Banco de Portugal licence: legal support before submitting the request

Anyone who wants to work as a credit intermediary in Portugal must go through a mandatory step: obtaining authorisation and registration with Banco de Portugal. Before submitting the request, many professionals leave one key question too late: is the process really ready to be reviewed?

The answer is not always in the forms. It is in the category chosen, the training presented, the documentation, the insurance, the legal structure and the consistency between all these elements. That is why a legal review before submission can help reduce delays and bring more confidence to the process.

What is at stake?

Banco de Portugal explains that access to credit intermediation depends on authorisation and registration. It also states that carrying out the activity without being authorised is an offence punishable as an administrative breach.

In practice, this means that contacts, commercial experience or the will to work with housing credit and consumer credit are not enough. Before attracting clients as a credit intermediary, the applicant must meet the legal framework and submit the request correctly.

The process is submitted through the Customer Banking Portal, but preparation starts earlier. This is where many questions appear.

Why the request should be reviewed before submission

The licence request is not only an administrative matter. It is a document-heavy, regulated and technical process.

Before submission, it is important to confirm whether:

• the chosen category fits the business model;
• the activity will be carried out as an individual or through a company;
• training and professional experience are properly framed;
• professional civil liability insurance is aligned with the request;
• documents for managers and the company are complete;
• the submitted information is consistent from start to finish.

A poorly prepared application may lead to clarification requests, corrections and a longer wait. This does not mean the request will be refused, but it can make the process slower and more demanding.

How long can the decision take?

According to official information from Banco de Portugal, the decision period is generally 90 days from receipt of the request. If clarifications or additional elements are requested, that period may be extended up to 180 days after the initial submission.

That is why the phase before submission matters so much. The clearer and more organised the process is, the lower the risk of having to go back to correct documents or explain information that was not clear enough.

Legal support does not guarantee authorisation. The decision always belongs to Banco de Portugal. But it can help the applicant understand what they are declaring, which documents they are attaching and which points should be reviewed before moving forward.

Is a lawyer mandatory?

No. The law does not always require the request to be submitted by a lawyer.

Even so, many professionals and companies prefer to have legal support before submitting the licence. This is especially relevant when there is company incorporation, a change to the corporate purpose, doubts about the intermediary category, good standing analysis, training, insurance or documentation for technical managers.

More than “handling paperwork”, the goal is to confirm whether the request makes sense as a whole.

A market with demand, but under supervision

Official data shows that there is interest in the activity. On the page about the evolution of authorisation requests, Banco de Portugal states that by December 31, 2023, it had received 8,902 authorisation requests. Of those, 6,512 were approved and 2,308 were refused.

These figures show that there is demand for the sector, but also that the supervisor reviews the requests. The credit intermediary licence should therefore be seen as the first professional step of the project.

How CRM Crédito can help

CRM Crédito has a legal support area and specialised partners to assist professionals and companies that want to obtain a credit intermediary licence.

Support may include an initial diagnosis, document organisation, category framing, review of the legal structure, preparation of the request and assistance with submission to Banco de Portugal.

If you are preparing the request, or still do not know where to start, you can request an initial review with the legal support team.

Before submitting, confirm the essentials

Entering credit intermediation requires more than a commercial opportunity. It requires authorisation, registration and compliance with the applicable requirements.

Before submitting the licence request to Banco de Portugal, it is worth confirming whether the category, documents, training, insurance and project structure are aligned. A legal review at this stage can save time and give more confidence to anyone who wants to start professionally.

Official sources

• Banco de Portugal - Access to the activity of credit intermediary
• Banco de Portugal - Credit intermediary authorisation
• Banco de Portugal - Authorisation request review period
• Banco de Portugal - Evolution of authorisation requests for credit intermediaries
• Official Gazette - Decree-Law no. 81-C/2017
• Official Gazette - Banco de Portugal Notice no. 6/2017

Read next

• Credit Intermediary Licence: what you need to start in Portugal - practical guide on requirements, training and documents.
• Tied vs Non-Tied Credit Intermediary: which path should you choose? - useful for choosing the right category.
• Get a credit intermediary licence - legal support page for the licensing request.