Legal Support for Credit Intermediaries

Banco de Portugal has a legal deadline of 90 days to decide on the application, which can be extended to 180 days if additional clarifications or documents are requested. Including the document preparation phase, the full process typically takes 3 to 6 months.

Natural persons may only apply as tied or ancillary credit intermediaries. The non-tied category is reserved for legal persons (article 18 of Decree-Law 81-C/2017). If you choose a legal entity, it can already be established or be set up after authorisation — in that case, you have 6 months to submit the registration request to Banco de Portugal (article 25).

The required documents vary depending on the type of applicant, under Banco de Portugal Notice 6/2017. Generally required: identification document, up-to-date criminal record certificate, individual questionnaire, description of training and professional background with training certificates, professional civil liability insurance policy and, for companies, articles of association, description of the organisational structure and documents for the members of the corporate bodies. We help prepare everything.

No. Credit intermediation activity may only be carried out after official registration with Banco de Portugal. Practising without authorisation constitutes an administrative offence, punishable by a fine and possible temporary prohibition from exercising the activity, under DL 81-C/2017.

There are three categories: tied credit intermediary, non-tied credit intermediary and credit intermediary on an ancillary basis. The non-tied category is reserved for legal persons and each category has its own operating and remuneration rules.

After authorisation, there are ongoing obligations: keeping professional civil liability insurance in force, updating the registration details and legally required communications with Banco de Portugal, complying with conduct duties and maintaining the legal requirements applicable to the activity. Non-compliance may lead to sanctions, including fines and, in the cases provided by law, suspension or cancellation of the authorisation.

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.

The process generally involves confirming the category in which you intend to operate, validating the personal and professional requirements, gathering the applicable training and certification, obtaining professional civil liability insurance and properly preparing the application to Banco de Portugal. Because it is a technical and document-heavy process, many applications benefit from specialist support.