Dili, 16 September 2026 – The Ombudsman for Human Rights and Justice (PDHJ), Virgílio da Silva Guterres “Lamukan”, together with his delegation, attended a hearing with Committee C of the National Parliament, which is responsible for public finance matters, to share views and discuss the Draft Law No. 29/VI (3rd) – General Regime for Administrative Fees.
During the hearing, Ombudsman Guterres raised several issues that, from the PDHJ’s perspective, require careful consideration, particularly regarding administrative equity and citizens’ access to public services.
The Ombudsman stressed that the application of administrative fees should take into account the different circumstances of citizens living in urban areas and those in rural and remote communities. “Sometimes we apply the same fee to everyone, but the costs of accessing public administration are not the same. People in Dili may have easier access compared to those living in remote areas,” Ombudsman Guterres said.
He cited access to passport services as a practical example. While citizens in Dili may be able to access the service relatively easily, citizens living in remote areas may have to pay for transportation and spend one or two days travelling to Dili and waiting to obtain their documents. Therefore, the actual costs faced by citizens in accessing public services should also be considered when developing and implementing the law, in order to avoid creating situations that could result in inequality or injustice.
The Ombudsman also highlighted the need for clear definitions and mechanisms for exemptions or special consideration for vulnerable groups, including persons with disabilities, older persons, and citizens who lack sufficient economic capacity to pay administrative fees.
Another issue raised was the need for the formula and basis for calculating administrative fees to be clearly defined and transparent, including the reference used to determine the amount of each fee. The Provedor also called for clear procedures regarding the payment and application of administrative fines and penalties, including clarification on where and how such payments should be made.
The Ombudsman further emphasised the importance of ensuring citizens’ right to challenge administrative decisions when they receive information or decisions that they consider to be incorrect. Citizens should have an opportunity to submit an administrative appeal and request clarification from the relevant authority before pursuing judicial proceedings.
Where the response or explanation provided by the administrative authority is insufficient or unsatisfactory, citizens should have the possibility to further appeal to the courts in accordance with applicable legal procedures.
These issues will inform the PDHJ’s formal opinion on the Draft Law, which will subsequently be submitted to Committee C of the National Parliament.
At the conclusion of the hearing, Ombudsman Guterres expressed his appreciation to the Chair of Committee C, Cedelízia Faria dos Santos, for inviting the PDHJ to provide its views on the proposed legislation, particularly given that the application of administrative fees or charges may directly affect citizens and their right to access public administration.
The hearing was held at the National Parliament’s Hearing Room and chaired by Committee C Chair Cedelízia Faria dos Santos. It was attended by PDHJ Deputy Ombudsman for Human Rights Maria Marília da Costa, Executive Secretary Ambrosio Graciano Soares, members of the PDHJ legal team, President of the Court of Appeal Afonso Carmona and his team, and members of Committee C of the National Parliament.
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