Digital Payments & Fintech - Portugal

Payment institutions and electronic money institutions must be authorised and registered with Banco de Portugal under Title II of the RJSPME (Articles 18–23), with a decision within three months of a complete file (max 12 months from application). A small-payments exemption regime applies below a €3 million monthly average transaction threshold.

Banco de Portugal is the competent authority licensing, supervising and enforcing the payments regime. PSD2 (Directive (EU) 2015/2366) was transposed into Portuguese law by Decree-Law No. 91/2018 of 12 November 2018.

Account Information Service Providers (AISPs) and Payment Initiation Service Providers (PISPs) are licensed/registered by Banco de Portugal, and the PSD2 Regulatory Technical Standards on access to payment accounts have applied since 14 September 2019, with major Portuguese banks operating live APIs.

Portuguese banks support SEPA Instant Credit Transfer (sub-10-second, 24/7), and the EU Instant Payments Regulation (adopted 13 March 2024) mandates instant-payment availability across the euro area; domestic schemes Multibanco and MB WAY run on these rails and dominate retail payments.

Portugal has implemented MiCA via national law, designating Banco de Portugal and the CMVM as joint national competent authorities under a functional split (prudential vs. market supervision). Previously Bank-of-Portugal-registered VASPs may continue activity until 1 July 2026 or a final MiCA authorisation decision, whichever comes first.

Consumer credit (the legal basis for regulated BNPL/instalment lending) is governed by Decree-Law No. 133/2009 transposing the EU Consumer Credit Directive, under which Banco de Portugal sets and publishes quarterly maximum APR (TAEG) caps and supervises lender conduct, including a 14-day withdrawal right.