Banking and payments
Banco de Portugal for credit and financial institutions, PI and EMI, exchange offices and credit intermediaries; ECB for bank decisions in the SSM.
Jurisdiction dossier
Portugal financial permissions and regulator dossier
Banco de Portugal authorises and supervises credit institutions, financial companies, payment institutions, electronic money institutions and credit intermediaries, with the ECB deciding euro-area bank licences. The Comissão do Mercado de Valores Mobiliários (CMVM) supervises investment firms, markets, collective investment and crowdfunding. The Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF) authorises insurance, reinsurance, distribution and pension entities. Under Law 69/2025, Banco de Portugal leads MiCA CASP authorisation with formal CMVM input and a divided supervisory remit. This dossier is current as of July 2026.
Route facts
Portugal regulatory map
Securities and funds
CMVM for investment services, markets, collective investment undertakings, managers and crowdfunding within its statutory remit.
Insurance and pensions
ASF for insurers, reinsurers, insurance distributors, pension-fund management companies and pension funds.
Crypto split
Banco de Portugal receives and decides CASP applications; CMVM gives statutory opinions and supervises allocated conduct and market matters.
Transition date
The former Banco de Portugal AML virtual-asset registration expired by 1 July 2026 unless MiCA authorisation had already intervened.
Review date
Last reviewed against official regulator and Diário da República material on 11 July 2026.
Read the allocation first
Institution type controls both activity and regulator
Portuguese law provides a detailed institution taxonomy. A bank can accept deposits and carry out the operations permitted to credit institutions. A credit financial institution, leasing company, factoring company, mutual-guarantee company, regional-development company or microcredit financial company has the narrower activities assigned to its form. A PI may provide its authorised payment services, while an EMI can issue e-money and approved payments. An exchange office, credit intermediary or account-information provider has a distinct status and cannot use that label to accept deposits or provide unrestricted payments.
Investment products and services sit on a different layer. An investment firm or manager must hold the CMVM status for its services, and a collective investment undertaking follows its product regime. Insurance and pension permissions sit with ASF. MiCA is now split by law: Banco de Portugal receives Article 60 notifications and Article 62 applications and makes the CASP decision, while CMVM gives opinions on completeness and compliance within its Title V remit. The old AML registration does not survive as an operating substitute after 1 July 2026.
Permission matrix
Portugal licence, authorisation and registration families
| Permission family | Regulator and instrument | Activities and exclusions | Entry and capital basis |
|---|---|---|---|
| Permission family Banks and other credit institutions | Regulator and instrument ECB authorisation with Banco de Portugal assessment under the SSM and Portuguese banking law | Activities and exclusions Accept deposits and perform banking operations available to the institution type and grant; no financial company, PI, EMI or credit intermediary may take deposits merely from that status | Entry and capital basis Portuguese establishment, qualifying holders, fit-and-proper management, programme, governance and CRR capital, liquidity, recovery and risk evidence |
| Permission family Financial companies, leasing, factoring and microcredit | Regulator and instrument Banco de Portugal authorisation for the applicable financial-company category | Activities and exclusions Credit, leasing, factoring, guarantees, regional development, microcredit or other statutory finance within the category; public deposits and some payment activities remain excluded | Entry and capital basis Legal form, Portuguese head office, owners and management, funding, credit governance, prudential resources, consumer treatment and AML/CFT depend on category |
| Permission family Payment institution | Regulator and instrument Banco de Portugal authorisation under the Legal Regime of Payment Services and Electronic Money | Activities and exclusions Approved account, execution, card, acquiring, remittance, initiation or account-information services; no e-money issuance or deposit taking merely from PI status | Entry and capital basis Initial and ongoing own funds vary by services and volume; safeguarding, governance, security, AML/CFT, agent, outsourcing and incident arrangements |
| Permission family Electronic money institution and AISP | Regulator and instrument Banco de Portugal EMI authorisation or AISP registration under Portuguese payment law | Activities and exclusions EMI status permits e-money issuance and approved payments; AISP status covers account information only and neither status authorises deposits | Entry and capital basis EMI capital, own funds, safeguarding, redemption and distributor oversight differ from AISP professional cover, registration and security requirements |
| Permission family Exchange office and money-changing | Regulator and instrument Banco de Portugal authorisation for exchange-office activity and any separate payment permission triggered | Activities and exclusions Purchase and sale of foreign notes, coins and travellers' cheques plus the ancillary operations allowed by law; no remittance, e-money or deposits automatically follow | Entry and capital basis Accepted legal form, management, operating premises, financial resources, transaction controls and AML/CFT follow the exchange-office status |
| Permission family Investment firm and trading venue | Regulator and instrument CMVM authorisation and supervision under the Securities Code and MiFID II, with prudential coordination where required | Activities and exclusions Reception and transmission, execution, dealing, portfolio management, advice, underwriting, placement, custody and venue operation only where granted | Entry and capital basis Portuguese head office, qualifying holders, suitable management, prudential class, client-assets, market conduct, conflicts and compensation arrangements |
| Permission family UCITS manager, AIFM and collective investment undertaking | Regulator and instrument CMVM authorisation or registration under Portuguese collective-investment law and UCITS or AIFMD | Activities and exclusions Manage collective portfolios and establish or market the applicable fund; manager, product, depositary, administrator and distributor remain separate statuses | Entry and capital basis Full or registered manager status sets own funds, risk, valuation, delegation and reporting; product form sets prospectus, depositary, investments and investor rules |
| Permission family Insurance and reinsurance | Regulator and instrument ASF authorisation under Portuguese insurance law and Solvency II | Activities and exclusions Underwrite approved life, non-life or reinsurance classes; distribution status never permits an intermediary to carry underwriting risk | Entry and capital basis Portuguese head office, qualifying holders, fit-and-proper board and key functions, governance, technical provisions, minimum and solvency capital |
| Permission family Insurance and reinsurance distribution | Regulator and instrument ASF registration or authorisation in the applicable mediation or distribution category | Activities and exclusions Advise, propose, arrange or assist insurance contracts within the registered role; no insurer, investment, payment or deposit-taking authority follows | Entry and capital basis Professional knowledge, good repute, professional indemnity, client-money, organisational, conduct and continuing-training requirements depend on category |
| Permission family Pension-fund manager and pension fund | Regulator and instrument ASF authorisation, approval or registration under Portuguese pension-fund law | Activities and exclusions Manage pension funds or operate the approved fund and membership arrangements; pension status is not an insurer, investment firm or bank licence | Entry and capital basis Management-company resources, suitable owners and key functions, fund constitution, governance, actuarial or funding method, investment, custody, disclosures and reporting |
| Permission family Consumer and mortgage credit intermediary | Regulator and instrument Banco de Portugal authorisation and registration under the credit-intermediary regime | Activities and exclusions Present, propose, prepare or conclude credit agreements and provide permitted advice within the intermediary category; no balance-sheet lending or deposit taking follows | Entry and capital basis Good repute, knowledge and competence, professional indemnity, lender relationships, organisational and consumer-disclosure requirements |
| Permission family Crowdfunding service provider | Regulator and instrument CMVM authorisation under Regulation (EU) 2020/1503 | Activities and exclusions Operate an investment- or lending-based ECSPR platform; no deposit taking, unrestricted lending or regulated-market authority follows | Entry and capital basis Prudential safeguards, governance, conflicts, investor protection, credit assessment where used, default handling, complaints and continuity |
| Permission family Crypto-asset service provider | Regulator and instrument Banco de Portugal Article 63 MiCA authorisation or Article 60 notification with statutory CMVM review under Law 69/2025 | Activities and exclusions Approved custody, platform, exchange, execution, placing, order, advice, portfolio-management or transfer services; legacy AML registration is no current substitute | Entry and capital basis EU registered office and effective management, suitable owners and managers, MiCA safeguards, custody, conduct, complaints, ICT, conflicts and AML/CFT |
| Permission family ART and EMT issuer | Regulator and instrument Banco de Portugal authorisation or notification under MiCA Titles III and IV, with CMVM cooperation on classification and allocated conduct matters | Activities and exclusions Issue qualifying asset-referenced or e-money tokens within the permitted issuer status; EMT issuance remains reserved to credit institutions and EMIs | Entry and capital basis Reserve, custody, redemption, governance, own funds, disclosure and recovery requirements depend on token classification and significance |
| Permission family Fiduciary, company and trust administration | Regulator and instrument No general Banco de Portugal or CMVM trust-company licence; reserved financial, legal, accounting and AML-supervised functions remain activity-specific | Activities and exclusions Company formation and ordinary administration do not confer custody, payment, investment or banking authority; asset-holding and fiduciary functions require individual classification | Entry and capital basis Confirm professional eligibility, Portuguese establishment, beneficial ownership and AML/CFT obligations and any separate investment, fund, insurance or payment permission |
| Permission family Online gambling and betting | Regulator and instrument SRIJ licence under Portugal's separate online gambling and betting regime | Activities and exclusions Offer only the licensed game or betting categories through approved systems and domain arrangements; no financial-services authority follows from the licence | Entry and capital basis Ownership, suitability, technical certification, player protection, financial guarantees, game controls, tax and AML/CFT follow the SRIJ route |
Entry test
Portuguese substance, suitability and financial resources
Applicants use the legal form and registered office and head office required for the institution. Banco de Portugal, CMVM and ASF assess direct and indirect qualifying holders, source of funds, directors, effective management and key function holders. The governance map identifies compliance, MLRO, risk, finance, internal audit, security and responsibility for agents, distributors, delegates and outsourcing. Vendors can support operations but cannot replace the local management and control required by the licence.
Capital follows the route: CRR for banks, category rules for financial companies, PSD2 and e-money calculations, the investment-firm prudential class, manager own funds, Solvency II, pension-manager requirements, crowdfunding safeguards and MiCA safeguards. Client funds, financial instruments, insurance assets and crypto-assets use different safeguarding or custody rules. Current regulator fee schedules and application pages control charges and any published decision clock. One EUR headline cannot describe the perimeter.
Application path
A Portugal authorisation, stage by stage
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Map activities and authorities
Identify deposits, credit, payments, e-money, investment, management, funds, insurance, pensions, crypto, fiduciary and gambling functions and assign Banco de Portugal, CMVM, ASF, ECB or SRIJ.
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Confirm legal form and filing channel
Use official sector and SSM guidance to settle the institution category, owners, management, prudential method, pre-application engagement and any statutory inter-authority opinion.
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Build the Portuguese operating file
Prepare programme, forecasts, ownership and suitability, governance, AML/CFT, safeguarding or client assets, product and conduct controls, outsourcing, DORA, continuity and wind-down.
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Complete substantive review
Answer completeness and technical questions and any regulator consultation. A legacy register entry, pending file or product approval grants no broader operating status.
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Satisfy conditions before launch
Complete capital, appointments, systems, agreements, reporting and register publication. EEA activity starts only after the applicable notification procedure.
After authorisation
Ongoing supervision and change in control
Portuguese institutions maintain capital or solvency, governance, AML/CFT, audit, regulatory returns, safeguarding or client assets, complaints, product and conduct duties, outsourcing, incident reporting and DORA resilience. Funds, insurance and pension structures maintain product, valuation, custody, funding, member or investor and reporting duties. New services, branches, agents, critical outsourcing, products or token functions can require approval, variation or notification.
A buyer acquires shares in the supervised company; the licence does not detach. Proposed qualifying holdings and control changes follow the Banco de Portugal, CMVM, ASF or ECB process allocated to the institution. Diligence should reconcile the current register, exact grant, capital headroom, client assets, complaints, inspections, enforcement, outsourcing and remediation. Legacy virtual-asset registration expired under the 2026 transition and must not be treated as MiCA status. The authority assesses the incoming holder; no adviser can guarantee approval.
Territorial reach
Portuguese home-state rights remain service-specific
A fully authorised Portuguese bank, PI, EMI, investment firm, manager, insurer or CASP may use the EU or EEA notification mechanism in its governing legislation for the services on its grant. A financial-company category, exchange-office or credit-intermediary status, national fiduciary activity, product approval or SRIJ gambling licence does not create a general passport. Host-state consumer, conduct, distribution and general-good rules remain relevant. Third-country business requires separate target-market analysis.
Verify it yourself
Primary Portugal sources
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Banco de Portugal institution and register pages
bportugal.pt and the Bank Customer portal define banks, financial companies, PI, EMI, exchange offices and credit intermediaries and publish authorised entities.
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CMVM institutional portal
cmvm.pt publishes securities, investment-firm, manager, fund, crowdfunding and market rules and authorised-entity or product registers.
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ASF authorisations and registers
asf.com.pt publishes insurer, reinsurer, insurance-distributor, pension-manager and pension-fund authorisations, approvals and registers.
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Law 69/2025 in Diário da República
The official law allocates MiCA authorisation and supervision between Banco de Portugal and CMVM and sets the 1 July 2026 end of the legacy virtual-asset transition.
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ECB and SRIJ material
ECB Banking Supervision controls SSM bank decisions, while SRIJ and Turismo de Portugal publish the separate online-gambling licence and operator register.
01 Can a Portuguese financial company accept deposits?
Not merely from financial-company status. Public deposit taking is reserved to the credit- institution types allowed by law. Leasing, factoring, microcredit and other financial companies remain within their specific operations and funding rules.
02 Who authorises a Portuguese CASP?
Banco de Portugal receives and decides the application under Law 69/2025. CMVM gives statutory opinions and supervises the conduct and market matters allocated to it. Both authorities publish the authorised service scope.
03 Does the old Banco de Portugal VASP registration survive?
No as an operating alternative after the transition. Eligible active registrants could continue only until 1 July 2026 or an earlier grant or refusal. Current service requires MiCA authorisation or a valid Article 60 notification.
04 Does a fund approval license its manager?
No. The product and manager are separate. Portfolio and risk management, depositary, administration, investment services and distribution must be performed by eligible providers under their own status.
05 Can an authorised Portuguese company be acquired?
Shares may be acquired subject to the relevant qualifying-holding process. The permission stays with the company, incoming holders and funding are assessed, and the precise grant and supervisory history require diligence.
Reviewed by the SKY7 advisory team. Last reviewed: 11 July 2026. This dossier is general information, not legal, regulatory, tax, investment or financial advice. It describes the Portuguese framework as of July 2026. Verify current Banco de Portugal, CMVM, ASF, ECB and SRIJ rules, registers, licence conditions and fee schedules before relying on a route. No regulator outcome is promised.
Tell us what you need
Build the Portugal permission map first
Send the services, products, customers, flow of funds, custody model, target markets and ownership chain. SKY7 will identify Banco de Portugal, CMVM, ASF, ECB and specialist requirements before a filing or acquisition decision. Fees are on request.