Banco de Portugal published a practical guide for credit intermediaries in June 2026. The first reading should be precise: this is not a new law and it does not replace the legal regime for credit intermediaries. What it does is organise, in a more operational way, rules that already came from Decree-Law No. 81-C/2017, Notice No. 6/2017, Instruction No. 16/2017 and, more recently, the advertising rules in Notice No. 5/2024.
In practice, that matters because the regulator turns scattered obligations into guides, templates and checklists. The message to the market is clear: compliance is no longer just knowing the law; it is being able to prove, every day, that each duty is applied.
What changes in practice compared with the previous framework
The core framework for credit intermediaries was created in 2017 and became fully effective from 2018. The previous rules defined who could carry out the activity, how authorisation requests were submitted, which information had to be reported to Banco de Portugal and which duties applied in the relationship with consumers.
The 2026 guide does not erase that base. It brings those rules closer to the practical reality of an inspection, a complaint or an internal review.
| Topic | Previous rules | Practical reading in 2026 |
|---|---|---|
| Access and registration | The legal regime, Notice No. 6/2017 and Instruction No. 16/2017 defined authorisation, registration, forms and documents | The intermediary should regularly confirm that requirements, contacts, insurance, links with lenders and registration elements remain updated |
| Client information | Duties to provide complete, clear, true, current and free information already existed | Banco de Portugal now provides models and reinforces the need to deliver information before the service is provided |
| Premises and website | Mandatory information already had to be visible in offices and on websites | The guide makes clearer where this information should be, how it should be presented and which elements cannot be missing |
| Advertising | Notice No. 10/2008 was the previous advertising framework | Notice No. 5/2024, in force since 1 July 2025, covers activity advertising and institutional advertising, with rules also designed for digital channels |
| Complaints and dispute resolution | Duties around complaint books and alternative dispute resolution already existed | Evidence of membership, responses, deadlines and channels becomes central to document organisation |
| Supervision | Banco de Portugal could request information and carry out inspections | The guide checklists work as a self-inspection tool and preparation for supervision |
The main difference: proving with evidence
The central point is not to presume whether intermediaries comply or fail to comply. The point is different: in a regulated activity, an obligation is easier to demonstrate when organised evidence exists. If mandatory website information is not updated, if the template delivered to the client is not stored, if a complaint is handled by email without organised history or if an advertising campaign is not archived, it becomes harder to demonstrate compliance during an internal review, complaint or supervisory action.
The Banco de Portugal practical guide points in the opposite direction. Each obligation should be verifiable with evidence:
- Which information was delivered to the client
- When it was delivered
- Which version was in force
- Which documents support the case
- Which communications were exchanged
- Which complaints existed and how they were answered
- Which advertising was published and with which mandatory elements
This is the main operational reading. Traceability becomes the centre of compliance.
Prior information: before the service, not after
One of the most relevant points is prior information to consumers. Banco de Portugal recalls that intermediaries must provide information about their activity before providing credit intermediation services, on paper or another durable medium.
This includes, among other elements, identification of the intermediary, registration number, category, lenders with whom it has a link where applicable, authorised services, complaint channels and alternative dispute resolution mechanisms. In mortgage credit, the existence and amount, where known, of commissions or incentives paid by the lender to the intermediary must also be clarified.
In many operations, this point was treated as a formality. With the 2026 guide and the new model made available by Banco de Portugal, it should be treated as a documented stage of the process.
Advertising: before and after Notice No. 5/2024
Another important comparison is advertising. The old framework was based on Notice No. 10/2008, created in a very different context, before the current intensity of social media ads, landing pages, forms, direct messages and digital lead generation campaigns.
Notice No. 5/2024 replaced that framework and entered into force on 1 July 2025. For credit intermediaries, this means advertising should not be treated only as marketing. It should be treated as a regulated area, with duties around identification, prominence, clarity, balance and prevention of confusion between intermediation and direct lending.
In practice, every ad, landing page or commercial post should be able to answer simple questions:
- Is it clear who the intermediary is?
- Is it clear that this is credit intermediation, not direct lending?
- Is the message balanced or does it promise more than it can guarantee?
- Do mandatory elements have sufficient prominence?
- Was the published version stored?
What should be reviewed now
For credit intermediaries, the best way to read the guide is not as a theoretical document. It is an internal review list.
Teams should confirm:
- Whether registration data and contacts are updated
- Whether mandatory information is visible in the premises and website
- Whether a prior information model is delivered before the service
- Whether the case stores proof of that delivery
- Whether advertising campaigns comply with Notice No. 5/2024
- Whether physical and electronic complaint books are correctly available
- Whether membership of alternative dispute resolution entities is evidenced
- Whether the team knows where to find each proof item in case of supervision
Conclusion
The practical guidance from Banco de Portugal should not be read as a new law for credit intermediaries. It should be read as a sign of sector maturity. The previous rules remain the base, but the operational expectation is clearer: informal compliance is no longer enough; teams need to organise, record and demonstrate.
For credit intermediaries, the practical effect is simple: review procedures, update public information, keep versions delivered to clients and maintain accessible evidence. This turns a written duty into a demonstrable procedure.
Sources
- Banco de Portugal: practical guide for credit intermediaries
- Practical guide for credit intermediaries
- Banco de Portugal: prior information model and new templates
- Banco de Portugal Notice No. 6/2017
- Banco de Portugal Instruction No. 16/2017
- Banco de Portugal Notice No. 5/2024
Read also
- Credit Intermediary in Portugal: Complete Guide
- Obligations of the Credit Intermediary in Portugal
- Tied vs Non-Tied Credit Intermediary: Which to Choose in Portugal?
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