Obligations of the Credit Intermediary in Portugal (2025)

If you work as a credit intermediary authorised by the Banco de Portugal (Portuguese Central Bank), you need to know your legal, administrative, compliance and ethical obligations. This guide covers everything from registration through to client relations.

1. Registration and Reporting to the Banco de Portugal

You must keep your registration up to date at all times. Any relevant change, such as registered office, partners, responsible persons, contracts or insurance, must be reported within the legal deadline, generally 15 days. If there is a substantial change in activity, you will need to apply for a new authorisation. The Banco de Portugal must be notified of appointments of directors, technical managers and holders of qualifying holdings. Situations affecting good repute or technical capacity must be reported immediately, as well as the commencement of activity in another EU Member State.

2. Professional Civil Liability Insurance

Your insurance must be valid, renewed and appropriate to your activity at all times. You must send proof to the Banco de Portugal at each renewal and upon request. The insurance must cover all activity, all channels and all employees, including specific coverage for each tied contract where applicable.

3. Contracts and Relationship with Lenders

All tied contracts must be filed and include the clauses required by law. Each new contract, termination or cancellation must be reported to the Banco de Portugal. You may not delegate or subcontract intermediation activity.

4. Duties of Conduct and Client Information

You must provide clear, complete, truthful and free-of-charge information. For untied intermediaries, presenting available alternatives is essential. The Consumer Information Sheet (FINE) and mandatory documents must be delivered before the contract is signed. All costs, rates, terms, risks and client rights must be explained. Undue commercial pressure, discriminatory practices and breaches of professional secrecy are not permitted.

5. Advertising and Communication

Comply with the rules set out in BdP Notice No. 5/2024. Always identify the intermediary and registration number in all advertising. Ensure legibility, contrast and prior approval from the lender in credit product advertising. Never suggest that you are the one granting credit. Keep all advertising materials and supporting documents on file for 5 years.

6. Training and Competences

Ensure initial and ongoing training for employees and technical managers. Document all training undertaken and update competences when new rules or products emerge. Prohibit the exercise of duties by anyone who does not meet the legal qualification requirements.

7. Internal Organisation and Compliance

Maintain an adequate administrative and commercial structure. Implement policies on conflicts of interest and data protection. Establish secure filing systems and adopt internal procedures for control, risk management and compliance.

8. Prevention of Money Laundering and Terrorist Financing

Comply fully with Law No. 83/2017. Identify and verify clients as required by anti-money laundering legislation.

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Summary: Obligations range from administrative reporting to the Banco de Portugal to rigorous duties of conduct with clients, ongoing training and regulatory compliance.

Related reading

• Credit Intermediary in Portugal: The Complete Guide — the single reference on credit intermediation in Portugal.
• Banco de Portugal Tightens Rules for Credit Intermediaries in 2026 — how these obligations will become even tougher in 2026.
• Want to Become a Credit Intermediary? With Legal Support, Everything Becomes Easier — the best way to meet all these duties without mistakes.