--- title: "Portugal Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/portugal/ source_html: /jurisdictions/portugal/index.html description: "Portugal payments and e-money regulation: 14 modules, 69 sourced findings, updated 2026-10-27. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-27T09:21:10Z content_sha256: 337e732c66f5760a718709867bbdab1954c1df86dfec1bcab218e59104646244 generator: "fe-fleet/md-twin@1.0" --- # Portugal PT schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-27 · 14 modules · 69 sourced findings · 152 sources in the cumulative register Download report (PDF) Expand all 14 Modules 1 Moved this cycle 1 Key judgments 2 Open gaps 69 Findings 85 Tier-1 sources Confidence mix 13 confirmed 1 unpopulated (sums to 14 rendered modules; click to filter) 1 module moved this cycle Law made at European Economic Area level that applies in Portugal is covered once, on the [European Economic Area](/jurisdictions/european-economic-area/) page. This page covers Portugal’s own layer: implementation, national authorities, national options and local enforcement. ## Jurisdiction brief Jurisdiction lead brief 1,256 Full executive summary 445 Jurisdiction sub-brief 2 538 ###### Latest update · 25 October 2026 #### Lead Signal Portugal's digital-money regulatory story is one of structural throughput rather than rulemaking. The transitional regime that let virtual-asset operators registered with Banco de Portugal before 30 December 2024 keep trading pending full Markets in Crypto-Assets authorisation closed on 1 July 2026. After that date, continuing to operate without authorisation became a serious administrative offence under Portugal's MiCA-implementing statute, Lei n.º 69/2025. The operative question now is how many firms actually cleared the gate: the European Securities and Markets Authority's interim register of crypto-asset service providers, carrying a file dated 7 October 2026, shows only one Portugal-supervised entity holding full authorisation, against a much larger population authorised across the rest of the European Union. An industry body has flagged this as an authorisation-pipeline bottleneck. This is a capacity signal, not an enforcement one. Lei n.º 69/2025 splits supervisory competence cleanly between Banco de Portugal, which takes asset-referenced tokens and e-money tokens, and the Comissão do Mercado de Valores Mobiliários, which takes other crypto-assets and market conduct; the legal architecture itself is settled and clear. What is unsettled is whether that architecture is processing applications at a pace that matches the size of the market that previously operated under transitional cover. #### Other Developments No material development was located across licensing and market access, conduct and safeguarding, operational resilience, scheme and network rules, corridor dynamics, industry structure, litigation, merchant acquiring, product innovation, consumer protection and fraud, AML/CFT, correspondent banking, or commercial intelligence for Portugal. The single active signal sits entirely within the stablecoin and digital-money space. #### Cross-Monitor Connections The authorisation-pipeline bottleneck identified here is the same underlying fact that financial-integrity-focused tracking would read as a supervisory-capacity question: a jurisdiction with a settled legal architecture but an unclear pace of gatekeeping is a jurisdiction where the population of entities operating between the end of transitional cover and the grant of full authorisation is worth watching, independent of any confirmed misconduct. No sanctions, enforcement action, or illicit-finance nexus has been identified against any Portugal-supervised entity; the overlap is structural rather than evidentiary. #### Outlook The figure to track into the next reporting window is whether the Portugal-supervised authorisation count on the ESMA interim register moves meaningfully beyond one, or whether it remains flat while applications stay pending. A persistent flat count across multiple cycles would sharpen the read that the authorisation bottleneck is a durable capacity constraint at Banco de Portugal and the Comissão do Mercado de Valores Mobiliários rather than a one-off processing lag at the October snapshot date. No primary statement from either competent authority addressing throughput or expected clearance timing has been located. 6 earlier updates not shown here. ###### Standing brief · as of 5 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Portugal's crypto-asset and stablecoin regime crossed a structural threshold this cycle. Law 69/2025, published 22 December 2025, transposes MiCA nationally through a twin-peaks supervisory model: Banco de Portugal (BdP) takes prudential authority over asset-referenced and e-money token issuance and CASP authorisation, while CMVM supervises market conduct. This is the first dedicated national framework governing crypto-assets and stablecoins in Portugal; no equivalent regime existed beforehand. The framework's transitional bridge has now closed. Entities that had registered under Portugal's prior national regime were permitted to continue operating only until 1 July 2026 or until their MiCA authorisation was granted or refused, whichever came first. That deadline has now passed as of this cycle's 4 July 2026 reference date, and whether the CASP authorisation register is now complete for previously-registered entities -- or whether some have fallen into a gap between expired transitional cover and pending MiCA authorisation -- is unverified this cycle. The practical effect is a live market-access cliff-edge for any legacy-registered crypto-asset service provider whose MiCA application has not yet been resolved, a condition regulators, counterparties and payment-instrument partners will need to monitor directly rather than infer from the framework's headline completion. #### Other Developments Portugal's most significant recent banking-sector ownership change has also concluded. BPCE completed its acquisition of NovoBanco on 30 April 2026 for a final price of approximately EUR6.7 billion, closing a process that began in summer 2024, passed a memorandum of understanding in June 2025 and a sale-and-purchase agreement in October 2025. This corrects an earlier framing of the transaction as merely "expected" during 2025 and registers as the most notable structural M&A event in Portugal's financial sector in recent memory. Scheme-level competition tension continues to build around SIBS, the operator of the dominant Multibanco/MB WAY domestic card and interbank infrastructure. The Autoridade da Concorrencia fined SIBS Group EUR13,869,000 in 2024 for tying processing services to scheme access, a practice conducted while SIBS held over 90% market share in the affected markets for roughly three years. SIBS has since appealed the decision; under Portuguese administrative law, an appeal does not suspend fine execution unless SIBS demonstrates considerable harm and provides effective guarantees. The appeal's outcome remains unresolved this cycle. On the conduct-and-governance side, a challenge-stage correction clarifies that BdP's Notice No 2/2025 (published 20 March 2025) amends the base governance and internal-control framework of Notice No 3/2020, rather than standing as a freestanding instrument -- a distinction that matters for institutions tracking which obligations remain live under the base notice. Separately, a new BdP notice on advertising of financial products and institutional advertising was under public consultation as of late December 2025; whether it has since closed, finalised or remains open is unverified as of this cycle. Elsewhere, the EU's Digital Operational Resilience Act, fully applicable since 17 January 2025, has settled into place with BdP as Portugal's national focal point for major ICT-incident notification, working alongside ASF and CMVM; infringements can draw fines of up to EUR5 million, 10% of annual turnover, or three times the economic benefit derived. Consumer-facing signals are also moving: BdP recorded an 80% year-on-year rise in complaints, with fraud allegations behind 47.4% of them, though BdP's own remedial power is limited to compliance verification rather than compensation orders, leaving redress to the courts. On the commercial side, Bison Bank has announced plans to launch Portugal's first MiCA-compliant, fiat-pegged stablecoin, targeted for the first half of 2026, alongside broader blockchain-service ambitions. #### Cross-Monitor Connections Portugal's AML/CFT posture, carried into this brief via the Sentinel.gi feed rather than original WPM analysis, remains assessed by FATF as sound and effective, with recommended improvement in oversight of non-financial businesses and professions. Laws 70/2025 and 72/2025, in force since December 2025, strengthen the Travel Rule regime under Regulation (EU) 2023/1113 and criminalise restrictive-measures breaches respectively, amending the base Law 83/2017 AML/CFT and sanctions framework. These developments -- along with any illicit-finance use of the stablecoin instruments now entering the Portuguese market under Law 69/2025 -- are flagged onward to the Financial Intelligence Monitor for continued analysis; this brief does not draw independent illicit-finance conclusions from them. #### Outlook Four threads carry directly into the next cycle: the resolution of SIBS's appeal against the AdC tying-abuse fine; whether BdP's advertising and financial-promotions notice has been finalised since its December 2025 consultation; whether the MiCA CASP authorisation register is complete for entities that operated under Portugal's prior transitional regime now that the 1 July 2026 deadline has passed; and whether Bison Bank's stablecoin launches within its targeted first-half-2026 window. Together they describe a Portuguese payments environment in which the big structural moves -- MiCA transposition, DORA embedding, the NovoBanco ownership change -- have landed, while the granular compliance and enforcement follow-through behind each remains to be confirmed. Read full brief · 1256 words Standing brief, as of 5 July 2026. #### Regulatory Status Portugal's payments regulatory environment this cycle is best characterised as tightening across multiple fronts simultaneously, though from a starting position of comprehensive, stable EU-harmonised baselines. Licensing architecture (W1a) remains a stable, standard PSD2/EMD2 and CRD/CRR transposition, with non-bank PIs/EMIs authorised by Banco de Portugal under the RJSPME and credit institutions authorised exclusively by the ECB within the SSM. Conduct and safeguarding rules (W1b) saw a challenge-stage correction clarifying that BdP's Notice 2/2025 amends, rather than replaces, the base Notice 3/2020 governance framework, while a new advertising/promotions notice remains in an unverified consultation status. The most consequential single development is the crystallisation of Portugal's first dedicated stablecoin and crypto-asset framework: Law 69/2025 establishes a twin-peaks BdP/CMVM supervisory model under MiCA, and the transitional deadline for legacy-registered CASPs -- 1 July 2026 -- has now passed, creating an active market-access cliff-edge whose resolution is unverified. Operational resilience (W3) is settled under DORA, fully applicable since January 2025 with BdP as national ICT-incident focal point. Scheme competition remains contested (W4/W7/W8): SIBS's EUR13.869 million AdC tying-abuse fine is under SIBS's own appeal, with the outcome unconfirmed and acquiring-market structure remaining dependent on SIBS scheme access throughout. Corridor infrastructure (W5) and correspondent-banking/settlement access (W12) are both stable, with Eurosystem TARGET2/TIPS participation extending to non-bank PIs/EMIs where enabled and removing much of the correspondent-banking access asymmetry seen elsewhere. Portugal's most significant recent commercial-structural event, the completion of BPCE's acquisition of NovoBanco on 30 April 2026 for approximately EUR6.7 billion, corrects prior "expected 2025" framing and marks the most notable ownership change in the market. Product innovation (W9) continues via the digital euro's technical readiness phase and persistently slow open-banking/TPP adoption. Consumer protection (W10) shows an escalating signal in an 80% year-on-year rise in complaints, nearly half fraud-related, against a backdrop of BdP's compensation-limited remedial powers. AML/CFT (W11), carried via the Sentinel feed, remains assessed as sound and effective by FATF, reinforced by Laws 70/2025 and 72/2025 on the Travel Rule and sanctions. Commercial intelligence (W13) additionally captures Bison Bank's announced MiCA-compliant stablecoin and a fintech-funding increase of 129.83% year-on-year. #### Outlook Four items carry forward with the clearest bearing on Portugal's regulatory trajectory: the SIBS appeal outcome; the finalisation status of BdP's advertising/promotions notice; post-deadline completeness of the MiCA CASP authorisation register; and Bison Bank's actual stablecoin launch date within its targeted window. Collectively, Portugal's direction of travel is toward tightening -- more supervisory frameworks (MiCA, DORA), more active enforcement postures (SIBS appeal, rising complaints) -- layered onto an already mature, EU-harmonised baseline, with the major structural events of the cycle now landed and the compliance and enforcement follow-through still to be confirmed. Read full brief · 445 words ###### Latest update · 25 October 2026 #### Regulatory Status Portugal's payments-relevant regulatory position is defined almost entirely by one fact: the end of its Markets in Crypto-Assets transitional regime on 1 July 2026, and the thin authorisation count that followed. Lei n.º 69/2025 is the domestic statute executing the Markets in Crypto-Assets Regulation, and it designates Banco de Portugal as the competent authority for asset-referenced tokens and e-money tokens, with the Comissão do Mercado de Valores Mobiliários taking other crypto-assets and conduct matters. That split is clear, settled, and unaffected by anything found. What is live is the transition from provisional to final authorisation status for the population of firms that had been trading under the pre-30 December 2024 registration carve-out. That carve-out expired on 1 July 2026, and operating without full authorisation after that date is treated as a very serious administrative offence. The European Securities and Markets Authority's interim crypto-asset service provider register, dated 7 October 2026, shows only one Portugal-supervised entity with completed authorisation, a figure an industry body has described as indicative of an authorisation-pipeline bottleneck relative to the rest of the Union. No other payments module shows material movement for Portugal: licensing and market access for traditional payment and e-money institutions, conduct and safeguarding obligations, operational resilience requirements, scheme and network rules, correspondent-banking access, and consumer-protection and fraud frameworks all remain as previously recorded, with no in-window development located. #### Outlook The authorisation count on the ESMA interim register is the figure to track for Portugal going forward. Whether it begins to rise toward a level more proportionate to the market that operated under transitional cover, or remains flat, will determine whether this reads as a one-off processing lag at the October snapshot date or a more durable capacity constraint at Banco de Portugal and the Comissão do Mercado de Valores Mobiliários. No other Portuguese payments-regulatory development is currently flagged as pending. 1 earlier update not shown here. ###### Standing brief · as of 11 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Portugal's payments and crypto-asset regulatory status this cycle reflects concurrent activity across licensing and corridor infrastructure. The Markets in Crypto-Assets Regulation was transposed via Law 69/2025, in force since January 2026, with CMVM and Banco de Portugal sharing supervisory responsibility for crypto-asset service providers depending on service type, and a transitional window for pre-MiCA operators closing 1 July 2026. Non-bank payment institutions and electronic-money institutions remain authorised and supervised by Banco de Portugal under the RJSPME (Decree-Law No. 91/2018), pending an expected 2027 migration to the unified PSD3/PSR regime. On the corridor-infrastructure side, Portugal has fully implemented the EU Instant Payments Regulation, with mandatory SEPA Instant send-and-receive and Verification of Payee in force since 9 October 2025, operating alongside the dominant domestic MB WAY scheme, which is now interoperable with Spain and Italy via the EuroPA initiative. #### Outlook The two Portugal-specific dates to track are the 1 July 2026 close of the MiCA transitional window and the still-estimated 2027 PSD3/PSR national transposition. Instant-payments infrastructure is comparatively settled following the 9 October 2025 mandatory-compliance date, leaving the licensing perimeter as the primary source of near-term regulatory change for Portuguese payments and crypto firms. Read full brief · 538 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market Access1 gapConfirmedconfirmed 2026-07-04▾# Portugal operates under the RJSPME (Decree-Law No 91/2018) transposing PSD2/EMD2, supervised by Banco de Portugal, with MiCA now transposed via Law 69/2025 and PSD3/PSR migration expected 2027. Open gap — wpm-int-1 No Banco de Portugal press-release feed item dated inside the 2026-10-18-25 window was located for EMI/PI authorisations or sanctions. merchant-acquiring ops Horizon · 2026-04-23 (± a quarter) PSD3/PSR final compromise text approval Adopted · Tier 3 source Horizon · 2027-Q4 (± more than a year) PSD3 EMI reauthorisation as PI deadline Adopted · Tier 3 source Horizon · 2027-Q2 (± a year) PSD3/PSR national transposition/direct application Adopted · Tier 3 source Horizon · 2026-Q4 (± a quarter) PSD3/PSR Official Journal publication Adopted · Tier 3 source Standing sub-brief · as of 5 July 2026 341 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Portugal's payments licensing architecture runs two parallel tracks, and the distinction between them is the module's analytical spine. Non-bank payment institutions and e-money institutions are authorised by Banco de Portugal under the RJSPME (Decree-Law 91/2018): PIs under Article 13(1), as companies whose main activity is providing payment services, and EMIs under Article 14(1), as issuers of e-money within the meaning of Article 2(ff). A domestic small-PI/EMI exemption track also exists under Article 37 RJSPME, consolidated by Executive Order 239/2019, applying where the monthly average of the preceding 12 months' payment transaction value does not exceed EUR3 million and no management-level money-laundering or terrorist-financing convictions exist -- a materially lighter-touch route than full PSD2 authorisation for smaller domestic players. The bank-PSP route runs on an entirely different authority. Credit institutions, governed by the RGICSF (Decree-Law 298/92, Article 1-A(1)), are authorised exclusively by the European Central Bank within the Single Supervisory Mechanism for euro-area participating states -- BdP has no independent authorisation power over this population. Around 150 credit institutions operate in Portugal, with the market concentrated among four large groups: Caixa Geral de Depositos, Millennium BCP, Santander Totta and BPI. This bank/non-bank split matters commercially: a fintech or PSP seeking to operate in Portugal must decide at the outset whether to pursue the non-bank PI/EMI route through BdP or partner with (or become) a credit institution subject to ECB authorisation -- two routes with materially different capital, governance and supervisory-relationship implications. No material change in this baseline licensing architecture was identified this cycle; both tracks are confirmed as stable, standard EEA PSD2/EMD2 and CRD/CRR transpositions. #### Outlook The licensing architecture itself is not in flux, but its interaction with newer regimes is: entities holding PI/EMI authorisation may increasingly need to layer MiCA CASP authorisation (W2) or DORA compliance (W3) on top of their base RJSPME licence, and the distinction between bank and non-bank routes will remain relevant wherever new product categories -- stablecoins, open banking -- test which authorisation track is the natural home for a given activity. Read full sub-brief · 341 words Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Portugal's payment-institution and e-money-institution licensing framework remains anchored in Decree-Law 91/2018, the existing PSD2-based regime under which Banco de Portugal continues to supervise authorised institutions. The reason this baseline has not moved this cycle is that the successor framework, the PSD3/PSR legislative package, has not yet reached the point where domestic transposition or implementation could begin. The package's final compromise texts, carried in Council documents ST-8221/8222-2026-INIT, were endorsed by the European Parliament's ECON committee on 5 May 2026, but the package still awaits a full plenary vote, Council sign-off, and Official Journal publication. That publication is now expected by December 2026, later than earlier timetables anticipated, and until it occurs the clock toward general application cannot formally start. Once published, the Payment Services Regulation's general application is expected to follow approximately 21 months after entry into force, which on current scheduling would place substantive application in the first half of 2028 rather than earlier. Verification-of-Payee obligations, which require payment-service providers to confirm that a payee's name matches the account holder before a transfer completes, are phased in on a longer clock still, at approximately 27 months after entry into force. The PSD3 directive component, which requires national transposition, runs on the same underlying timetable as the directly-applicable PSR, so Portuguese market participants, including payment institutions, e-money institutions and banks, face a licensing and authorisation landscape that remains governed by the current regime for a materially longer period than had been anticipated when the package was first negotiated. This delay is a European Union-wide scheduling matter rather than anything specific to Portugal's domestic implementation capacity, and Banco de Portugal's supervisory posture under the current regime has not been reported as changing in response to the delay. The practical consequence for market-access planning is that firms seeking authorisation or passporting arrangements into or via Portugal over the next twelve to eighteen months should expect to do so under the existing Decree-Law 91/2018 framework, with the PSD3/PSR transition representing a 2027-to-2028 horizon event rather than an immediate consideration. #### Outlook The next concrete milestone to watch is Official Journal publication of the PSD3/PSR package, now expected by December 2026. Once that occurs, the approximately 21-month clock to general application, and the longer approximately 27-month clock for Verification-of-Payee obligations specifically, will begin running in earnest, pointing toward substantive compliance obligations for Portuguese-licensed and Portuguese-passporting payment institutions, e-money institutions and banks materialising around the first half of 2028. Until publication occurs, no further change to Portugal's licensing and market-access landscape under this package is expected, and Banco de Portugal's continued administration of the current PSD2-based regime should be read as the stable baseline against which the eventual PSD3/PSR transition will be measured. 4 earlier distinct update(s) Periodic update · new data 2026-09-21 #### Licensing, Authorisation & Market Access Portugal's payment-services licensing framework remains anchored in PSD2 as transposed via Decree-Law No. 91/2018 of 12 November 2018, administered by Banco de Portugal. This is a Confirmed finding, directly sourced to Banco de Portugal's own published guidance, and it establishes that PSD2 continues to govern authorisation and market access for payment institutions and electronic-money institutions in Portugal today, pending replacement by the PSD3/PSR package. That replacement package advanced materially this cycle: the PSD3/Payment Services Regulation (PSR) proposed text reached national-representative approval on 22 April 2026, with Banco de Portugal and the Ministry of Finance having participated in the underlying negotiations through 2025-2026. This is a Probable finding for the reform-stage transition and a Confirmed finding, sourced to Banco de Portugal's own annual payment-systems report, for the regulator's continued participation. Once formally adopted, PSD3, as a directive, will require Portuguese national transposition into domestic law, while the PSR, as a regulation, will apply directly across Portugal without a national transposition step — a structural distinction operators should track separately, since PSR-governed obligations will take effect on the EU-wide schedule regardless of Portugal's own transposition timeline for PSD3. The practical consequence for market participants is a bifurcated near-term landscape: PSD2/DL 91/2018 remains the operative licensing and authorisation framework for payment institutions and electronic-money institutions today, while the PSD3/PSR successor framework is now at an advanced negotiation stage but not yet in force. Both bank-PSP and non-bank payment-institution/EMI licensees currently operate under the same PSD2-derived DL 91/2018 authorisation regime administered by Banco de Portugal; the PSD3/PSR transition, once it takes effect, is expected to carry forward this same institutional split rather than introduce a new licensing category, though the precise treatment of non-bank PIs/EMIs under the final PSR text was not established in this cycle's evidence. #### Outlook The item to watch is the pace of PSD3's formal adoption following the 22 April 2026 national-representative approval stage, and the subsequent national transposition timeline for Portugal, which the current reform-horizon estimate places at roughly 12-18 months following formal adoption. The PSR's direct-application timeline should be tracked separately, since it does not depend on Portuguese transposition in the way PSD3 does. Periodic update · new data 2026-09-11 #### Licensing, Authorisation & Market Access The European Parliament and Council reached provisional political agreement on the third Payment Services Directive (PSD3) and the accompanying Payment Services Regulation (PSR) on 27 November 2025, with COREPER invited to approve final compromise texts on 22-23 April 2026. This is a confirmed, major EU payments-regulation milestone with direct applicability to Portugal as an EU member state, and it will fundamentally restructure the market-access framework for both bank and non-bank payment providers. PSD3 and the PSR will repeal and replace both PSD2 and the second E-Money Directive with a single, merged supervisory framework covering payment institutions and electronic money institutions together. A critical consequence for Portugal's market is that existing electronic money institutions, which have operated under a distinct EMD2-derived authorisation from Banco de Portugal, will need to seek reauthorisation as payment institutions under the new merged regime. This is a direct market-access impact affecting the non-bank payment-institution and e-money-institution population operating in Portugal, distinct from the bank-supervised segment of the market, and it will require affected institutions to undertake a fresh authorisation process rather than a simple registration update. The practical effect is a multi-year transition window during which EMIs currently licensed in Portugal must plan for reauthorisation, likely triggering renewed fit-and-proper assessments, capital adequacy review, and governance-framework scrutiny by Banco de Portugal as the merged framework's national implementation takes shape following the April 2026 compromise-text approval. #### Outlook The final compromise-text approval expected in April 2026 will set the formal legislative adoption clock running, after which national implementation timelines, including the specific reauthorisation deadline and process for Portuguese EMIs, will become clearer. Portuguese non-bank payment institutions and electronic money institutions should treat this as the trigger point to begin reauthorisation planning ahead of the eventual national implementing deadline. Periodic update · new data 2026-08-24 #### Licensing, Authorisation & Market Access Banco de Portugal is confirmed as Portugal's lead supervisor for payment institutions and electronic-money institutions under the national transposition of the second Payment Services Directive (PSD2), a directly-sourced finding from Banco de Portugal's own legislation page. The PI/EMI licensing regime carries an initial capital requirement banded between EUR 20,000 and EUR 350,000 depending on licence class, a statutory decision clock of approximately three months, and an expectation that the licensed entity maintain a Portuguese-resident director. These figures derive from a Tier-3 vendor source and merit corroboration against Banco de Portugal's own published fee and capital schedule. For entities seeking to combine payment services with crypto-asset activity, CMVM and Banco de Portugal jointly cover the MiCA crypto-asset service provider (CASP) authorisation perimeter, meaning a dual-licensed entrant faces two coordinating, rather than competing, supervisors. This bank-PSP versus non-bank-PI/EMI distinction matters throughout Portugal's payments regime: the capital-band and resident-director expectations described above apply to the non-bank PI/EMI population specifically, while credit institutions offering payment services sit within the heavier prudential perimeter of their banking licence. #### Outlook No forward regulatory date specific to W1a was surfaced this cycle. The item to watch is whether Banco de Portugal publishes updated fee or capital-schedule guidance that would allow independent verification of the EUR 20,000-350,000 capital band currently sourced from a single vendor summary. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Portugal's payments and crypto-asset licensing perimeter is undergoing simultaneous change on two fronts. On the crypto-asset side, Law 69/2025 transposes the Markets in Crypto-Assets Regulation into Portuguese law, in force since January 2026, with a transitional window for pre-MiCA-registered crypto-asset operators closing 1 July 2026; after that date, such operators must hold full MiCAR authorisation to continue operating. Supervisory responsibility for MiCA-authorised crypto-asset service providers is split between the CMVM and Banco de Portugal depending on the specific service type offered, an architecture that requires operators to identify the correct supervisory counterparty per licensable activity rather than dealing with a single crypto regulator. On the payment-institution and electronic-money-institution side, the governing instrument remains the Regime Jurídico dos Serviços de Pagamento e da Moeda Eletrónica (RJSPME, Decree-Law No. 91/2018), whose Article 14(1) defines electronic-money-institution authorisation, with Banco de Portugal as the authorising and prudential supervisor for both PI and EMI licences. This bank-versus-nonbank distinction matters structurally: non-bank PIs and EMIs are authorised and supervised under this dedicated regime rather than under general banking-licence provisions. A structural shift is on the horizon for this population specifically: Portuguese PIs and EMIs are expected to migrate to the unified PSD3/PSR regime around 2027, following the European Commission's June 2023 legislative proposal and the 2025 provisional political agreement, with national transposition typically following roughly eighteen months after the instrument's entry into force. Until that migration occurs, RJSPME remains the operative framework, and the current PI/EMI authorisation pathway through Banco de Portugal continues unchanged. #### Outlook The nearer-dated milestone is the 1 July 2026 close of the MiCA transitional window, which converts what is currently a grace period into a hard authorisation requirement for any pre-MiCA-registered crypto-asset operator still active in Portugal. The PSD3/PSR migration for PIs and EMIs remains a 2027-horizon item whose exact transposition date is still an estimate; operators in the non-bank PI/EMI population should treat the RJSPME framework as the operative regime for now while tracking the PSD3/PSR timeline for the next structural transition. Evidence 6 Sources and findings (6) - T1[https://www.bportugal.pt/en/page/application-authorisation-payment-institution](https://www.bportugal.pt/en/page/application-authorisation-payment-institution)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/application-authorisation-payment-institution](https://www.bportugal.pt/en/page/application-authorisation-payment-institution)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/application-authorisation-electronic-money-institution](https://www.bportugal.pt/en/page/application-authorisation-electronic-money-institution)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/application-authorisation-credit-institution](https://www.bportugal.pt/en/page/application-authorisation-credit-institution)retrieved 2026-07-04 - T3[https://www.lexology.com/library/detail.aspx?g=9d6a1d79-da88-4996-9cb8-ee768a1702a5](https://www.lexology.com/library/detail.aspx?g=9d6a1d79-da88-4996-9cb8-ee768a1702a5)retrieved 2026-07-04 - T3[https://crassula.io/guides/licenses/portugal-emi-pi/](https://crassula.io/guides/licenses/portugal-emi-pi/)retrieved 2026-07-04 ### W1bConduct, Safeguarding & PromotionsConfirmedconfirmed 2026-07-04▾# Safeguarding of PI/EMI client funds follows the PSD2 Article 10 segregation-or-insurance model, supervised by Banco de Portugal alongside its broader banking conduct supervision mandate. BdP has tightened internal-control and governance expectations via Notice 2/2025, and financial-promotion/advertising rules for products and services remain under active regulatory development. Standing sub-brief · as of 5 July 2026 277 words · last cycle 2026-07-04 #### Conduct, Safeguarding & Promotions Portugal's payment institutions and e-money institutions safeguard client funds under the PSD2 Article 10 regime, which permits either the Segregation Method or the Insurance Method. Under the Segregation Method, safeguarded funds must be held in a separate account with an authorised credit institution, or invested in secure liquid assets, by close of the following business day -- the baseline protection standard for non-bank PI/EMI customers in Portugal as elsewhere in the EEA. A challenge-stage correction is material here. BdP's Notice No 2/2025, published 20 March 2025, does not stand as a freestanding governance instrument; it amends the base Notice No 3/2020 framework covering governance, internal-control systems and organisational culture for supervised institutions. The amended framework addresses sound administrative and accounting procedures, gender-neutral remuneration policies, and suitability requirements for members of management and supervisory bodies. Institutions tracking their governance obligations should read Notice 2/2025 as a layer on top of the still-live Notice 3/2020 baseline, not as its replacement. On promotions, a new BdP notice governing advertising of financial products and services and institutional advertising was under public consultation as of late December 2025. Whether that consultation has since closed, whether the notice has been finalised, or whether it remains pending, is unverified as of this July 2026 cycle -- a currency gap flagged for next-cycle verification given financial-promotion enforcement is an under-indexed category in this methodology's bias-correction framework. #### Outlook The trajectory here is escalating rather than stable: the governance-notice correction resolves one open question, but the advertising-notice's live status is the clearer near-term watch item, together with how safeguarding practice evolves as PIs/EMIs increasingly intermediate stablecoin-adjacent products under the new MiCA framework (W2). Read full sub-brief · 277 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5264](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5264) Applies beyond this jurisdiction (EU)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/banking-conduct-supervision](https://www.bportugal.pt/en/page/banking-conduct-supervision)retrieved 2026-07-04 - T2[https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/portugal/trends-and-developments](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/portugal/trends-and-developments)retrieved 2026-07-04 - T3[https://abreuadvogados.com/en/conhecimento/publications/mica-in-portugal-highlights-of-the-new-implementing-law/](https://abreuadvogados.com/en/conhecimento/publications/mica-in-portugal-highlights-of-the-new-implementing-law/)retrieved 2026-07-04 - T3[https://www.iflr.com/article/2fn8ndkg7a80l45uq4dmo/sponsored/banking-finance-guide-2025-portugal](https://www.iflr.com/article/2fn8ndkg7a80l45uq4dmo/sponsored/banking-finance-guide-2025-portugal)retrieved 2026-07-04 ### W2Stablecoins & Digital Moneymoved1 judgmentlimited signalConfirmedconfirmed 2026-07-04▾# Portugal completed MiCA implementation via Law 69/2025 (published 22 December 2025), establishing a twin-peaks CASP supervisory model splitting duties between Banco de Portugal (prudential, ARTs/EMTs) and CMVM (conduct, other crypto-assets). A transitional window for pre-MiCA-registered entities runs to 1 July 2026. Prior to this law Portugal had no dedicated national stablecoin framework. Movement — CHANGED ESMA interim CASP register shows only 1 PT-supervised CASP authorisation as of 2026-10-07 New T3-sourced data point on PT's MiCA authorisation-pipeline throughput. Key judgment — Probable · impact ELEVATED PT's MiCA transitional end-date (1 July 2026) has produced an authorisation-pipeline bottleneck, with only one CASP authorised against a potentially larger applicant pool. claims: wpm-2026-W43-003 Horizon · 2026-Q2 (± six months) Bison Bank MiCA-compliant stablecoin planned launch Adopted, not yet in force · Tier 3 source Horizon · 2026-07-01 (± a quarter) MiCA transitional deadline for legacy-registered CASPs expires In force · Tier 3 source Standing sub-brief · as of 5 July 2026 260 words · last cycle 2026-10-25 #### Stablecoins & Digital Money Portugal now has, for the first time, a dedicated national framework governing crypto-assets and stablecoins. Law 69/2025, published 22 December 2025, transposes MiCA nationally through a twin-peaks supervisory model: Banco de Portugal holds prudential authority, including authorisation of asset-referenced and e-money token issuance and of crypto-asset service providers, together with prudential and governance supervision; CMVM supervises market conduct. Before this law, there were no specific national guidelines or legislation governing stablecoins in Portugal at all -- the new framework is a genuine regime shift rather than an incremental update, and it establishes the licensing gateway that banks and PSPs must now use to offer stablecoin or CASP products domestically. The framework's transitional provisions have now reached their deadline. Entities registered under Portugal's prior national regime were permitted to continue operating until 1 July 2026, or until their MiCA authorisation was granted or refused, whichever occurred first. That date has passed as of this cycle's 4 July 2026 reference point. Whether the CASP authorisation register is now complete for previously-registered entities -- and what enforcement posture BdP/CMVM will take toward any that have not yet secured authorisation -- is unverified this cycle; this is flagged as an active market-access cliff-edge to monitor directly rather than assume resolved. #### Outlook Two forward markers matter most: post-deadline completeness of the MiCA CASP register, and the pace at which bank-led stablecoin products (see Bison Bank, W13) come to market under the new authorisation gateway. Both will determine whether Law 69/2025's twin-peaks model translates into an orderly transition or a contested one. Read full sub-brief · 260 words Periodic update · new data 2026-10-25 #### Stablecoins & Digital Money Portugal's digital-money regulatory architecture passed a structural inflection point. Lei n.º 69/2025, the domestic statute implementing the Markets in Crypto-Assets Regulation, designates Banco de Portugal and the Comissão do Mercado de Valores Mobiliários as the two competent authorities, splitting supervisory responsibility by instrument type: Banco de Portugal takes asset-referenced tokens and e-money tokens, the categories most relevant to stablecoin-style digital money, while the Comissão do Mercado de Valores Mobiliários takes other crypto-assets and market-conduct matters. That competence split is settled law and has not changed. What has changed, structurally if not legally, is the end of the transitional cover that let firms registered with Banco de Portugal before 30 December 2024 continue operating pending full authorisation. That window closed on 1 July 2026. From that date, an entity continuing to provide crypto-asset services in Portugal without having obtained full Markets in Crypto-Assets authorisation is treated as committing a very serious administrative offence under the domestic implementing statute. The practical test of how the regime is working in practice is therefore the pace at which firms that were operating under transitional cover have converted that cover into full authorisation. The European Securities and Markets Authority's interim register of crypto-asset service providers supplies that test, and the result is notable. As of the file dated 7 October 2026, only one Portugal-supervised entity appears as fully authorised, a count markedly smaller than the hundreds of authorisations recorded across the European Union as a whole. An industry body has characterised this gap as an authorisation-pipeline risk, implying either that the volume of firms seeking authorisation in Portugal specifically is modest, or that a backlog exists at one or both of the two competent authorities, or some combination of both. The evidence available does not distinguish between these explanations, and no statement from Banco de Portugal or the Comissão do Mercado de Valores Mobiliários addressing processing timelines or expected clearance volumes has been located. For firms operating payment or e-money products with a digital-asset dimension in Portugal, or counterparties relying on Portuguese-authorised entities for passported services into other Union member states, the practical consequence is a narrower-than-expected set of lawful counterparties in the near term. A completed Markets in Crypto-Assets authorisation carries a bloc-wide passport under Article 65 of the Regulation, so the low Portuguese authorisation count also constrains how much passported capacity originates from Portugal specifically, relative to firms authorised in jurisdictions that have processed larger volumes of applications more quickly. This finding sits alongside, but is legally distinct from, the token-classification and prudential architecture that MiCA establishes across the Union; nothing in the evidence suggests any change to that underlying taxonomy or to the asset-referenced-token and e-money-token prudential regime as applied in Portugal. The signal here is specifically about authorisation throughput, not about the substantive content of the rules being applied. #### Outlook The metric to watch into the next reporting window is movement in the Portugal-supervised authorisation count on the ESMA interim register. A rise from one toward a figure more proportionate to the size of Portugal's prior transitional-registration population would suggest the October snapshot caught a processing lag rather than a durable bottleneck; a count that stays flat across successive cycles would support reading this as a structural capacity constraint at the competent authorities rather than a timing artefact. No regulatory-horizon item addressing a planned fix to authorisation throughput has been identified, so this remains a pure monitoring question rather than one with an announced remediation path attached. 1 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money Portugal's MiCA transitional regime for pre-existing crypto-asset service providers ended on 1 July 2026, closing a window that had allowed firms registered with Banco de Portugal to continue operating pending full authorisation. Bison Bank obtained the first full Crypto-Asset Service Provider authorisation at around this point, reported 30 July 2026, and was the only market participant holding a full authorisation at the close of the transitional window. The governing instrument, Lei 69/2025, divides supervisory responsibility: Banco de Portugal is the competent authority for Titles III and IV of MiCA, covering the issuance of asset-referenced tokens and e-money tokens, while CMVM supervises Chapter 3 of Title V and Articles 66 and 70 to 72, the conduct-facing provisions governing how crypto-asset services are offered to customers. This division is structurally significant for stablecoin issuers and digital-money providers operating in or into Portugal: an entity issuing an asset-referenced or e-money token engages primarily with Banco de Portugal's prudential remit, while an entity providing crypto-asset services to Portuguese customers engages with CMVM's conduct remit, and many firms will need to satisfy both depending on their business model. The single-authorisation-holder position at the transitional deadline signals a market-access bottleneck for other pre-existing registrants, several of which Banco de Portugal itself warned risked lapsing into unauthorised status. #### Outlook Whether further full CASP authorisations are granted beyond Bison Bank in the near term is the key item to watch; this will determine whether the current concentration in Portugal's licensed digital-asset market persists through the remainder of 2026 or begins to broaden as other pre-existing registrants complete the full-authorisation process. Evidence 5 Sources and findings (5) - T3[https://www.dlapiper.com/en/insights/publications/2025/12/legal-alert-portugal-implements-laws-on-crypto-assets-and-transfer-of-funds-regulations](https://www.dlapiper.com/en/insights/publications/2025/12/legal-alert-portugal-implements-laws-on-crypto-assets-and-transfer-of-funds-regulations)retrieved 2026-07-04 - T3[https://coincentral.com/bison-bank-launches-portugals-first-mica-compliant-stablecoin/](https://coincentral.com/bison-bank-launches-portugals-first-mica-compliant-stablecoin/)retrieved 2026-07-04 - T3[https://www.macedovitorino.com/en/knowledge/insights/New-rules-for-the-crypto-asset-market/6865/](https://www.macedovitorino.com/en/knowledge/insights/New-rules-for-the-crypto-asset-market/6865/)retrieved 2026-07-04 - T3[https://abreuadvogados.com/wp-content/uploads/2025/12/Country-Update-Portugal-Crypto-asset-regulation-2025.pdf](https://abreuadvogados.com/wp-content/uploads/2025/12/Country-Update-Portugal-Crypto-asset-regulation-2025.pdf)retrieved 2026-07-04 - T3[https://coingeek.com/portugal-bison-bank-expands-into-crypto-with-stablecoin-initiative/](https://coingeek.com/portugal-bison-bank-expands-into-crypto-with-stablecoin-initiative/)retrieved 2026-07-04 ### W3Operational Resilience & Critical InfraConfirmedconfirmed 2026-07-04▾# DORA (Regulation (EU) 2022/2554) has been fully applicable since 17 January 2025, with Banco de Portugal designated as the national ICT-incident focal point and mandated to cooperate formally with ASF and CMVM. This layers atop pre-existing PSD2-based major-incident reporting obligations (Instruction 01/2019). Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/portugal/) Standing sub-brief · as of 5 July 2026 188 words · last cycle 2026-09-21 #### Operational Resilience & Critical Infra The EU's Digital Operational Resilience Act (Regulation (EU) 2022/2554) has been fully applicable since 17 January 2025, and Portugal's implementing arrangements designate Banco de Portugal as the national focal point for major ICT-incident notifications and for voluntary reporting of significant cyber threats, with formal cooperation duties running among BdP, ASF and CMVM. This layers a harmonised EU-wide resilience regime on top of the pre-existing PSD2 Instruction 01/2019 incident-reporting framework that PIs and EMIs already operated under. The national DORA implementing law also carries a sanctions regime: infringements may draw fines of up to EUR5 million, 10% of total annual turnover, or three times the economic benefit derived, applicable to both legal entities and natural persons, with serious and very serious enforcement decisions subject to public disclosure. No PT-specific deviation from the harmonised EU baseline was identified this cycle; the module remains stable. #### Outlook With the regime now over a year into full applicability, the next signal to watch is enforcement activity -- whether BdP begins publishing DORA-related sanctions decisions, which would test the practical bite of the EUR5 million/10%-turnover/3x-benefit framework against Portuguese institutions. Read full sub-brief · 188 words Periodic update · new data 2026-09-21 #### Operational Resilience & Critical Infrastructure Banco de Portugal introduced an incremental macroprudential tightening measure this cycle, setting the countercyclical capital buffer at 0.75% of risk-weighted national banking-sector credit exposures, effective 1 January 2026. This sits on top of the standard 4.5% Common Equity Tier 1 (CET1) requirement and the 2.5% capital-conservation buffer already applicable to Portuguese banks. This is a Probable finding, sourced to a law-firm summary of the regulator-set buffer rather than a direct Banco de Portugal primary-source citation this cycle. The buffer applies to the national banking sector's risk-weighted credit exposures generally, rather than being a payments-specific or payment-institution-specific measure; it is most directly relevant to bank-PSPs holding banking licences and subject to the full CET1/buffer stack, rather than to non-bank payment institutions or electronic-money institutions, which are typically subject to a different, non-bank-specific prudential regime under PSD2/DL 91/2018 rather than the CET1 capital-buffer framework applicable to credit institutions. This distinction matters for assessing which categories of payment-services providers in Portugal are directly affected by the buffer increase: bank-PSPs face a modestly higher capital-adequacy bar from 1 January 2026, while non-bank PI/EMI licensees operating under the separate payment-institution prudential regime are not directly captured by this specific buffer setting. The buffer increase is incremental rather than a signal of acute stress in the Portuguese banking sector; it is consistent with a routine macroprudential calibration exercise rather than a response to any identified vulnerability in the evidence reviewed this cycle. #### Outlook The item to watch is whether Banco de Portugal signals any further countercyclical buffer adjustments in subsequent macroprudential reviews, and whether any clarification emerges on how the buffer setting interacts with payment institutions that hold partial banking authorisations or operate under hybrid licensing arrangements. 1 earlier distinct update(s) Periodic update · new data 2026-08-24 #### Operational Resilience & Critical Infrastructure The Digital Operational Resilience Act (DORA) applies directly to Portuguese credit institutions and financial companies, including payment institutions and electronic-money institutions, running alongside the Capital Requirements Regulation's (CRR) capital-buffer requirements. Separately, Banco de Portugal set the countercyclical capital buffer at 0.75 percent of risk-weighted domestic credit exposures, effective 1 January 2026. The two obligations are distinct in scope and audience: DORA's ICT-risk-management, incident-reporting, and third-party-risk provisions apply across both bank and non-bank payment firms, while the countercyclical buffer is a bank-balance-sheet prudential setting. A non-bank PI or EMI operating in Portugal therefore experiences the full weight of DORA's resilience-testing regime without the offsetting capital-buffer context that shapes how credit institutions experience the same framework. #### Outlook No Portugal-specific forward date beyond the already-effective 1 January 2026 buffer setting was located this cycle. The item to watch is how DORA's supervisory examination cycle plays out in practice for Portuguese non-bank payment firms specifically, an area not yet covered by the sourcing reached this cycle. Evidence 5 Sources and findings (5) - T3[https://www.mlgts.pt/en/knowledge/legal-alerts/Legal-Alert-Implementation-of-the-DORA-Regulation-in-Portugal/26484/](https://www.mlgts.pt/en/knowledge/legal-alerts/Legal-Alert-Implementation-of-the-DORA-Regulation-in-Portugal/26484/)retrieved 2026-07-04 - T3[https://www.mlgts.pt/en/knowledge/legal-alerts/Legal-Alert-Implementation-of-the-DORA-Regulation-in-Portugal/26484/](https://www.mlgts.pt/en/knowledge/legal-alerts/Legal-Alert-Implementation-of-the-DORA-Regulation-in-Portugal/26484/)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/legislation-and-regulations-psd2](https://www.bportugal.pt/en/page/legislation-and-regulations-psd2)retrieved 2026-07-04 - T3[https://practiceguides.chambers.com/practice-guides/fintech-2026/portugal/trends-and-developments](https://practiceguides.chambers.com/practice-guides/fintech-2026/portugal/trends-and-developments)retrieved 2026-07-04 - T3[https://cyberupgrade.net/blog/compliance-regulations/dora-regulations-in-portugal-and-impact-for-all-industries/](https://cyberupgrade.net/blog/compliance-regulations/dora-regulations-in-portugal-and-impact-for-all-industries/)retrieved 2026-07-04 ### W4Scheme & Network Compliance1 gapConfirmedconfirmed 2026-07-04▾# Multibanco, operated by SIBS, is Portugal's dominant domestic card/interbank scheme, co-badged with Visa/Mastercard for international use. Interchange fees are capped under EU Regulation 2015/751. SIBS was fined by the national competition authority in 2024 for tying scheme access to its processing services. Open gap — wpm-int-2 No scheme/network rule change for PT in-window was located. financial-promotion enforcement Standing sub-brief · as of 5 July 2026 203 words · last cycle 2026-08-21 #### Scheme & Network Compliance Multibanco, operated by SIBS, remains Portugal's dominant domestic card and interbank scheme, co-badged with Visa and Mastercard for international acceptance. Debit interchange is capped at 0.2% and credit interchange at 0.3% under the EU Interchange Fee Regulation (Reg. (EU) 2015/751) -- the same EU-wide caps applicable across the bloc, with no Portugal-specific variation. The scheme's dominance is now under sustained competition-law pressure. The Autoridade da Concorrencia (AdC) fined SIBS Group EUR13,869,000 for tying processing services to scheme access, following a Statement of Objections issued 28 July 2022; SIBS held over 90% market share in the affected markets across roughly three years of the tying practice. SIBS has appealed the decision. Under Portuguese administrative law, an appeal does not automatically suspend execution of the fine unless SIBS can demonstrate considerable harm and provide effective guarantees -- meaning the fine's practical effect may persist through the appeal period regardless of its eventual outcome, which remains unconfirmed this cycle. #### Outlook The AdC appeal is the clearest near-term marker for this module: its resolution will determine whether SIBS's scheme-access practices are confirmed as an antitrust violation on appeal or overturned, with direct implications for how acquirers and PSPs negotiate Multibanco access going forward. Read full sub-brief · 203 words Periodic update · new data 2026-08-24 #### Scheme & Network Compliance The EU Instant Payments Regulation (Regulation (EU) 2024/886) requires Portuguese payment service providers that already offer standard credit transfers to also offer instant credit transfers at no additional charge, together with mandatory Verification of Payee (VoP) checks on domestic and euro-area transfers, a finding sourced directly to Banco de Portugal. Banco de Portugal itself co-developed the Eurosystem's VoP reference solution together with Latvijas Banka, and this solution was live ahead of the EU-wide October 2025 VoP mandate, a directly-sourced ECB finding. This positions Portugal among the earlier movers in the EU's instant-payments scheme-compliance rollout rather than a jurisdiction implementing the mandate at the deadline. #### Outlook The item to watch next cycle is whether Banco de Portugal's early VoP infrastructure role extends into further Eurosystem instant-payments initiatives, and whether PT-specific VoP false-positive or fraud-detection performance data becomes available as the scheme matures. Evidence 5 Sources and findings (5) - T1[https://www.bportugal.pt/en/perguntas-frequentes/258](https://www.bportugal.pt/en/perguntas-frequentes/258)retrieved 2026-07-04 - T1[https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes](https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes)retrieved 2026-07-04 - T1[https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes](https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes)retrieved 2026-07-04 - T3[https://www.paymentyearbooks.com/sample-report/](https://www.paymentyearbooks.com/sample-report/)retrieved 2026-07-04 - T1[https://competition-policy.ec.europa.eu/system/files/2021-10/IFR_report_card_payment.pdf](https://competition-policy.ec.europa.eu/system/files/2021-10/IFR_report_card_payment.pdf) Applies beyond this jurisdiction (EU)retrieved 2026-07-04 ### W5Payment Corridor DynamicsConfirmedconfirmed 2026-07-04▾# As a euro-area member, Portugal's cross-border rails run through the Eurosystem's TARGET2/T2 RTGS platform and TIPS instant-settlement service, with SEPA SCT/SCT Inst/SDD schemes governing retail euro payments. Portugal migrated to TARGET2 in the system's second wave in 2008. Horizon · 2026-10 (± a quarter) Instant Payments Regulation second-wave compliance window opens for PIs/EMIs In force · Tier 3 source Standing sub-brief · as of 5 July 2026 112 words · last cycle 2026-10-18 #### Payment Corridor Dynamics As a euro-area member, Portugal's cross-border payment rails run through the Eurosystem's TARGET2 RTGS system and TIPS instant-settlement service, with SEPA Credit Transfer, SCT Instant and SEPA Direct Debit governing retail euro payments. Portugal migrated to TARGET2 in the system's second migration wave, on 18 February 2008. This corridor infrastructure is long-established and unchanged this cycle: no disruption to euro-area access or settlement arrangements was identified. #### Outlook Corridor dynamics remain the most stable element of Portugal's payments environment; the principal forward development to watch is not a corridor-access change but the digital euro's technical readiness phase (W9), which will eventually run alongside, rather than replace, the existing TARGET2/TIPS/SEPA architecture. Read full sub-brief · 112 words Periodic update · new data 2026-10-18 #### Payment Corridor Dynamics The Instant Payments Regulation's second wave began its compliance clock in October 2026, extending the instant-transfer-receiving obligation that previously applied only to banks onto payment institutions and e-money institutions. Euro-area payment institutions and e-money institutions now have a six-month window from that starting point to begin receiving instant transfers, while banks outside the euro area have been given a shorter three-month window. This is a meaningful widening of the instant-payments corridor's reach within Portugal's payments ecosystem: payment institutions and e-money institutions, which had previously been exempted from the receiving-side obligation imposed on banks in the regulation's first wave, now face the same requirement, closing a gap in instant-transfer coverage that had persisted between bank and non-bank payment-service-provider categories. Portugal enters this second-wave compliance window from a position of comparatively high existing adoption. Reported data shows the share of instant transfers among total transfers in Portugal rising from 25% in 2024 to 80% in 2025, a trajectory that reflects substantial infrastructure build-out and consumer-behaviour shift well ahead of the October 2026 compliance-window opening for payment institutions and e-money institutions specifically. While that adoption data describes the market broadly rather than isolating the payment-institution and e-money-institution segment specifically, it indicates that the underlying corridor infrastructure, including the interbank and inter-provider settlement rails that instant transfers depend on, was already substantially mature in Portugal before the second-wave obligation reached the non-bank segment. Banco de Portugal's own Verification-of-Payee infrastructure, built in part on solutions developed jointly with Latvijas Banka for the Eurosystem-wide Verification-of-Payee scheme, represents a related corridor-level capability that sits alongside, though is governed on a separate track from, the Instant Payments Regulation's receiving-side obligations addressed here. The two capabilities, instant-transfer receipt and payee-name verification, are complementary parts of the same broader instant-payments corridor architecture, with Verification-of-Payee obligations under PSD3/PSR phasing in on the later, approximately 27-month, timetable discussed separately under the PSD3/PSR licensing development. #### Outlook The immediate question for the payment-institution and e-money-institution segment specifically is whether the six-month compliance window opened in October 2026 proceeds without disruption, given that Portugal's broader instant-transfer adoption curve, already at roughly 80% of total transfers by 2025, suggests the corridor infrastructure these institutions will need to plug into is largely already in place. No PT-specific gap-assessment data isolating payment institutions and e-money institutions from the broader adoption figures has been located this cycle, so the extent to which this segment specifically still needs to build out receiving capability, as opposed to simply connecting to existing rails, remains unconfirmed. The non-euro-area bank three-month window, shorter than the payment-institution and e-money-institution six-month window, is not directly applicable to Portugal as a euro-area jurisdiction, but is noted here as the comparative corridor-dynamics backdrop against which the euro-area timetable should be read. 3 earlier distinct update(s) Periodic update · new data 2026-09-11 #### Payment Corridor Dynamics Portugal's cross-border instant-payment interoperability network expanded in July 2026 when the Greek IRIS payment system launched cross-border instant transfers with Italy, Portugal, and Spain, joining the European Payments Alliance (EuroPA) alongside SIBS (Portugal's Multibanco/MB WAY operator), Bizum (Spain), and Bancomat (Italy). This is a probable-confidence development extending PT-linked instant-payment interoperability beyond the original three-country alliance into a fourth national market, deepening the corridor dynamics that link Southern European domestic instant-payment schemes into a broader regional network. Alongside this corridor expansion, a separate and less certain data point concerns the commercial weight of Portugal's domestic rails themselves: one vendor estimate reports that Multibanco and MB WAY wallet-and-reference rails hold dominant e-commerce checkout share in Portugal, with wallet share specifically estimated at 18 to 22 percent of card transactions. This claim carries only uncertain confidence, resting on a single vendor-source market-data estimate rather than an official statistics release, but it underscores the commercial significance of the underlying rails whose cross-border reach EuroPA's expansion is now extending. The combination of a dominant domestic checkout rail and an expanding cross-border interoperability network positions Portugal's non-bank payment-institution ecosystem, principally SIBS as the scheme operator behind Multibanco and MB WAY, as an increasingly consequential node in Southern European payment-corridor dynamics. #### Outlook Further EuroPA membership expansion beyond the current four-country footprint would reinforce Portugal's position as an anchor node in Southern European instant-payment interoperability. Independent verification of the MB WAY/Multibanco wallet-share estimate against an official or multi-source dataset would materially strengthen confidence in the commercial-significance reading of this corridor. Periodic update · new data 2026-08-24 #### Payment Corridor Dynamics Portugal's domestic instant-transfer rail settles directly via TIPS, the Eurosystem's real-time gross settlement service, with a maximum ten-second crediting window operating twenty-four hours a day, seven days a week. MB WAY is the dominant domestic mobile-payment scheme, processing at national-rail scale and functioning as the primary customer-facing initiation layer for Portugal's instant-payments corridor even though underlying settlement runs through TIPS rather than through MB WAY's own infrastructure. For an entrant assessing corridor strategy, the practical implication is that customer-facing product design in Portugal needs to account for MB WAY's incumbency at the initiation layer independent of the entrant's own settlement-rail choice. #### Outlook No forward-looking corridor-specific date was located this cycle. The item to watch is whether MB WAY's national-rail-scale position shifts as EU Instant Payments Regulation compliance becomes universal across PT PSPs, potentially narrowing MB WAY's current initiation-layer advantage. Periodic update · new data 2026-08-11 #### Payment Corridor Dynamics Portugal's domestic and SEPA-wide payment-corridor infrastructure reached full mandatory status this cycle under EU-level instant-payments rules. Regulation (EU) 2024/886, the Instant Payments Regulation, has required mandatory send-and-receive of euro instant credit transfers in under ten seconds, twenty-four hours a day, seven days a week, since 9 October 2025, and this obligation now applies fully within the Portuguese corridor. Alongside the transfer mandate, a Verification of Payee IBAN-name check has been mandatory for SEPA Instant transfers since the same date, with the underlying Eurosystem VoP service building on technical solutions to which Banco de Portugal was a contributor alongside Latvijas Banka. The practical effect for the Portuguese corridor is that settlement-friction and beneficiary-mismatch risk on instant transfers have both been addressed at the infrastructure level, ahead of, and independent of, the separate MiCA and PSD3 licensing-perimeter changes affecting the same market. Within this now-mandatory instant-rail environment, MB WAY continues to hold the dominant position as Portugal's mobile instant-payment product. Built on the Multibanco network, MB WAY is now interoperable with comparable mobile payment products in Spain and Italy through the EuroPA initiative, extending its corridor reach beyond purely domestic transactions. This combination — a fully mandatory, harmonised EU instant-payments backbone plus a dominant, increasingly cross-border-interoperable domestic scheme sitting on top of it — defines the current shape of the Portuguese payment-corridor landscape. #### Outlook With SEPA Instant and Verification of Payee both now embedded as mandatory, 24/7 infrastructure, the corridor-dynamics picture for Portugal is comparatively settled relative to the still-moving licensing perimeter tracked elsewhere. The item to watch is the pace and depth of MB WAY's EuroPA interoperability expansion, which would extend Portugal's dominant domestic scheme's reach further into the Spanish and Italian corridors rather than displacing it with a pan-EU alternative. Evidence 4 Sources and findings (4) - T1[https://www.bportugal.pt/en/page/target2](https://www.bportugal.pt/en/page/target2)retrieved 2026-07-04 - T3[https://en.wikipedia.org/wiki/TARGET2](https://en.wikipedia.org/wiki/TARGET2)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/target-instant-payment-settlement](https://www.bportugal.pt/en/page/target-instant-payment-settlement)retrieved 2026-07-04 - T1[https://www.ecb.europa.eu/paym/retail/instant_payments/html/index.en.html](https://www.ecb.europa.eu/paym/retail/instant_payments/html/index.en.html) Applies beyond this jurisdiction (EU)retrieved 2026-07-04 ### W6Industry Structure & CommercialConfirmedconfirmed 2026-07-04▾# Portugal's payments market is anchored by SIBS's Multibanco/MB WAY infrastructure with near-universal bank participation, alongside a growing layer of international PSPs (Stripe, Adyen, PayPal, Revolut) using EU passporting and domestic fintechs (Eupago, easyPay, ifthenpay) bridging SMEs into local rails. Banking remains concentrated among a handful of large groups, with NovoBanco's ownership in transition. Standing sub-brief · as of 5 July 2026 190 words · last cycle 2026-07-04 #### Industry Structure & Commercial Dynamics Portugal's most significant recent financial-sector ownership change has concluded. NovoBanco's sale process -- initiated in summer 2024, formalised via a memorandum of understanding in June 2025 and a sale-and-purchase agreement in October 2025 -- completed on 30 April 2026, with BPCE acquiring NovoBanco for a final price of approximately EUR6.7 billion. This corrects the original research framing, which had characterised the sale as merely "expected to occur in 2025"; the transaction is now confirmed closed, with implications for market concentration and cross-border banking-group consolidation in Portugal. Beneath this headline transaction, Portugal's broader payments market structure remains anchored by SIBS's Multibanco and MB WAY infrastructure, which commands near-universal bank participation. International PSPs -- Stripe, Adyen, PayPal, Revolut -- operate via EU passporting rights alongside domestic fintechs such as Eupago, easyPay and ifthenpay, which bridge SMEs into local payment rails. This structural landscape is unchanged this cycle aside from the NovoBanco transaction. #### Outlook With the NovoBanco/BPCE deal now closed, the next structural question is how BPCE integrates NovoBanco into its wider European banking-group footprint, and whether further consolidation follows among Portugal's remaining mid-tier banking and payments players. Read full sub-brief · 190 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://thepaypers.com/payments/expert-views/portugal-an-analysis-of-payments-and-ecommerce-trends](https://thepaypers.com/payments/expert-views/portugal-an-analysis-of-payments-and-ecommerce-trends)retrieved 2026-07-04 - T3[https://thepaypers.com/payments/expert-views/portugal-an-analysis-of-payments-and-ecommerce-trends](https://thepaypers.com/payments/expert-views/portugal-an-analysis-of-payments-and-ecommerce-trends)retrieved 2026-07-04 - T3[https://practiceguides.chambers.com/practice-guides/fintech-2026/portugal/trends-and-developments](https://practiceguides.chambers.com/practice-guides/fintech-2026/portugal/trends-and-developments)retrieved 2026-07-04 - T3[https://iclg.com/practice-areas/fintech-laws-and-regulations/portugal](https://iclg.com/practice-areas/fintech-laws-and-regulations/portugal)retrieved 2026-07-04 - T3[https://www.lexology.com/library/detail.aspx?g=9d6a1d79-da88-4996-9cb8-ee768a1702a5](https://www.lexology.com/library/detail.aspx?g=9d6a1d79-da88-4996-9cb8-ee768a1702a5)retrieved 2026-07-04 ### W7Legal & LitigationConfirmedconfirmed 2026-07-04▾# The most significant recent payments-sector enforcement action is the Portuguese Competition Authority's 2024 fine against SIBS for tying scheme access to processing services. Banco de Portugal separately runs sanctioning proceedings against credit institutions and payment institutions for AML, conduct, and consumer-information breaches, backed by broad inspection and fining powers. Standing sub-brief · as of 5 July 2026 179 words · last cycle 2026-07-04 #### Legal & Litigation Banco de Portugal holds broad inspection and fining powers over credit institutions and payment institutions for anti-money-laundering, conduct and consumer-information breaches, including the power to publish sanctions and warnings; recent enforcement activity spans AML control failures and conduct-rule breaches across the payment-institution population. The single most significant competition-law action in this space is the AdC's fine against SIBS Group, and the module's live development is SIBS's response to it: SIBS has announced it will contest the roughly EUR13.9 million fine for abuse of dominant position. Under Portuguese administrative law, an appeal does not suspend fine execution unless SIBS demonstrates considerable harm and provides effective guarantees, meaning the practical consequences of the AdC decision may take hold before the appeal is resolved. The appeal's outcome is unconfirmed this cycle. #### Outlook Resolution of the SIBS appeal is the clearest litigation marker to track into the next cycle; a confirming decision would harden the AdC's tying-abuse theory as applied precedent for scheme-access disputes, while a reversal would reopen questions about how SIBS's scheme-access practices should be regulated going forward. Read full sub-brief · 179 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes](https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes)retrieved 2026-07-04 - T3[https://www.iflr.com/article/2fn8ndkg7a80l45uq4dmo/sponsored/banking-finance-guide-2025-portugal](https://www.iflr.com/article/2fn8ndkg7a80l45uq4dmo/sponsored/banking-finance-guide-2025-portugal)retrieved 2026-07-04 - T3[https://www.uria.com/documentos/colaboraciones/3620/documento/portugal.pdf?id=13645_en&forceDownload=true](https://www.uria.com/documentos/colaboraciones/3620/documento/portugal.pdf?id=13645_en&forceDownload=true)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/oversight](https://www.bportugal.pt/en/page/oversight)retrieved 2026-07-04 ### W8Merchant Acquiring & RiskConfirmedconfirmed 2026-07-04▾# Card acquiring in Portugal is structurally dependent on SIBS scheme access for Multibanco/MB WAY acceptance, a dependency that was central to the 2024 AdC tying-abuse finding. International acquirers (Adyen, Worldline, and others) compete alongside SIBS-linked local providers, with acquirer liability for merchant chargebacks and fraud governed by general EU card-scheme and PSD2 conduct rules rather than a distinct Portuguese acquiring statute. Standing sub-brief · as of 5 July 2026 136 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk Card acquiring in Portugal is structurally dependent on SIBS scheme access for Multibanco and MB WAY acceptance -- the same dependency at the centre of the AdC's 2024 tying-abuse finding against SIBS (W4, W7). International acquirers such as Adyen and Worldline compete alongside SIBS-linked local providers, but they do so under general EU card-scheme rules and PSD2 conduct requirements rather than any dedicated Portuguese acquiring statute; no distinct national merchant-acquiring or high-risk-MCC regime exists. This absence limits the granularity of acquirer-specific risk analysis available for the Portuguese market and is flagged as an under-indexed category for future-cycle attention. #### Outlook The acquiring landscape will track the SIBS appeal outcome (W4/W7) closely, since any change to SIBS's scheme-access obligations would directly affect the competitive terms on which international and domestic acquirers operate in Portugal. Read full sub-brief · 136 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes](https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes)retrieved 2026-07-04 - T1[https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes](https://www.concorrencia.pt/en/articles/adc-fines-sibs-group-abusing-its-dominant-position-accessing-domestic-payment-schemes)retrieved 2026-07-04 - T2[https://www.docs.pay.sibs.com/portugal/](https://www.docs.pay.sibs.com/portugal/)retrieved 2026-07-04 - T3[https://thepaypers.com/payments/expert-views/portugal-an-analysis-of-payments-and-ecommerce-trends](https://thepaypers.com/payments/expert-views/portugal-an-analysis-of-payments-and-ecommerce-trends)retrieved 2026-07-04 ### W9Product Innovation & Market DevelopmentConfirmedconfirmed 2026-07-04▾# MB WAY is Portugal's leading domestic mobile-payment product, built on SIBS rails. Regulatory sandboxes (Portugal FinLab, the Technological Free Zones/ZLT regime, and CMVM's Market4Growth sandbox) support fintech testing, while open banking/TPP adoption remains structurally slow due to Multibanco dominance. Banco de Portugal is engaged in the Eurosystem's digital euro project, now in its technical readiness phase. Horizon · 2026 (± a year) Digital euro Regulation expected adoption Proposed · Tier 1 source Horizon · 2027-Q4 (± six months) Digital euro pilot test expected to begin Adopted, not yet in force · Tier 1 source Standing sub-brief · as of 5 July 2026 156 words · last cycle 2026-07-04 #### Product Innovation & Market Development The digital euro project entered its technical readiness phase on 1 November 2025, expected to run for 26 months, preparing for potential issuance in 2029 assuming the underlying Regulation is adopted in 2026; a pilot test is planned for the end of 2027. Banco de Portugal participates in this work as a Eurosystem national central bank. Separately, Portugal's fintech-sandbox infrastructure includes the Technological Free Zones established under Decree-Law 67/2021 and CMVM's Market4Growth sandbox, launched 22 November 2023. Despite this testing infrastructure, open-banking and third-party-provider adoption remains structurally slow: as of October 2024, Portugal had no domestically registered third-party providers, a gap attributable in part to Multibanco's continuing market dominance. #### Outlook The digital-euro timeline (Regulation adoption expected in 2026, pilot testing planned for late 2027) is the clearer near-term marker; the open-banking adoption lag is a slower-moving structural question tied directly to whether Multibanco's dominance (W4) is loosened by ongoing competition scrutiny. Read full sub-brief · 156 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.bportugal.pt/en/page/digital-euro-project](https://www.bportugal.pt/en/page/digital-euro-project)retrieved 2026-07-04 - T3[https://iclg.com/practice-areas/fintech-laws-and-regulations/portugal](https://iclg.com/practice-areas/fintech-laws-and-regulations/portugal)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/fintech](https://www.bportugal.pt/en/page/fintech)retrieved 2026-07-04 - T3[https://noda.live/articles/open-banking-in-portugal](https://noda.live/articles/open-banking-in-portugal)retrieved 2026-07-04 - T3[https://www.imarcgroup.com/portugal-fintech-market](https://www.imarcgroup.com/portugal-fintech-market)retrieved 2026-07-04 ### W10Consumer Protection & APP FraudConfirmedconfirmed 2026-07-04▾# Consumer protection in payments runs through Banco de Portugal's complaints book (Livro de Reclamações) and Bank Customer Website channels, alternative dispute resolution bodies, and Law 24/2023's financial-services consumer protection package. Fraud-related complaints have risen sharply as a share of total complaints, though BdP's own remedial power is limited to compliance verification rather than compensation orders. Standing sub-brief · as of 5 July 2026 139 words · last cycle 2026-09-11 #### Consumer Protection & APP Fraud Banco de Portugal's complaints channel recorded an 80% year-on-year increase in complaints, with fraud allegations behind 47.4% of them -- a significant escalation in consumer-facing risk signals. BdP's own remedial power under direct complaints handling is limited to compliance verification rather than compensation orders; consumers seeking financial redress must rely on the courts for that remedy, a structural limitation on the regulator's consumer-protection toolkit. Separately, Law 24/2023 (29 May) imposes consumer-protection limitations on financial-services charges, including a prohibition on commissions for photocopies and duplicate statements -- part of the baseline consumer-protection legislative framework. #### Outlook The fraud-complaint surge is the clearer escalating signal in this module; whether BdP's compliance-verification-only remedial model comes under pressure to expand toward direct compensation powers, given the scale of the complaint increase, is a question worth tracking into subsequent cycles. Read full sub-brief · 139 words Periodic update · new data 2026-09-11 #### Consumer Protection & APP Fraud The PSR and PSD3 package will materially broaden consumer-protection obligations around payment fraud once adopted. Verification-of-payee checks, which currently apply only within the scope of the Instant Payments Regulation for SEPA Instant credit transfers, will be extended to cover all wire transfers under the new framework. This is a confirmed development at the EU legislative level, directly applicable to Portuguese payment service providers as an EU member state, and represents a substantive widening of the payee-verification safety net beyond its current instant-payment-only scope to standard, non-instant wire transfers as well. Alongside the verification-of-payee extension, the PSR/PSD3 package introduces new authorised-push-payment fraud reimbursement obligations. This directly addresses a consumer-protection gap in the current framework, where liability allocation for APP fraud losses has been inconsistent across payment service providers and member states. For Portuguese consumers and the payment institutions serving them, this represents a forward-looking tightening of consumer-protection standards tied directly to the broader PSD3/PSR legislative package moving toward final adoption. #### Outlook The scope and mechanics of the new APP-fraud reimbursement obligation, including liability-allocation rules between sending and receiving institutions, will become clearer once the final PSD3/PSR compromise texts are approved and national implementation begins. Portuguese payment service providers should anticipate operational changes to extend verification-of-payee infrastructure beyond current SEPA Instant scope ahead of the eventual implementation deadline. Evidence 5 Sources and findings (5) - T1[https://www.bportugal.pt/en/page/oversight](https://www.bportugal.pt/en/page/oversight)retrieved 2026-07-04 - T3[https://www.theportugalnews.com/news/2024-04-12/banking-complaints-soar/87881](https://www.theportugalnews.com/news/2024-04-12/banking-complaints-soar/87881)retrieved 2026-07-04 - T3[https://www.uria.com/documentos/colaboraciones/3620/documento/portugal.pdf?id=13645_en&forceDownload=true](https://www.uria.com/documentos/colaboraciones/3620/documento/portugal.pdf?id=13645_en&forceDownload=true)retrieved 2026-07-04 - T3[https://www.uria.com/documentos/colaboraciones/3620/documento/portugal.pdf?id=13645_en&forceDownload=true](https://www.uria.com/documentos/colaboraciones/3620/documento/portugal.pdf?id=13645_en&forceDownload=true)retrieved 2026-07-04 - T1[https://clientebancario.bportugal.pt/en/consumer-disputes](https://clientebancario.bportugal.pt/en/consumer-disputes)retrieved 2026-07-04 ### W11AML/CFT & Financial CrimeSourced from Sentinel.gi ↗Confirmedconfirmed 2026-07-04▾# SENTINEL.GI POSITION (payments-context carry only). Banco de Portugal supervises AML/CFT compliance for its regulated entities under Law 83/2017, recently strengthened by Laws 70/2025 (Travel Rule/crypto-asset AML integration and AMLA cooperation) and 72/2025 (restrictive-measures sanctions regime). Portugal's most recent FATF assessment characterises its AML/CFT regime as sound and effective. Horizon · 2026-Q4 (± a quarter) 6AMLD transposition reply deadline for Portugal Proposed · Tier 3 source Standing sub-brief · as of 5 July 2026 143 words · last cycle 2026-10-11 #### AML/CFT & Financial Crime This module's intelligence is sourced from the Sentinel.gi feed rather than original WPM analysis; illicit-finance findings are attributed to that feed and linked out rather than re-analysed here. Portugal's most recent FATF mutual evaluation characterises its AML/CFT regime as sound and effective, with recommended improvement in the implementation of measures applicable to non-financial businesses and professions. Laws 70/2025 and 72/2025, in force since December 2025, strengthen the framework further: Law 70/2025 implements the Travel Rule under Regulation (EU) 2023/1113 and formalises AMLA/EBA cooperation duties, while Law 72/2025 introduces restrictive-measures criminal offences; both amend the base Law 83/2017 AML/CFT and sanctions framework. #### Outlook These developments are flagged onward to the Financial Intelligence Monitor for continued illicit-finance analysis, including any downstream implications of the new stablecoin framework (W2) for Travel Rule compliance; this brief draws no independent illicit-finance conclusions from them. Read full sub-brief · 143 words Periodic update · new data 2026-10-11 #### AML/CFT & Financial Crime The European Commission sent a letter of formal notice to Portugal, together with 17 other Member States, on 25 September 2026, over incomplete transposition of Directive (EU) 2024/1640, the sixth Anti-Money Laundering Directive, specifically Articles 11, 12, 13 and 15, which govern access to central beneficial-ownership registers for competent authorities, self-regulatory bodies, obliged entities, and persons able to show a legitimate interest. This intelligence is fed through the Sentinel.gi feed; readers seeking the underlying illicit-finance analysis should refer to that feed directly, as this monitor does not re-analyse the illicit-finance substance. The payments-sector relevance of this gap lies in its upstream effect on payment service providers' and e-money institutions' customer-due-diligence and beneficial-ownership-identification duties, which in practice depend on the completeness and accessibility of the national beneficial-ownership register. The transposition deadline was 10 July 2026, and Portugal has a two-month window to reply, running to approximately late November 2026. #### Outlook Portugal's response to the European Commission within the reply window, to approximately late November 2026, is the item to watch for payment institutions and e-money institutions relying on the national beneficial-ownership register for CDD purposes. Evidence 7 Sources and findings (7) - T3sentinel.dlapiper.com/en-us/insights/publications/2026/03/aml-cft-and-sanctions-in-2026 - T?FIM (sentinel.gi) per-JID baseline profile — Portugal — Portugal has a technically sound AML/CFT legal framework (Law 83/2017 transposing EU AMLDs; RCBE beneficial-ownership register since 2018) supervised by Banco de Portugal (financial sector, incl. VASPs) and CMVM (securities). FATF's 2017 MER found the regime sound but flagged weak DNFBP implementation, low conviction rates and real-estate/legal-person vulnerabilities that persist structurally. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: absent-field-provenance - T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: EU listing - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: enforcement-absence - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap ### W12Correspondent Banking, Settlement & Accesslimited signalConfirmedconfirmed 2026-07-04▾# Portuguese credit institutions and, where enabled, non-bank PIs/EMIs access central-bank settlement via TARGET2/T2 and TIPS as Eurosystem participants, removing the need for a separate domestic correspondent-banking network for euro transactions. Banco de Portugal is part of the Single Supervisory Mechanism and Single Resolution Mechanism as the national resolution and supervisory authority. Standing sub-brief · as of 5 July 2026 122 words · last cycle 2026-08-21 #### Correspondent Banking, Settlement & Access The bank-versus-non-bank access asymmetry is this module's analytical spine, and in Portugal that asymmetry is narrower than in many jurisdictions. Portuguese credit institutions, and non-bank payment institutions and e-money institutions where enabled, access central-bank settlement directly via TARGET2/T2 and TIPS as Eurosystem participants -- removing the need for a separate domestic correspondent-banking network for euro-denominated transactions. Banco de Portugal additionally sits within the Single Supervisory Mechanism and Single Resolution Mechanism as Portugal's national supervisory and resolution authority. #### Outlook With direct Eurosystem settlement access already extended to non-bank PIs/EMIs where enabled, the correspondent-banking access gap that constrains non-banks in many other jurisdictions is comparatively muted in Portugal; the module remains structurally stable with no material change this cycle. Read full sub-brief · 122 words Periodic update · new data 2026-08-24 #### Correspondent Banking, Settlement & Access Banco de Portugal settles instant transfers directly in TIPS central-bank money, a directly-sourced Banco de Portugal finding. This is the module's analytical spine: direct TIPS settlement places Portuguese payment service providers inside the Eurosystem settlement perimeter without dependence on a domestic correspondent-banking intermediation layer for retail instant payments, in contrast to jurisdictions where non-bank payment institutions must access settlement indirectly through a correspondent bank. The bank-versus-non-bank access question is therefore substantially resolved for Portugal's instant-payments corridor specifically, though this cycle's sourcing does not extend to Portugal's correspondent-banking access position for other payment rails or currencies. #### Outlook The item to watch is whether Portugal's direct-TIPS-access model for instant payments extends to any additional settlement rails, and whether any non-bank PI/EMI in Portugal reports differential settlement-access experience relative to the bank-settled TIPS model described here. Evidence 4 Sources and findings (4) - T1[https://www.bportugal.pt/en/page/target2](https://www.bportugal.pt/en/page/target2)retrieved 2026-07-04 - T3[https://advapay.eu/settlement-and-clearing-systems-in-europe-sepa-target2-and-ebics-are-explained/](https://advapay.eu/settlement-and-clearing-systems-in-europe-sepa-target2-and-ebics-are-explained/)retrieved 2026-07-04 - T1[https://www.bportugal.pt/en/page/the-bank-mission-and-tasks](https://www.bportugal.pt/en/page/the-bank-mission-and-tasks)retrieved 2026-07-04 - T3[https://en.wikipedia.org/wiki/TARGET2](https://en.wikipedia.org/wiki/TARGET2)retrieved 2026-07-04 ### W13Commercial Intelligence (M&A, Investment & Product)Probableconfirmed 2026-07-04▾# Fintech investment in Portugal accelerated markedly in 2025, with the payments/crypto segment producing the country's most notable regulatory-linked product launch (Bison Bank's MiCA-compliant stablecoin). Banking-sector M&A (NovoBanco's ongoing sale) remains the largest structural transaction shaping the industry. Standing sub-brief · as of 5 July 2026 272 words · last cycle 2026-07-04 #### Commercial Intelligence Four discrete commercial events populate this module's baseline. First, Bison Bank announced plans to launch Portugal's first MiCA-compliant, fiat-pegged stablecoin, targeting introduction in the first half of 2026 alongside other blockchain-based services -- an amount not publicly disclosed, and the earliest identified bank-led stablecoin product initiative in the Portuguese market ahead of the full MiCA framework's maturation (W2). Second, BPCE completed its acquisition of NovoBanco on 30 April 2026 for a final price of approximately EUR6.7 billion, following the October 2025 sale-and-purchase agreement and the June 2025 memorandum of understanding with Portugal's Resolution Fund -- the largest recent PT financial-sector M&A transaction, correcting the original research's "expected 2025" framing (see also W6). Third, MB WAY formed a partnership with ECOMMPAY in January 2025 to improve the e-commerce payments experience in Portugal, giving merchants enhanced online payment options; the value of this partnership was not publicly disclosed. Fourth, at the market level, Portuguese fintech companies raised $71.2 million in equity funding across eight rounds through September 2025, versus $31 million across six rounds in the same period of 2024 -- a 129.83% year-on-year increase. As of January 2026, 310 active fintech companies had collectively raised $408 million, led by Ethena at $156 million; this aggregate metric is a market-level indicator rather than a single discrete event. #### Outlook The clearest near-term marker is whether Bison Bank's stablecoin launches within its targeted first-half-2026 window; more broadly, the combination of completed banking M&A, rising fintech funding and an early bank-led stablecoin product suggests continuing commercial momentum in Portuguese payments even as the underlying MiCA and safeguarding frameworks (W1b, W2) are still settling into practice. Read full sub-brief · 272 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://tracxn.com/d/explore/fintech-startups-in-portugal/__38FtfxfYPbd2pJZUtqxCh8JGBgKppSUXFGloU3fktGw](https://tracxn.com/d/explore/fintech-startups-in-portugal/__38FtfxfYPbd2pJZUtqxCh8JGBgKppSUXFGloU3fktGw)retrieved 2026-07-04 - T3[https://tracxn.com/d/explore/fintech-startups-in-portugal/__38FtfxfYPbd2pJZUtqxCh8JGBgKppSUXFGloU3fktGw](https://tracxn.com/d/explore/fintech-startups-in-portugal/__38FtfxfYPbd2pJZUtqxCh8JGBgKppSUXFGloU3fktGw)retrieved 2026-07-04 - T3[https://coingeek.com/portugal-bison-bank-expands-into-crypto-with-stablecoin-initiative/](https://coingeek.com/portugal-bison-bank-expands-into-crypto-with-stablecoin-initiative/)retrieved 2026-07-04 - T3[https://iclg.com/practice-areas/fintech-laws-and-regulations/portugal](https://iclg.com/practice-areas/fintech-laws-and-regulations/portugal)retrieved 2026-07-04 - T3[https://www.imarcgroup.com/portugal-fintech-market](https://www.imarcgroup.com/portugal-fintech-market)retrieved 2026-07-04 No modules match. 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