What is a credit intermediary?
A credit intermediary is a natural or legal person who, not being a credit institution or financial company, is authorised by Banco de Portugal to carry out intermediation activities in credit agreements, under the terms of Decree-Law no. 81-C/2017.
In practice, the intermediary acts as a bridge between the client (the person looking for credit, typically a mortgage or consumer loan) and the lenders (banks and financial institutions). They search for the best solution available on the market, present proposals, advise the client and, in many cases, accompany the process all the way to the deed.
This is a regulated activity, with strict rules on client information, mandatory training, professional civil liability insurance and periodic reporting to Banco de Portugal. In Portugal, the sector has grown year after year, in line with the complexity of the banking market and the demand for specialised advice.
Legal framework in Portugal
The legal regime applicable to credit intermediaries is set out in Decree-Law no. 81-C/2017, of 7 July, which transposed Directive 2014/17/EU on credit agreements for consumers relating to residential immovable property (MCD) into Portuguese law. This regulation defines who can carry out the activity, under what conditions, the existing categories and the applicable obligations.
Banco de Portugal is the authority responsible for authorising, registering and supervising intermediaries, and it is also the main official source for confirming access requirements, training, registration and ongoing update obligations.
Beyond the sectoral regime, the GDPR (protection of clients' personal data), the anti-money laundering and counter-terrorist financing regime, the RCBE (central register of beneficial owners) and the general rules of Commercial and Tax law all apply across the board. Knowing this framework is critical — read the complete guide to obligations for details.
If your goal is to move forward with support from the beginning, you can also see our dedicated legal support page to obtain the credit intermediary licence.
Categories of credit intermediary
When applying for authorisation from Banco de Portugal, you must choose one of the three recognised categories. Each has its own rules, specific obligations and direct impact on the business model.
1. Tied credit intermediary
A natural or legal person acting in the name and under the full and unconditional responsibility of one or more lenders with whom they hold a binding agreement. Remunerated exclusively by the lenders; charging the client is prohibited (article 58 of Decree-Law 81-C/2017).
2. Credit intermediary on an ancillary basis
Provides goods or services and, in the name and under the full and unconditional responsibility of the lender, intermediates the credit needed for the purchase of those goods or services (e.g. a real estate agent arranging mortgage credit). Remunerated exclusively by the lenders (article 58).
3. Non-tied credit intermediary
Only legal persons may operate in this category (article 18 of Decree-Law 81-C/2017). Acts independently, without any binding contract with lenders. Remunerated exclusively by the client; receiving any payment from lenders is prohibited (article 61).
How to become a credit intermediary in Portugal
The process has 5 main steps. All are mandatory and the order matters — if the application is incomplete or Banco de Portugal asks for clarifications, the overall timeline may become longer.
- Verification of suitability and personal requirements. Criminal record with no relevant convictions, not being insolvent, not having been banned from carrying out the activity.
- Training and professional certification. Obtaining the knowledge and competence required by law, through training suited to the category sought and the type of credit, under the rules defined by Banco de Portugal and Ordinance no. 385-B/2017.
- Professional civil liability insurance. Policy with minimum cover set by BdP, valid throughout the period of activity, with annual renewal.
- Incorporation of a company and RCBE (if a legal entity). Commercial registration, tax number (NIPC), declaration of the beneficial owner.
- Submission of the application to Banco de Portugal. Form and complete documentation, then await decision: 90 days from receipt of the application, extendable up to 180 days if BdP requests clarifications (article 20).
It is a highly document-driven process where every detail counts. See our legal support service for the licensing process — a specialised team accompanies you from the first step to the final decision, avoiding returns and delays.
Obligations of an authorised CI
Once authorised, the intermediary has ongoing duties of conduct, information and maintenance of the legal requirements. The obligations include:
- Deliver the legally required pre-contractual information, including the ESIS/FINE for housing credit, where applicable
- Keep professional civil liability insurance always up to date
- Keep registration details and legally required communications with Banco de Portugal up to date
- Maintain certified continuous training
- Comply with anti-money laundering rules
- Preserve records of each operation for the legal time periods
- Inform clients in a clear, impartial and non-misleading way
Non-compliance has serious consequences: fines, suspension or cancellation of the authorisation. Read the detailed 2025 obligations guide so you don't miss a thing.
If you are still at application stage or need help organising documentation, insurance and the structure of the request, you can ask for legal support to obtain the licence.
The intermediary's working tools
A modern credit intermediary does not work with scattered spreadsheets and loose emails. Professionalisation requires specialised tools that organise the day-to-day and reduce regulatory risk.
CRM Crédito was designed from the ground up for this activity: client pipeline by stage (prospecting, simulation, proposal, deed), process organisation, document centralisation and support for the internal management of the activity.
Using a generalist tool (e.g. a sales CRM from another sector) forces constant adaptations, leaves compliance gaps and wastes time. A platform specialised for credit intermediaries reduces errors and frees up time for what matters: closing deals.
The market in Portugal — data and trends
The credit intermediation market in Portugal is mature and growing. According to data from Banco de Portugal, the number of authorised intermediaries has increased year on year, in line with the rising demand for specialised advice on mortgage credit — the dominant segment.
Three factors explain this growth:
- Banking complexity — differences in rates, spreads, products, insurance and conditions make comparison almost impossible for the average client
- Active real estate market — Portugal continues to attract domestic and foreign buyers
- Digitalisation — clients search online, but want human advice before deciding
Read our analysis on the role of the intermediary in the mortgage credit market.
Technology, AI and the future of intermediation
Artificial intelligence and automation are transforming credit intermediation in Portugal. Tasks that used to take hours — running simulations, comparing proposals, analysing documents — now happen in minutes. Banks already use AI at scale; Novobanco, for example, has around 600 internal AI agents.
For the intermediary, AI inside a specialised CRM can support tasks such as organising information, reading documents more quickly, helping compare proposals and preparing the file internally. Learn more in our analysis on AI in credit CRMs.
At the same time, the FinTech revolution brings open banking, PSD3 and new distribution channels. Those who embrace technology gain a lasting competitive advantage.
Frequently Asked Questions
What is a credit intermediary in Portugal?
A credit intermediary is a person or company authorised by Banco de Portugal to present, propose and enter into credit agreements, or to assist in such agreements, under the terms of Decree-Law no. 81-C/2017. It does not belong to a bank but acts as a bridge between the client and financial institutions.
What are the categories of credit intermediary?
There are three categories: tied credit intermediary, credit intermediary on an ancillary basis and non-tied credit intermediary. Natural persons may only be tied or ancillary. Only legal persons can operate as non-tied credit intermediaries under Decree-Law 81-C/2017.
How long does it take to obtain the credit intermediary licence?
Banco de Portugal has a statutory deadline of 90 (calendar) days from the receipt of the application to issue its decision (article 20 of Decree-Law 81-C/2017). If clarifications or additional elements are requested, the deadline may be extended up to a maximum of 180 days from the initial submission. Including document preparation, the full process typically takes 3 to 6 months.
What are the obligations of an authorised credit intermediary?
The obligations include: keeping professional civil liability insurance up to date, complying with information duties towards the client, delivering the legally required pre-contractual information (including the ESIS/FINE for housing credit, where applicable), keeping registration details updated with Banco de Portugal, maintaining certified training requirements and complying with all applicable conduct, compliance and anti-money laundering rules.
How much does it cost to start a credit intermediary activity?
The cost varies depending on the type of structure (sole trader vs company) and the category sought. It typically includes: registration fee with Banco de Portugal, professional civil liability insurance (annual amount proportional to the size of the business), mandatory certified training, possible legal support fees, incorporation of a company if applicable and registration of the beneficial owner (RCBE).
Do I really need a CRM to manage my activity?
A CRM specialised for credit intermediaries lets you organise your client portfolio, follow the pipeline of files from simulation to deed, centralise documents and communications and support the internal organisation of the activity. Without a proper tool, management becomes slow and error-prone, increasing operational and regulatory risk.
Do I need specific training to obtain the licence?
Yes. Banco de Portugal requires adequate knowledge and competence for the activity. This may be met through an academic route, where the study plan includes the legally required minimum contents, or through professional certification based on training provided by entities certified by Banco de Portugal. The required training also depends on the type of credit you intend to intermediate.
How can I obtain the credit intermediary licence?
In general, the process involves choosing the category in which you intend to operate, confirming the personal and professional requirements, gathering the applicable training and certification, obtaining professional civil liability insurance and correctly submitting the application to Banco de Portugal. Because it is a technical and document-heavy process, specialist support may be useful.
See legal support to obtain the licence