practical reference designed to shape day-to-day decision-making, clarify expectations, and promote consistent standards of conduct across the organization.

Refining Roles and Responsibility

One of the key adjustments in the 2025 plan is a clearer mapping of responsibilities across ASF’s departments. During the previous cycle, some risk mitigation measures had been assigned to units that played only a limited part in related activities. The new version narrows those assignments so that each organizational unit is accountable specifically for the areas where it has operational responsibility.

ASF said the goal is to simplify oversight and make the prevention framework more workable in practice. In some areas, particularly supervision and public procurement, responsibilities remain shared due to the cross-cutting nature of the work.

The plan is supported by ASF’s current internal governance framework, which includes:

• A Compliance Officer designated in 2024 to oversee the application of the compliance program.
• The Advisory Committee on the Corruption Prevention Regime, which provides guidance on implementation.
• The Internal Control Office, created during ASF’s 2024 restructuring, which brings together internal audit, data protection, and compliance oversight in one structure.
• The ASF Board and individual directorates, which are responsible for applying the measures relevant to their roles.

ASF noted that the plan is reviewed every three years, as required under the RGPC, but ongoing assessments are expected to continue refining it.

Part of a Broader Integrity Culture

Alongside the plan, ASF maintains codes of conduct for staff and leadership, internal ethics training, and whistleblowing channels for reporting concerns. These elements are intended to complement one another, forming a broader integrity framework rather than operating in isolation.

The emphasis, ASF said, is on building a “culture of prevention”, one in which identifying and managing ethical risk is treated as a normal and routine part of public oversight work.

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